Comment from Sandy Chang

Document ID: APHIS-2006-0011-0269
Document Type: Public Submission
Agency: Animal And Plant Health Inspection Service
Received Date: July 05 2011, at 12:00 AM Eastern Daylight Time
Date Posted: July 6 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: May 3 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: July 5 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80eb9fa2
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I request an extension of the comment period as I have only found out about this more than two-thirds through the comment period. Note: This is intended to be part one of a two part document. The following comments are in regard to: 7 CFR Part 319 {Docket No. APHIS–2006–0011} Importation of Plants for Planting; Establishing a Category of Plants for Planting Not Authorized for Importation Pending Pest Risk Analysis These comments are meant to address some apparent errors made in the 40 page final rule document which is found in the: Federal Register / Vol. 76, No. 103 / Friday, May 27, 2011 / Rules and Regulations pages 31172-31210 URL: http://frwebgate1.access.gpo.gov/cgi-bin/PDFgate.cgi?WAISdocID=CNMw/1/2/0&WAISaction=retrieve The above document will be cited within my comments as (APHIS 2011) My comments emphasize three main points which are relevant to the Importation of Plants for Planting (APHIS–2006–0011) Final rule. The major points to be emphasized are as follows: A. Exclusion of Commenter citation numbers in (APHIS 2011), by the USDA APHIS authors, is EXTREMELY sloppy. B. A misleading statement was made in (APHIS 2011) which appears to equate the number of journal citations with how scientifically acceptable a study is. This is discussed in regard to the recent human cloning scandal. C. An apparently false statement was made in (APHIS 2011), by USDA authors, regarding the number of references which appear in Pimentel et al 2000. The following are detailed explanations of the major points I wish to emphasize: Major Point A. Exclusion of Commenter citation numbers in (APHIS 2011), by the USDA APHIS authors, is EXTREMELY sloppy. I wish to state that I found the exclusion of comment numbers in (APHIS 2011), by the USDA APHIS author(s), to be EXTREMELY unhelpful and downright sloppy. I do not know if the author(s) are: (1) simply too lazy or sloppy to correctly identify the commenter’s assigned number or (2) if the author(s) wish to p

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S_Chang_APHIS_Comments_July-5-2011_part1_Submitted

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S_Chang_APHIS_Comments_July-5-2011_part1_Submitted

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Related Comments

   
Total: 3
Comment from JEAN PUBLIC
Public Submission    Posted: 05/04/2011     ID: APHIS-2006-0011-0265

Jul 05,2011 11:59 PM ET
Comment from Sandy Chang
Public Submission    Posted: 07/06/2011     ID: APHIS-2006-0011-0269

Jul 05,2011 11:59 PM ET
Comment from Quita Sheehan
Public Submission    Posted: 05/13/2011     ID: APHIS-2006-0011-0266

Jul 05,2011 11:59 PM ET