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Re: Submitting comments on rulemakings



If I remember correctly, Congress pasted a law that

states BRC cannot be used in the future.  My

impression was that the NRC thought that BRC was a

good idea, or else they would not have initiated the

process to put it in place.  It still is a good idea.



--- "Bradt, Clayton" <Clayton.Bradt@Labor.State.Ny.Us>

wrote:

> Bill Lipton wrote:

> 

> "Thus, when BRC became an issue, the shear number of

> negative comments influenced  the NRC to rescind

> this."

> 

> I think it was congress that stopped NRC from

> promulgating BRC.  No doubt

> congress were influenced by the number of negative

> comments from their

> constituents in determining to stifle the

> commission's actions.  My

> experience is that NRC indulges comments that

> further its predetermined

> purposes and is dismissive of comments that don't. 

> Remember, the

> commission's real constituents are in congress. Once

> given their marching

> orders by the oversight committees, the commission

> will promulgate the

> necessary regulations come hell or high water.  A

> comment will never

> influence the outcome of a rulemaking unless it

> resonates with a power

> center internal to the organization that can use it

> as a pretext to further

> a specific aim.  The intellectual merit of a comment

> is largely irrelevant

> to its reception. 

> 

> Clayton J. Bradt, CHP

> Principal Radiophysicist

> NYS Dept. of Labor

> Radiological Health Unit

> voice: (518) 457-1202

> fax:    (518) 485-7406

> e-mail: usccjb@labor.state.ny.us

> 

>

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=====

"Self-criticism is the secret weapon of democracy, and candor and confession are good for the public soul."

Adlai Stevenson



-- John

John Jacobus, MS

Certified Health Physicist

e-mail:  crispy_bird@yahoo.com



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