The Agencies request comment....
"The Agencies request comment" appears in the proposed rule over 20 times.
Following the thread convention, is there is interest, I can post the more relevant sections one at a time in this single topic header for discussion.
There are a number of issues covered by the PPA talking points in general that IMO could be re-enforced by specifically addressing each of these points as well as others.
Given the nature of the "deliberation" process from comment to adopting a final published rule, I feel there is value in this apporach. I've been in a number of these "process" meetings. Yes this is the Executive Branch, but even appointees' powers in this process are limited.
The fact that we are aporaching the end of the Bush Administration and more than likely the "feeling" that a political party change is more than possible, on or about the timeframe the final regulation is drafted increases our leverage in this process.
Just pushing out the 6 months proposed timeframe a few months could stall the process into a new administration.
Let me know,
D$D
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