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Dr. Allen knows our feelings by now and is acting on them. As Duck_feeder suggested, swamping Dr. Allen with tons of mail will only be a distraction, putting a strain on their resources and slowing down the process they need to follow to move AHEAD. Look at the FWS website. and see there is not a massive staff and PR department . If you have specific data that could be used in the background of a new reg, including "Required Determinations" (information required of all federal regulations that state their impacts in very specific terms, from economic impact to compliance with the "Paperwork Reduction Act" to "...relationships with Native American Tribal Governments"), that may be helpful to them. Please follow the link from page one of this thread to see what the regulation looks like and what goes into it. These mandatory items are the components that make merely re-writing a regulation more difficult. Fortunately for us, most of those determinations likely woudn't need to change. Your empirical data, perhaps written in a similar format to the regulation, or even as a count-counterpoint format, may be helpful. Since there is no "United Front of Muscovy Interests," I think organizations such as APA may be our best bets for providing that needed information to FWS.
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The problem is more a case of incomplete data than inaccurate data. I think it's unlikely that they didn't follow the proper procedure. But more importantly, I think it would expend precious time and resources trying to prove that they did. They have already expressed that they are willing to change the regulations and no matter what else is going on, have to follow protocol to write new ones. Lawsuits etc to stop the current regulation would just add an extra step.
Dr. Allen knows our feelings by now and is acting on them. As Duck_feeder suggested, swamping Dr. Allen with tons of mail will only be a distraction, putting a strain on their resources and slowing down the process they need to follow to move AHEAD. Look at the FWS website. and see there is not a massive staff and PR department . If you have specific data that could be used in the background of a new reg, including "Required Determinations" (information required of all federal regulations that state their impacts in very specific terms, from economic impact to compliance with the "Paperwork Reduction Act" to "...relationships with Native American Tribal Governments"), that may be helpful to them. Please follow the link from page one of this thread to see what the regulation looks like and what goes into it. These mandatory items are the components that make merely re-writing a regulation more difficult. Fortunately for us, most of those determinations likely woudn't need to change. Your empirical data, perhaps written in a similar format to the regulation, or even as a count-counterpoint format, may be helpful. Since there is no "United Front of Muscovy Interests," I think organizations such as APA may be our best bets for providing that needed information to FWS.
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The problem is more a case of incomplete data than inaccurate data. I think it's unlikely that they didn't follow the proper procedure. But more importantly, I think it would expend precious time and resources trying to prove that they did. They have already expressed that they are willing to change the regulations and no matter what else is going on, have to follow protocol to write new ones. Lawsuits etc to stop the current regulation would just add an extra step.