7/6/20
On Mondays, Rogan’s List features a
listing of proposed rule and regulation changes that are currently accepting
public comment. Commenting is the way to show government agencies
how we feel about these proposed changes. Our comments also become part of a
record that will be reviewed by courts if and when a reg change is contested.
Courts use comments to judge whether an agency is acting arbitrarily and
capriciously.
Organization
Closing Soon
Recent
Section I - ICE, DHS, DOL, NLRB
Section II - everything environmental -
EPA, BLM, DOE
Section III - Civil rights, housing,
education, healthcare
Other: More on regulations (tracking the
trackers/general information)
(Note: After a couple of weeks items are moved from “Recent” and
“Closing soon” into the Roman numeral sections. A note on regulatory processes:
there are three stages - Notice, Proposed Rule, and Rule. There’s usually a
time lag of a few months to a few years between them, and they must be
published in the Federal Register before appearing on Regulations.gov. Comment
time varies from 10 days to 2 months, sometimes with extensions.)
This week's list - Closing: Allowing asylum for credible fear
(note: Trump bans it, but he's banned almost all immigration, legal and
undocumented.) New: closing homeless shelter to trans youth. These are all
still a moving target. Even as supposedly temporary rules are put in place
often w/o comment allowed, other proposed rules on the same topic in the
pipeline are proceeding through the process. Some - maybe more - appear to be
in direct conflict. So, there's a new Trump Rule on work visas, even as they banned
them by Exec order over a week ago. So even if one is tracking these, it often
(actually, usually) doesn't make sense. Also, a lot of measures aren't going
through the regulatory process. That was the basis for the Supreme Court
declaring the LGBTQ have employment rights - why? Because it hadn't gone
through the proper regulatory channels. Chief Justice Roberts basically gave
the Trump admin. a road map to how to it - except, as we know, Trump et al.
have little, if any attention to detail.
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