Friday, September 26, 2003

Re: Commercial solicitation

Joe, I plan to take some time and respond to your comments, but in the meantime, I wanted to add a concern to the debate. This comment was filed with the FTC prior to its implementation of the rule creating the national do-not-call registry, on behalf of national direct marketers and publishers (although the comment does not specifically identify the group). I draw this to your attention because they argue that the registry violates the National Environmental Protection Act of 1969, which requires (among other things) that regulatory actions having potentially serious environmental consequences must produce an Environmental Impact Statement and evaluate the harms against its purported benefits. At first I though the comment would argue that reducing telephone solicitation would lead to an increase in junk mail, but no. They argue that "consumers have come to increasingly rely upon direct marketing for the purchase of goods and services. This increased reliance has dramatically reduced the need for physical storefronts, which themselves require more energy and impose greater environmental burdens than do telephone calls followed by the "carpooled" delivery of purchased products."

This reminds me of a bumber sticker I saw in Vermont that read: "If you don't like logging, then go ahead and wipe your ass with plastic toilet paper!"

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