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Originally Posted by mrg
I think you were pretty much dead on with the PRA OMB# "fiasco."
It leads to delegation issues, and they do not want, cannot afford to have somebody stumble onto that path.
PRA is a small part of the Administrative Procedures Act, as far as I know.
APA will/can probably lead to where they do not want to go.
Or maybe I am wrong.
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Even though it is obvious to me, mainly the Delegation of Authority 120-10 being unsigned - never signed by the Secretary, I was never involved or even very interested in proving it.
Regards,
David Merrill.