thinkator lankford, i your question is beyond my expertise. designed to give guidance to the field on implementing the standards. >> the concern i have is the guidance seems to remove flexibility that previously existed. when we try to look at what is guidance and what is regulation, it seems the regulation give flexibility to say you have this generally recognized engineering practice, go by those, or you can create your own process, you just have to show it is good process. this new guidance seems to "or" and everything else seems to go away. that seems to be one of those things that it would look like it would be a regulation that would need to go through a comment. if it is meant as a flexible enforcement standard, this june five seems to take it away. how is it determined this is going to be a guidance rather than a rule? so, to begin, we follow the apa and the bulletin in providing recommendations. we are very committed to following the rules. if there is ever any question that is done in consultation with our solicitor. we are confident