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
Comment from Sandy Chang
This is comment on Notice
Agency Information Collection Activities; Proposals, Submissions, and Approvals: Category of Plants for Planting Not Authorized for Importation Pending Pest Risk Analysis
View Comment
Attachments:
S_Chang_APHIS_Comments_July-5-2011_part1_Submitted
Title:
S_Chang_APHIS_Comments_July-5-2011_part1_Submitted
Related Comments
Public Submission Posted: 05/04/2011 ID: APHIS-2006-0011-0265
Jul 05,2011 11:59 PM ET
Public Submission Posted: 07/06/2011 ID: APHIS-2006-0011-0269
Jul 05,2011 11:59 PM ET
Public Submission Posted: 05/13/2011 ID: APHIS-2006-0011-0266
Jul 05,2011 11:59 PM ET