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FSC Member Advisory from Diane Duke re: 2257
The most recent email - the FSC says it's getting ready for the secondary producer fight:
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Dear FSC Member:
This is an update on the newly-released rules and regulations related to 2257. We will provide you with more information as it becomes available.
First, it is important to recognize that the regulations that the DOJ has set forth today are simply proposed regulations, issued for comment and possible change.
FSC will extensively comment on the regulations, and we intend to launch an industry-wide campaign to solicit your comments as well. We need your participation in this process. In the coming days we will provide details on how to comment.
Some of the points set forth were expected, and they represent the modest gains that we have achieved through litigation thus far. Some of the other points are troubling and represent the intransigence which we have come to expect from Attorney General Gonzales and his associates.
On the critical subject of secondary producers, the Justice Department is continuing to suggest that it has been right all along and that Congress ALWAYS intended secondary producer to be included in 2257. Therefore, they are considering the original legislation and regulations issued in 1995 to be valid for secondary as well as primary producers. We understand that for many of you it is simply impossible to comply with the Justice departments demands, and that is one of the reasons why we will continue the fight.
Unless the final regulations change radically from those proposed today, FSC will continue our litigation at the appropriate place and time, including seeking another injunction for secondary producers as well as others.
At the end day, we will make sure that federal judges understand the absurdity of these regulations, and we will not let up on our commitment to you and to your rights.
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