3 ms·

You can read the full notice here: http://www.regulations.gov/#!documentDetail;D=TSA-2013-0004-0001 http://www.regulations.gov/#!documentDetail;D=TSA-2013-0004-

by dsl 14y ago

You can read the full notice here: http://www.regulations.gov/#!documentDetail;D=TSA-2013-0004-0001 http://www.regulations.gov/#!documentDetail;D=TSA-2013-0004-... BoingBoing: http://boingboing.net/2013/04/21/tsa-finally-seeks-public-comme.html http://boingboing.net/2013/04/21/tsa-finally-seeks-public-co... Gizmodo: http://gizmodo.com/5995181/time-to-give-the-tsa-a-piece-of-your-mind-about-those-full+body-scanners http://gizmodo.com/5995181/time-to-give-the-tsa-a-piece-of-y... LA Times: http://www.latimes.com/business/money/la-fi-mo-comment-on-tsas-fullbody-scanners-20130419,0,4478127,print.story http://www.latimes.com/business/money/la-fi-mo-comment-on-ts... Ruling: http://www.cadc.uscourts.gov/internet/opinions.nsf/B3100471112A40DE852578CE004FE42C/$file/10-1157-1318805.pdf http://www.cadc.uscourts.gov/internet/opinions.nsf/B31004711...

tomrod 14y ago
I wonder if the comment period is just another part of security theater, given the LATimes is showing a lot of pre-established counter arguments to claims.
- rayiner 14y ago
  Under the APA, administrative acts that establish new regulations (rules) require notice and comment. The TSA tried to implement this without the required notice and comment process, and EPIC got a court order requiring them to. So it's for show on their part in the sense they didn't want to do it in the first place. But now that it's a notice and comment rulemaking, that sets the stage for endless litigation over any procedural failures and court oversight of their determinations. The pre-established counter arguments are there for efficiency. The way notice and comment works is that you have to respond to significant new issues that come up. You might have to have another round of comments on the new issues. If you anticipate counter arguments up front, that saves time on the back and forth.

by dsl 14y ago

tomrod 14y ago

I wonder if the comment period is just another part of security theater, given the LATimes is showing a lot of pre-established counter arguments to claims.

rayiner 14y ago
Under the APA, administrative acts that establish new regulations (rules) require notice and comment. The TSA tried to implement this without the required notice and comment process, and EPIC got a court order requiring them to. So it's for show on their part in the sense they didn't want to do it in the first place. But now that it's a notice and comment rulemaking, that sets the stage for endless litigation over any procedural failures and court oversight of their determinations. The pre-established counter arguments are there for efficiency. The way notice and comment works is that you have to respond to significant new issues that come up. You might have to have another round of comments on the new issues. If you anticipate counter arguments up front, that saves time on the back and forth.