Sam Creasey

Document ID: NHTSA-2013-0042-0011
Document Type: Public Submission
Agency: National Highway Traffic Safety Administration
Received Date: April 10 2013, at 12:00 AM Eastern Daylight Time
Date Posted: April 11 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: March 26 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: May 28 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-84pa-q8vg
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This is comment on Proposed Rule

Direct Final Rulemaking Procedures

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This comment is to register my opposition to the NHTSA proposal for direct final rulemaking (DFR). Particularly, I am concerned by the provision for "minor substantive rules or changes to existing rules on which the agency does not expect adverse comment.". The agency's judgement on what rules will expect adverse comment should not replace the standard comment process, particularly in the case, as one of the most important purposes of these comments are to notify the NHTSA that rules have adverse consenquences which the agency did not expect.