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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
tances, which is unsupported by empirical evidence and, in effect, nullifies the SCA's increase in the available time in community corrections. A. The Proposed Regulation Does Not Comply With The Congressional Instruction To Address The Optimal Duration Of Pre-Release Community Corrections. An essential component of the SCA's change in reentry policy was
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
tances, which is unsupported by empirical evidence and, in effect, nullifies the SCA's increase in the available time in community corrections. A. The Proposed Regulation Does Not Comply With The Congressional Instruction To Address The Optimal Duration Of Pre-Release Community Corrections. An essential component of the SCA's change in reentry policy was
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
tances, which is unsupported by empirical evidence and, in effect, nullifies the SCA's increase in the available time in community corrections. A. The Proposed Regulation Does Not Comply With The Congressional Instruction To Address The Optimal Duration Of Pre-Release Community Corrections. An essential component of the SCA's change in reentry policy was
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