To be honest Dave, the relicensing process is so complex and inclusive now that I'm not sure that further appeals are necessary to accomplish greater fairness. It seems to me that the proposal is intended to address methodology more than the primary directives and goals of an agreement.

Rather than oppose the addition of an after agreement appeal, some of the tribes and environmentalists feel left out and want to be able to initiate their own appeals and burden the process with even more complexity including repeated environmental impact and ESA studies.

The proposal, as written, does provide for equal input from all concerned stakeholders, but not for everyone to initiate an appeal and attempts to avoid redundancy in initiating new studies and legal actions.

I think I like the idea of an opportunity for the facility operators to address limited aspects of an agreement through an appeal process that includes input from all stakeholders but fear than in suggesting doing so they are opening the door to even cost and complexity than what already exists.


What about you Dave?
Any thoughts or ideas concerning the proposals?