NFB: Merchant's Division Regulation Comment

NFB: Merchant's Division
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Letter for Blind Entreprenuer

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Dear Secretary King / Assistant Secretary Swenson / Commissioner LaBreck: My name is _____ and I am a licensed Randolph-Sheppard vendor in the state of ______. I am very concerned about the Department of Defense’s attempt to promulgate rules that would adversely affect the Randolph-Sheppard Program and blind vendors. If the proposed rules become final, they will eliminate current opportunities for blind vendors across the country and deny future generations of blind people any chance of ever being allowed to manage and operate troop dining contracts. We need your help to ensure that the priority afforded by the Randolph-Sheppard Act is protected. It is the Department of Education that has responsibility for administering the national program and for interpreting the Randolph-Sheppard Act and not the Department of Defense. I am calling on you to join the more than 4,700 concerned citizens who submitted comments to DOD in opposition to the proposed rules to protect what is no doubt the most successful entrepreneurial program in history for people who are blind. DOD is basing the proposed rules on the Joint Policy Statement agreed to by the previous Administration in 2006. The Joint Policy Statement was flawed and when this Administration took over, it understood this and made the conscious decision to not promulgate rules implementing the agreement. Now, DOD has taken it upon itself to implement a flawed and illegal policy. In court affidavits, DOD has suggested the Department of Education concurs with these rules. In responses to inquiries from members of Congress, DOD has implied the same thing. The only way this goes away is if the Department of Education disavows the Joint Policy Statement and communicates in an unambiguous way that the proposed rules are in direct conflict with regulations already promulgated by your Department. DOD has more or less laid this at the feet of your Department. I implore you to stand up in support of your constituents who are blind as well as future generations of blind people and protect this program by backing away from the Joint Policy Statement. Thank you for your consideration.

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