I think you got it CC. WDFW had trouble getting timelines to match / merge so the NOF process was designed. The problem there is the decisions were already made & finalized before a citizen could even comment. Take GH and the 26th you can go to the R6 office to comment on the CR 102 ( WAC for seasons ) but it is already a done deal on the FED register and up on WDFW's website as to be adopted the 26th. NOF is smoke and mirrors and violates about every standard for open government I know of.