[ RadSafe ] Re: Radiation Hormesis
sjd at swcp.com
Fri Dec 28 19:51:55 CST 2007
Public comment is a de facto fraud and hoax. It's an opportunity
for a minute portion of the public to blow off steam, or to think it may
have some salutary influence, while the regulators, etc., go right ahead
and do what they planned to do all along. Besides, who has the time to
read that dry-as-dust legalese (in what --- six point type?) and decipher
what the writers are trying to say, let alone compose a response or a
At 02:22 PM 12/28/07 -0800, John Jacobus wrote:
> You are quite right. I would say that regulartory agencies do write
> and enforce regulations that implement the laws. But regulations have to
> be posted in the Federal Register for a commentary period for public
> review, so I doubt they do it every day. My impression is that public
> comments seldom have an impact during the process.
>"Syd H. Levine" <syd.levine at mindspring.com> wrote:
> But EPA DOES write law. They do it every day! The legislators have
>delegated the vast majority of regulatory duties to administrative agencies
>like EPA. Historically, this goes back to the original railroad regulatory
>scheme in the very late 1800s, but has become a true monster since 1970 when
>Nixon gave us the EPA.
>Congress merely says regulate some particular activity, and EPA is charged
>with developing the administrative law to accomplish same. Worse yet, if
>the agency decides you have violated some provision of this voluminous
>administrative law, you get the dubious honor of having the matter
>adjudicated before an "administrative law judge", generally an employee of
>the agency that promulgated the regulation to begin with. If you ever do
>get to see a "real" judge, deference will be given to the agency ( a nice
>way of saying what you say will not matter).
>Pity is not what EPA deserves, I fear.
>Syd H. Levine
>AnaLog Services, Inc.
>Phone: (270) 276-5671
>Telefax: (270) 276-5588
>E-mail: analog at logwell.com
>Web URL: www.logwell.com
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