The Bush Administration is counting on the media to cover nothing but the election these next two months, turning September and October into a 60-day long Friday dump. From my perspective the biggest piece of garbage they are setting out by the curb is their rework to the Endangered Species Act. Currently the ESA requires federal agencies to consult with the USFWS to see if actions they are taking would impact threatened or endangered species. The new rule would cut out this consultation if the Agency/Department felt they had sufficient expertise in-house to conduct their own assessment. I don't know where to begin to explain how this is soooo wrong, but it is similar to many of the free-market, deregulation approaches the Administartion has pulled lo these many years. Basically the Administration is saying let the Federal Agencies police themselves when it comes to the ESA. DOD, we trust you when you say sonar activities aren't hurting dolphins, DOT if you say no turtles will be harmed by the new highway, hey its your call. Drill now, drill forever...you got it especially since those pesky bears won't be bothered.
I previously worked in Washington DC writing regulations for a government Agency. One of the more difficult tasks when it came to down to the wire was writing our response to comments documents. It is not well known but everytime a member of the public submits a comment, the Agency publishing the rule must respond to the particular comment as well as all of the other comments (otherwise you risk leaving a hole open from lawsuits). I found this an easy task when folks just sent a form letter in from an organization to beef up the sheer volume of comments. These comments were easy to answer, in that when you answered the first one, all you had to do for the others was to respond by saying "See response to comment xyz." The really tough ones were ones that were originals created by well-meaning members of the public. These comments took significant time to respond to since they typically dealt with odd-ball issues or aspects of the rule we hadn't contemplated (most comments from the major stakeholders had already been known in advance and therfore the answers also worked out in advance.) I remember one from a monastary, that had me scratching my head for most of the day trying to knock out an articulate and defensible response.
Please, please, please, if you care enough about the importance of the endangered species act, take the time to write a short comment letter and submit it here. Try to write about a particular action your favorite govt group (DOD, DOI, EPA, DOT, etc.) tried to ram through but for which the plans were changed because of ESA consultation with USFWS.
Bottom line...it takes time to respond to comments. With only a 30-day comment period, the Bush Administration is trying to limit the number of comments it receives which will allow the response to comments to be drafted quickly and the rule published in the Federal Register. Once that happens the 60-day clock under the Congressional Review Act starts ticking (Congress can override a reg by simple majority of both houses...but the president can veto and then congress has 30 more days to try to override). Do the math counting back from January 20th and you will see how important it is to the Administration to get this BAD regulation in place as quick as possible.
Thanks for taking the time to read my first diary and thanks in advance if you plan to send in a comment.