Eli;

In the real and logical world of business and relationships you are correct.  
There are specific rules set up for a reason.  What you have been asked to 
comment on has already been through various committees and is specifically what 
they want to tweak.  If all comments were taken into consideration, you would 
have a mass of confusion and nothing would ever be completed.  Although your 
ideas are truly good ones and your passion is grand, time to introduce such 
changes have passed.  But, another train can leave the station at any time, so 
rogue ideas need to be fortified with data, numbers and juice (the political 
kind) and put forth by someone with the wherewithal to see them through.  (No, 
I'm not going there, gang. Syd and I need to continue to work together instead 
of having another pissing match.)  

I guess you are correct in saying that you may comment on anything but it's 
truly unfortunate that comments not directly related to each rule will hit the 
round file.  The government employees have a job to compile data regarding the 
proposed change and that's what they do.

You really want it, rally the troops.  In the meanwhile start becoming close 
with your Congressman, you'll need him/her.  That's another thread all together!

Al DeMarzo
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  ----- Original Message ----- 

  Al

  Respectfuly disagree.

  If you could comment only on exactly what they wrote, and exclude anything
  other than what they wrote, you could never propose any change whatsoever
  to what they wrote, because, by definition any change is going to be
  different than what they wrote and will include additional and different
  words and phrases to describe the change you want ! Where you draw the
  line on what is "close enough" to the original proposal to be appropriate?

  Comments to proposed rulemaking can include changes, additions, deletions,
  scrapping the whole thing, etc. We are proposing an addition.

  They are saying "we want to do A, B, C, D, tell me your comments about it
  ", and we are commenting to them, "we would rather you do the A, B, C, D
  you proposed, plus these additional things (E, F) you missed"

  C'mon guys, help us out here...

  Thanks and again, respectfully

  Eliacim
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