as part of graduate school, I participated in State of California hearings, studied particular regulations that were adopted after a major law was passed in my

as part of graduate school, I participated in State of California hearings, studied particular regulations that were adopted after a major law was passed in my chosen field, and finally submitted (and had accepted) amendments to their final regulations. (this is not trivial, since there were more than 400 public comments and suggested changes to the administrative rulings, but less than three dozen were accepted - including mine). What I learned: the written law is ambiguous, mostly intentionally. The reply at the time was that the legislators "set the direction" and it is up to political appointees at an agency, working with their staff, to write regulation based on the "intent of the Legislature." The published regulations that implemented the law were written in such a way, that the references were actually circular, and the same term (noun) was used in two different places to mean two different things, without acknowledging that. I did as others suggested, and drew diagrams with notes to check the very very dense legalese in the regulations. My change was regarding that twice-defined noun, which they acknowledged by accepting the change. Overall - what is said is not what is done -- the saying I heard in Sacramento was "never write what you can say, never say what you can imply, and never imply if you can nod or wink" What that means is cynical; that you habitually do not write what you really mean to do, knowing that it will be reviewed by your adversaries, and taken out of context to be used against you. The regulations writing was adversarial, and the response from the agency involved was measured and ready for court, at every step. The default action in the public comment period is to ignore your comment, and they do that in most cases.