No idea CM. It was just a few years back that it became clear that the NOF process violated the laws of the APA requirements. In other words they filed the CR 102 and 102 for public comment and processes after setting the seasons ( unofficially sorta/kinda/what the he--) which is ass backwards from what the law requires. I guess they came up with another innovative way to pull it off that they regard as good enough .........until somebody sues their collective butts.