To practice what I believe my job would be like if the federal government hired me for one of the regulatory specialist jobs for which I applied, I perused the Federal Register website. I browsed the Antitrust Division notices in particular because these could potentially be useful to mention in a cover letter to an involved firm.
Announcing its first change of membership since October 1998, the technological development consortium The Open Group, LCC submitted a notice that was published in the Federal Register on May 31. In the far-right column of page 3, the notice lists UW-Madison from Wisconsin and Van Haren Publishing from the Netherlands. Here's an annotated screen capture:
A search on the UW-Madison website returned professorial papers on UNIX-related computing such as “X server code” and “zone-based data striping.” The absence of minutes, agendas, or other reports on the UW website suggests The Open Group is more like memoranda of agreement among the participating organizations than an actual governing body. And since January 2014, Van Haren Publishing and I have been mutual followers on Twitter -- thereby giving me two ties to The Open Group.
Returning to the main page of the Federal Register website, I moved onto the list of proposed rules for which the public comment period is open. It bears mention that each web page containing proposed rule text has a comment button in the upper-right corner.
Clicking the “submit a comment” button redirects you to the appropriate rule-specific page on the Regulations.gov website, the only collective portal for any online comments to public agencies regarding their rulemaking. Otherwise, you would need to visit each agency website and submit comments through their specific channels.
Before you comment -- or technically speaking, “send a public submission” -- to any federal agency, download and read the official guidelines for creating influential comments. I especially appreciate how the document says not once, but twice, that a thousand duplicate comments or “form letters” are wasted effort unless each contributor adds his or her own experience and supporting facts to the public submission.
Remember that you are competing with think tanks and lobbying groups that have retained some of the sharpest minds -- though not all -- and therefore need to do more than act like a parrot reiterate some publicist's message on the matter!
I’ll add some helpful hints the official guidelines omitted:
1) Don’t threaten any government employee -- that would be a terroristic threat -- or anyone at all in your comment to the agency. Some issues can be highly emotional, but the last thing you need is for the agency to sic the FBI on you over a perceived threat! So play it cool; use professional language.
2) Although the guidelines state, “There is no minimum or maximum length,” the online comment submission form has a maximum length of 5,000 characters. The quickest way to check this in Microsoft Word is to highlight your comment; next, click the “Review” tab; and then, click the “Word Count” button.
If it pains you to trim part of your over-long comment, then save your omitted text for another commenting opportunity. With approximately 430 interdependent agencies proposing at least a few rules each quarter, there are many occasions for you to be heard!
My comments tend to speak generally about policy through repeated interrelated themes, each of which pertains at least tangentially to broad set of rules, so as to maximize exposure in the public record to ideas that I support.
This allows many opportunities for contacting a wide variety of agencies regarding their proposed rules and creates a megaphone effect while diversifying the commentary to suit the particular agency-promulgated rules under question.
3) If a proposed regulation hurts your personal job prospects in any way, then let the agency know your specific story. The human element is underrated in the regulatory winnowing process. Segueing from the third point, I commented on three proposals that caught my attention in terms of being relevant to me and well enough within my grasp of policy to comment both intellectually and practically. From briefest comment to longest:
The Pipe and Hazardous Materials Safety Administration is renewing oil pipeline inspection regulations, including requiring every sub-national government (regional compact, state government, municipalities, etc.) that desires to regulate intrastate oil pipelines must first be certified by PHMSA.
Here’s my comment, Tracking Number 1yj-8cff-5teo, on another facet of the regulations:
“I’m surprised an energy lobbyist hasn’t commented on these proposed rules. As an everyday citizen, I appreciate PHMSA’s requirement that operators of underwater oil pipelines must periodically inspect for any protrusion to the surface. The corrosive potential of a marine environment cannot be understated, so thank you for helping to prevent corrosion-related leakage.”
I also commented on the U.S. Fish and Wildlife Service regulation that would expand, by 24 acres, the designated critical habitat of the Vandenberg Monkeyflower. I feel sorry for whoever owns those 24 acres, as now the land cannot be developed in the foreseeable future.
If you comment by 4:59 p.m. EST on June 5, then your message will be viewable by the FWS! Here’s mine, Tracking Number 1jy-8cfv-t3dp:
“As an unemployed manual laborer and 2010 master’s graduate of the public administration program at the University of Wisconsin-Milwaukee, I’d say the job prospects of college graduates are about as endangered as the Vandenberg Monkeyflower.
Just as the FWS socks away critical habitat for endangered species, we should -- as a national grant-making policy -- partition more of the existing university system budgets to provide exclusively for internships and on-the-job training rather than for class assignments or wasteful programs such as mandatory “literary” and “inequality” studies that only serve to alternately distract and divide our potential workforce.”
My third submitted comment regards a rule proposed by Citizen and Immigration Services that would authorize 4-H nonimmigrants to apply for work visas. Part of the policymakers’ argument is that H-1B workers are more likely to remain in the U.S. and become citizens if their spouses are allowed to work here.
But why the need for so many skilled worker visas? Do our universities suck or something? *Nodding in the audience* Okay -- but the quality of our graduates reflect the universities, so university officials ought to be embarrassed at the scores of H-1B visas issued.
Thousands of positions filled by workers on visa could be filled at comparable expense by those who are already loyal to the United States; a little more training, but less INS/CIS paperwork and a generally reduced security risk. Why invite industrial espionage from those who grew up with sympathies towards a different country?
(NOTE: Liberal arts universities are doing their best to make America seem like not such a great place, though! That’s why traitors born here, such as “Fast” Eddy Snowden and Brad “Call me Chelsea” Manning, have seemed more prevalent in recent years.)
To answering the above questions: It’s because the universities refuse to more intimately involve corporations in establishing curricula, thereby limiting the labor market utility of any hands-on experience gained through a university. I’m sure at least a few eggheads understand that, but their self-interest in so-called “academic freedom” creates market inefficiencies when it comes to training the workforce, thereby exacerbating functional employment!
For my own sake, I commented at length against the proposed H-4 work authorization and advised H-1B visas be contracted by 10 percent. Once the CEOs are done whining to the editors of Fortune magazine, they’d get cracking at training local talent to replace their precious foreign talent.
Without further preliminaries, the Tracking Number for the following comment is 1jy-8cfw-gjx1.
“I don’t feel sorry at all for employers who suffer “detriment” because they are unable to hire foreign talent! Why? Because they are causing me and millions of fellow able-bodied, able-minded under- and unemployed workers to experience the same economic loss those organizations claim, if not greater, by refusing to hire us!
I earned a degree in public administration to get a government job, but that apparently does not count towards any substantive expertise or qualification. I received no interviews for over a year after graduating before deciding to undertake my own policy analysis in my spare time at my blog, JoeOhlerJr.WordPress.com.
My landmark policy to date is proposing university student workers be allowed to finally earn unemployment insurance -- after years of state-by-state legislative prohibition -- and estimating the fiscal impact of the same to be over $2 million economic growth in each state, on average.
I’ve yet to break through into the second round of interviews, so my dream of a white-collar job is unlikely to ever come true, despite my efforts. That is why I went to college in the first place, but those eight years and $50,000 are now in a figurative black hole.
I’ve also applied for a bunch of private sector jobs. Three years after graduating, I finally received a four-day tryout at a pump assembly plant for $10 hourly. My job was to unpackage 1500 tightly packed units, movable only with sustained force through both hands over the length of each box, during a 10-hour shift: 7:30 a.m. through 5:30 p.m.
I developed tendonosis, filed a workers’ compensation claim, and was blacklisted at area temp agencies for over a year. Then, I received an interview at a grant-subsidized temp agency. They had advertised a permanent position but proposed I start as an LTE at the minimum wage, to which I expressed enthusiasm.
But a week later, the receptionist informed me that I was not selected and that there were already too many experienced people in the area to be hired. Given the general preference for previously fired, but experienced, workers over the worker without prior experience, it is doubtful I’ll ever work again -- not because I lack ambition or an education, but because employers are hiring foreign workers instead of locally.
A pressing question for the public is: When will employers stop being skinflints and start training local, born-in-the-USA citizens who want to work -- and perhaps already have a few degrees -- but still don’t have the specific training sought by that employer?
Some manual labor and office jobs I seek are filled by foreign workers, with the office work at starting salaries exceeding thirty thousand dollars -- wages substantially greater compensation than for what I would ask in exchange for the privilege of office work. Cue the red-faced CEO screaming, “WE DON’T HAVE QUALIFIED TALENT LOCALLY!”
And instead of yelling back, I disabuse him of executive ignorance by proposing a native-friendly solution that should be obvious to someone of his qualification but is most evident to the common worker: If the universities aren’t providing enough of the training you demand from new hires, then train the semi-skilled but inexperienced job seekers yourself!
CEOs should reallocate some of their distant underlings’ compensation to instead purchase valuable training time. HR should reduce the starting compensation of entry-level professional employees, hire more people without significant prior experience, and train them to eventually earn a higher compensation. A Department of Labor rule to this effect would restore America’s former economic glory and global influence.
Those universities that consistently fail to produce employ-able graduates actually hired by global firms should be shuttered, for they are a waste of public taxpayer money and therefore a misuse of corporate money -- funds that would be better spent directly training inexperienced employees rather than subsidizing $6 billion degree farms.
I hereby oppose extending employment authorization to spouses of those in the U.S. on H-1B visas or otherwise here on H-4 nonimmigrant status. I would also reduce the number of H-1B visas by 10 percent, by attrition.
The Department of Health and Human Services would thereby force the hand of corporations, and thereby necessitate greater investment in the U.S. workforce already here, by refusing additional 4-H work authorizations. When federal agencies companies to do so, they will hire local talent despite HR’s irrational fear, uncertainty, and doubt caused by their inaccurately low perception of my value as a potential employee.
Don't sell our American workforce down the river. Hire local; hire from within the U.S.! And if your locals don’t have the skills, then stop being a cheapskate -- and start training them the way you want; universities will never do this.”If you agree with me, then let the agencies know! You can even comment confidentiality, if you like. I commented under my real name to draw attention to myself as a means of reflecting some of that mindshare towards fairly obscure issues such as unemployment compensation for student workers. The worst that can happen is you end up in the national spotlight!
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