I think that the overtime as it relates to on-call is very problematic.

I have long maintained that I think guidance can be extraordinarily helpful.

I want to bring you back into this discussion, Mr. Shelanski.

I think one of my concerns--and it goes back to what I said, longstanding agency interpretation and deference.

I do believe that there are things that are done at the IRS that need maybe a second look.

When we change how we interpret either rules or statutes, and the change has a dramatic impact on the livelihood of business people, we get a little suspicious that that does not look much like a guidance and it is not a legitimate new…

Yes, and this is a problem because we give deference--and I do not mean to give the Chairman any more ammunition than what he already has on deference--but we give deference to longstanding interpretations of agencies.

I think that guidance is extraordinarily valuable.

Is that really the kind of relationship we want with the public as it relates to an interpretive change?

Yes, we settled those cases, but it is still guidance documents.

We still have not satisfied the public that they have had adequate input in this process.

There has to be some flexibility that they have because they have to make those determinations.

I could see doing something where you say, well, you might consider this, you might consider that; here are some things that we would consider appropriate.

And, it just keeps getting to that point where had you started with a rulemaking process, you would have a firmer foundation for this whole structure that you have created.

I thank my colleagues from New York and Indiana and the other colleagues supporting this legislation. They have described it beautifully. I would just simply state that what this really does is it brings FAA policy up to the contemporary…

I think that we are in that spot where we are looking at motivation as opposed to kind of looking at it from a legal standpoint.

I think it is important to get your opinion, that the troublesome piece of this really has been the cash transfer.

that flexibility is vitally important.