it is going to stress another area.
We are an endangered species.
It's very telling when you have a Democrat Senator who is generally supportive of the EPA's efforts calling the final rule a 'slap in the fa...
I cannot describe it for you, but I know it when I see it, and we all may have a different line in terms of where we think guidance may cros...
We all agree, hopefully, here that a guidance does not have the full force and effect of law, right?
But, we should know what those requirements are from both the statute and the substantive rulemaking, and when it seems like we cross that r...
It looks like it is a shortcut to changing the rule.
That is one of your recommendations in your report, is that we actually look at written policies as it relates to guidance...
If we were in compliance before doing what we are doing, then how can we so dramatically be out of compliance right now?
Being guidance is not enforceable.
To simply unilaterally, without comment or process, change the rules does not seem to be what a guidance should do.