Michael Smolensky

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?