This draft IAR has been strengthened in a number of ways, compared to the very weak proposals the Government circulated for public comment on September 2, 2010. On the other hand, in many other important ways, it has not been improved, despite the feedback we and so many others gave the government last fall. Many of our 79 recommendations in our October 8, 2010 brief have not been implemented. However there are clearly instances where our advocacy efforts have paid off, at least to some extent.
Read more at