On Wed, 28 May 2003 08:12:28 -0500, Eric Growden
>I find it significant that the number of responses to some rule change
>where the ATFE controls the official 'count' would be considered by our
>Senators as more significant than direct feedback to their offices.
"Significant opposition to the proposed rulemaking is critical
and supports BOTH our legislative and legal actions. "
I don't profess how this stuff works in Washington. But I do know
that John Kyte, who make his living doing this, is telling me this is
the way it works.
If a group doesn't support the NPRM process with the same vigor and
energy as it does the legislative process, then we look bad, and open
the doors for our opponents to claim we don't care. We have to fight
a multiple front war, and if we lose on one front, we stand to weaken
the case on other fronts, so please write the letters.
>I'm a bit confused over this. The ISEE is suggesting to their members
>that they copy and paste the form letter available on the ISEE site. If
>multiple copies of a 'form' letter count only as one, why would ISEE be
>suggesting that route and how did they come up with 600+ responses?
experience that the typical agency response to their approach is
something along these lines:
"A total of 342 respondants comments that xyz proposal was invalid
because of abc reasons, a position outlined by the 123 Business
This is how agencies can legally respond to absolute volume, but
equivalent substance, in handling the NPRM. They, the Congress and
the courts all recognize a mass mailing approach to the NPRM, and it's
simply not as effective as everyone writing their own letter.
I've also seen the "write your own letter" approach taken on social
justice issues at my church; it's demonstrated that its a far more
effective technique than mass mailing the same letter over and over.
As for the absolute number of ISEE generate responses, I don't know
how they got there, but my guess is the employees of their members
have written in oppositiion to the NPRM.
>Are you saying that the ATF may have 50 responses of a form letter from 50
>individual US citizens and then will try and count them as one response?
When they say exactly the same thing, the agency can indeed respond to
those 50 responses with one comment. I've seen it done in financial
industry NPRM's from the SEC and Federal Reserve in my professional
life, so don't assume it's some stunt ATFE is pulling on us. Think of
it as standard operating procedure instead.
>> I suspect that the BATFE is classifying many of the replies as
>> "not-comments" because of subject lines or some other obstructive criteria.
>> That Agency will do anything it thinks it has to, including lie to Congress,
>> to achieve the smallest of its goals.
In my opinion, given the rulings we've gotten thus far in court, the
ATFE would have to be suicidial to take this approach. It would
completely doom their legal positions in front of the Federal bench.
On Wed, 28 May 2003 08:39:43 -0700, David Weinshenker
>Would _not_ fighting it spoil someone's inter-office ass-kissing
"Our lack of opposition is actually helping ATF. Your choice
is simple. If you want to help preserve our hobby, write a
letter today. If you want to help ATF, do nothing."
NOT writing helps the ATF.
Writing helps the hobby.
How can I make this clearer to readers of this newsgroup?
>BATF, as well as post copies of the letters, if people are willing to
>send me the information.
Tuesday morning. This is really a nice gesture, but is a lot of work
for an incomplete result. I can always have my local NAR resources
check the docket again when it closes and in fact, our counsel intends
to review the docket to make sure the ATFE's response is complete and
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Mark B. Bundick mbundick - at - earthlink - dot - net
NAR President www.nar.org