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fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00100226 Thomas R. Kane November 16, 2011 Page 3
is not only important to ensure that decision making is informed by data, but to establish stakeholder confidence."); see also Nathan James, CONG. RESEARCH SERV., Risk and Needs Assessment in the Federal Prison System 11 (July 10, 2018) (Congressional Research Service report concerning risk assessment in the
fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00064963 Thomas R. Kane November 16, 2011 Page 3
is not only important to ensure that decision making is informed by data, but to establish stakeholder confidence."); see also Nathan James, CONG. RESEARCH SERV., Risk and Needs Assessment in the Federal Prison System 11 (July 10, 2018) (Congressional Research Service report concerning risk assessment in the
fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00094081 Thomas R. Kane November 16, 2011 Page 3
is not only important to ensure that decision making is informed by data, but to establish stakeholder confidence."); see also Nathan James, CONG. RESEARCH SERV., Risk and Needs Assessment in the Federal Prison System 11 (July 10, 2018) (Congressional Research Service report concerning risk assessment in the
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