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Stephen L. Kass and Jean M. McCarroll, partners at Carter Ledyard & Milburn, write that despite some modest procedural reforms, the North American Commission for Environmental Cooperation's citizen submissions process has not significantly improved. A 2001 report urged the Commission to reduce to a maximum of two years the total time required to review submissions, prepare Factual Records, and authorize their release. In the last three years, however, the Commission released five new Factual Records that averaged nearly five years to complete, a time period that effectively vitiates any impact from the exposure of a government's failure to enforce its environmental laws.
August 25, 2008 at 12:00 AM
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