Will this regulatory amendment create a legitimate claim of entitlement for the
drawbridge employees? I leave it to you to determine the state of the law in
this area. If it does, then how much process will be due to the employees in
the event that they will not be provided with the family time on holidays? If
you put this in a regulation, and if that regulation creates a legitimate claim
of entitlement, then both notice and an opportunity to be heard will be required
before this time is denied to any drawbridge employee.
I concede that this sequence of events seems absurd, and in all likelihood it
probably will not come about. The point is this: Unnecessary bureaucracy has
already been created with the proposed amendment. If the rule is amended, you
stand to create even more bureaucracy. Even if it does not create a legitimate
claim of entitlement, this whole procedure is just plain wasteful. The
employees are receiving the time with their family on the holidays. They
deserve this family time. All things being equal, they will most likely
continue to have the time with their families.
I want to make it clear that I support providing these employees with the family
time on holidays as has been the practice for the past 6 years. Nevertheless I
think that formalizing this in a regulation is a mistake. Look at the
additional government overhead involved in the amendment process, and the
foreseeable, though unlikely, overhead in the future. The proverbial wheel is
working, so why change things?
Related Comments
Total: 2
Michael Smolensky Public SubmissionPosted: 11/13/2007
ID: USCG-2007-0026-0003
Nov 26,2007 11:59 PM ET
Michael Smolensky Public SubmissionPosted: 11/13/2007
ID: USCG-2007-0026-0004
Michael Smolensky
This is comment on Rule
Drawbridge Operation Regulations; Corson Inlet, New Jersey Intracoastal Waterway (NJICW), Townsend Inlet, NJ
View Comment
Related Comments
Public Submission Posted: 11/13/2007 ID: USCG-2007-0026-0003
Nov 26,2007 11:59 PM ET
Public Submission Posted: 11/13/2007 ID: USCG-2007-0026-0004
Nov 26,2007 11:59 PM ET