Greenguy's Board - About Submitting Comments to fight the new 2257 regulations

I figure we should start talking about this, since the comment period ends on Sept 10th, not long from now.

Here's the guidelines from the Free Speech Coalition, as a starting point.

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Guide to Submission of Comments for 2257 New Rules and Regulations
July 12 - September 10, 2007
Posted: 7/30/2007

Background
The U.S. Justice Department is seeking to amend and update the 2257 regulations by a process known as notice-and-comment rulemaking. In this process, the Government publishes proposed regulations in a publication called the Federal Register and invites public comment for a specified period. Then, the Government goes back and considers the comments. It can and usually does change the proposed rules at least slightly. Then it publishes them, also in the Federal Register, as a final rule with an effective date announced when the final rule is published.

So far, the first step in this process occurred on July 12, 2007. You can find the relevant pages of the Federal Register (giving the Justice Department's reasoning and the proposed regulations) on the FSC web site. The next step, the comment period, is NOW.
Here is what you can do . . .

Submit Comments
In their released regulations, the DOJ stated that the cost of industry compliance for 2257 is negligible. It is up to us to convince them otherwise. If we can make a case that 2257 imposes an undue burden to small business or an expense of over $100,000,000 annually to the industry as a whole, the government is under severely increased scrutiny as far as the imposition of these regulations. Financial burdens are only one of the subjects appropriate for comment. You are the expert, make sure you communicate the full extent of the burden 2257 imposes on you and your business. If DOJ disregards our input from the public comment period, at the very least, we will have a much more solid foundation for our next phase of litigation.

What to Submit
It is important communicate the extent of the burden 2257 imposes including any or all of the following:

• Staffing costs to maintain records
• Attorney costs to assure compliance
• Storage expenses
• Additional IT expenses
• If you, or someone you know, have not been able to enter the industry because of the financial burden that 2257 would impose
• Associated costs for 20 hours per week availability for FBI inspections between the hours of 9AM and 5PM and during production
• Cross-referencing and additional information collection and maintenance (required for 7 years)
• The percentage of overall company expenses related to 2257
• For secondary producers the difficulty and expense of obtaining records from primaries
• Other burdens imposed by 2257

(Note: Always strive to be accurate when speaking to the Government. But cost and other burden estimates are okay so long as they are reasonably accurate as forecasts--just as you would do for business planning purposes. It is not necessary or advisable to go into a lot of personally identifiable detail about your record-keeping practices to date.)

How to Submit Comments
FSC would like to make it as easy as possible for adult entertainment industry members to participate. Below are three ways to participate – select the one that works best for you.

1. FSC will assist you in writing your statement for public comments - Email us at legal@freespeechcoalition.com, tell us about the burdens that 2257 imposes on your business, we will compile your comments into a document ready for submission and send it back to you with instructions on how to submit.
2. Sign on to a statement prepared by FSC representing concerned members of the adult entertainment industry. Email us at legal@freespeechcoalition.com tell us that you would like to sign on to the 2257 proposed Rules and Regs statement and we will add your name to the list. The statement will be posted on our website by mid August and sent back to you for confirmation prior to submission.
3. Submit your own statement for public comment :
By mail to:
Andrew Oosterbaan
Chief
Child Exploitation and Obscenity Section
Criminal Division, United States Department of Justice
Washington DC 20530
Attn: “Docket No. CRM 104”

Comments may be submitted electronically to: Admin.ceos@usdoj.gov or by using the electronic form provided on the site at www.regulations.gov
Comments submitted electronically must include Docket No. CRM 104 in the subject box.

Please send a copy of your correspondence to:
Free Speech Coalition
2257 Public Comments
PO Box 10480
Canoga Park, CA 91309
or legal@freespeechcoalition.com

When Are Comments Due?
The public comment period ends September 10, 2007. Please don’t delay.

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