Grants and Regulations

GRANTS AND COOPERATIVE AGREEMENTS PROGRAM

The Grants and Cooperative Agreements Program provides for well managed off-highway vehicle recreation in the State of California by providing financial assistance to cities, counties, districts, federal agencies, state agencies, educational institutions, federally recognized Native American Tribes, and nonprofit entities.

The Grants and Cooperative Agreements Program supports the planning, acquisition, development, maintenance, administration, operation, enforcement, restoration, and conservation of trails, trailheads, areas, and other facilities associated with the use of off-highway motor vehicles, and programs involving off-highway motor vehicle safety or education.


2008 REGULATIONS UPDATE [Updated 8/18/08]
The Division has submitted the 2008 regulations to the Office of Administrative Law for consideration. The 2008 proposed regulations and related documents may be accessed by clicking on the link below.

Please click here to access the 2008 proposed regulations.
http://ohv.parks.ca.gov/?page_id=25486

PUBLIC COMMENT PERIOD
The 45-day public comment period will commence on Friday, August 22, 2008, and end on Monday, October 6, 2008. We look forward to hearing from you! Beginning Friday, August 22, 2008, please submit your comments via email to ohvinfo@parks.ca.gov.

PUBLIC MEETINGS
The Division will host public meetings on the 2008 proposed regulations subsequent to the conclusion of the 45-day public comment period. The public meeting schedule is as follows:

October 7, 2008 -- Sacramento
OHMVR Headquarters
1725 23rd Street, Suite 200
Sacramento, CA 95816
(916) 324-4442
6:00 p.m. - 9:00 p.m.

October 9, 2008 -- San Diego
Holiday Inn Express -- San Diego Old Town
3900 Old Towne Avenue
San Diego - Old Town, CA 92110
(619) 299-7400
6:00 p.m. - 9:00 p.m.
See you there!

Please click here to access the 2008 proposed regulations.
http://ohv.parks.ca.gov/?page_id=25486

I'm waiting on a response from Division to find out if ANY changes were made to the regulations before sending it to the OAL due to public input. And, there is no longer a link to the Evaluation Criteria.

Ride on
Brewster

there is no longer a link to the Evaluation Criteria.

They said they'll get that up before the comment period officially starts on the 22, Good catch, a few things screaming at me:


*caps may be a Little low under O&M for larger applicants, I hear three Forest up North will no longer apply for OHV money claiming it's more trouble than it's wroth. Any input on this how would you feel if they add user fees and don't apply, also funding projections are effecting the route designation process. Best talk to your agency's up there, if they don't intended to apply are they adding user fees, what trails are you considering closing due to lack of funding? NO we don't want to hear about it!!!

* soil loss due to wind??? sand people better be on that one.

* soil loss standards Greene states everyone bought of on it, who's everyone at least on the 1991 document they were much more forthcoming, if it's so easy then all agency's should be applying for grants right?

* sup categories under O&M, you said what I wanted to say that any left over funds should be moved, to the other O&M categories where's the formula for doing this?

* no cap for restoration, there should be some cap just so one applicant can't wipe out all the money, personally I say 20% of any category to one applicant.

* formula for adjusting caps if there are shortfalls or money left over due to the caps, they should also be allowed to turn in secondary applications, for consideration only if there's money left over.

Bruce,

The criteria is included with the appendix.

Thanks LoneLobo!

Has anyone that submitted written or oral comments on the reg's seen them incorperated? None of mine showed up.

Ride on
Brewster
CERA...assistant LAO

I don't think anyone's did, which has me scratching my head wondering why they bothered, looks like their waiting to this step to do any changes, that was the impression I got talking to Phil at the ASA open BOD meeting...TJ

Here's the transcript from the regs meeting you attended:
http://ohmvr.com/regs/Live_Transcript.htm

I received a reply from OHMVR Division today. There are some changes to the draft regulations. A list of them will be sent to me tomorrow..........I hope that they also post it on their website.

Ride on
Brewster
CERA...assistant LAO

Keep us posted, sometimes these public comment periods feel like wellhttp://quietbike.org/icon/deadhorse.gif...TJ

* no cap for restoration, there should be some cap just so one applicant can't wipe out all the money, personally I say 20% of any category to one applicant.

The 25% co-payment should limit the amount any agency would request. They all say that they are underfunded so I don't see how they could come up with enough of their co-payment to wipe out the restoration fund.

Ride on
Brewster

I received a list of changes made to the draft Regulations. Out of the 14 changes, only 3 made minor changes in their content. The others just corrected procedures or added/changed a word or two for clarification.

I hope that Division will be willing to make more substantitive changes after this 45 day public comment period.

Ride on
Brewster

Brewster2
The 25% co-payment should limit the amount any agency would request. They all say that they are underfunded so I don't see how they could come up with enough of their co-payment to wipe out the restoration fund.

Then why have any caps at all in any category? Yes the 25% match is an issue that we're stuck with according to the Division Chief, this is a real factor with the applicants, and my pet peeve with the budget. Out of an $85 Million Dollar proposed budget, you would think they could just ask for more for grants, rather than finding way to restrict the total amount applied for:shaking:

Brewster2
I received a list of changes made to the draft Regulations. Out of the 14 changes, only 3 made minor changes in their content. The others just corrected procedures or added/changed a word or two for clarification.

I hope that Division will be willing to make more substantitive changes after this 45 day public comment period.

So then what was the purpose of the July 29th meeting, for us to proof read their paperwork, sure looks that way don't it:confused:...TJ

So then what was the purpose of the July 29th meeting, for us to proof read their paperwork, sure looks that way don't it:confused:...TJ

Finally, something we can agree on!

Ride on
Brewster

Gee Brew, nobody wants to take Division to task on anything, not even the $20.4 Million Dollar Staff expansion, hey were you expecting any different...TJ:smokin:

Tom, it ain't that nobody wants to disagree with Division... it is how we choose to disagree.
- When I disagree with Division, I call 'em up, or email 'em, or talk to 'em.
- When you disagree, there's a press release, tar, feathers, torches, and pitchforks involved.
There's a difference...

We'll likely get a chance to work with new Division personnel since Ahnold can't book a sequel to his current reel... IMHO, it makes semse to work with OHMVR now to get the best structure and budget to move forward to support whatevere personnel we get out of the inevitable restructuring.

Randii

I have a long String of polite emails that have gone unanswered about this issue, also have emails from other leaders that have had similar luck, only to realize they were just isolating themselves. So that's the choice sell your sol to be on the inside, or ask the hard questions and be on the outside looking in, fact is as long as we allow a pre-Madonna to exist we get what we get.

Parks has one goal in mind, feed their face, can't we at least ask obvious questions:shaking:...TJ

Keep going along your own lines of approach to OHMVR, they both have their own benefits. The main thing is to continue comparing notes to avoid major differences in the policies that 4x4 interests are advocating. A battle is rarely won on a single front.

Just look at the audit findings, back in 2005 they said we're spending too much on the SVRA's for what they offer, when they sat down at the table on SB742 this apparently got ignored. Now their proposing an $85 Million Dollar budget and their just giving us a sprinkling for grants, $8 Million or OK $9.1 if you include the extra for Restoration. $65 Million for just the SVRA's and Division is ridicules, they could have just as easily funded the grants program, rather than finding ways to cap and restrict it. Also I hear three Forest up North wont even go for Green Sticker money any more, this must be effecting the route designation process, how do you feel about the Tahoe:confused:...TJ

how do you feel about the Tahoe:confused:...TJ

Tahoe NF hasn't released their Travel Management plan yet, that I'm aware of.

Ride on
Brewster

Also I hear three Forest up North wont even go for Green Sticker money any more, this must be effecting the route designation process, confused:...TJ

Are you referring to the old regulations where less than $1 million of the fund got granted to "on the ground" projects? I doubt that the forests will be holding back on their requests under the new (SB742) program, with $13 million available for O & M type projects. Afterall, the Commission has been cleaned out and can no longer raid OUR money for their own pet projects.

Ride on
Brewster

Gee Brew, nobody wants to take Division to task on anything, not even the $20.4 Million Dollar Staff expansion, hey were you expecting any different...TJ:smokin:

TJ
Can you provide a reference source for the figures you posted? According to the governors proposed budget, there is only $4.846 million proposed for 120 new positions for ALL OF PARKS AND RECREATION.

See page 13 of:
http://www.ebudget.ca.gov/pdf/GovernorsBudget/3000/3790.pdf

Ride on
Brewster

TJ
Can you provide a reference source for the figures you posted? According to the governors proposed budget, there is only $4.846 million proposed for 120 new positions for ALL OF PARKS AND RECREATION.

See page 13 of:
http://www.ebudget.ca.gov/pdf/Govern.../3000/3790.pdf

Ride on
Brewster


SB 742: Off-Highway Vehicle Program Expansion $20.427 Mil 84.0positions

Page 2 link you provided.

Development Criteria item 13
The presence of "No" riparian/wetland issues now earns applicants 10 points.

Hey Brew one other thing, people I shared this with don't consider this minor, at least for Desert minded people...TJ

"Off-Highway Vehicle Program Expansion (SB 742):
The Budget provides $20.4 million Off-Highway Vehicle (OHV) Trust Fund and 84 positions for the department to expand its OHV program consistent with Chapter 541, statutes of 2007 (SB 742)."

TJ, those are TWO SEPARATE items. Do the math, $20,400,000 / 84 = $242,857 per position. It doesn't add (or divide) up to a number that would represent actual salaries.

And please keep in mind that these are only proposed figures. The budget hasn't been passed.

Ride on
Brewster

"Off-Highway Vehicle Program Expansion (SB 742):
The Budget provides $20.4 million Off-Highway Vehicle (OHV) Trust Fund and 84 positions for the department to expand its OHV program consistent with Chapter 541, statutes of 2007 (SB 742)."

TJ, those are TWO SEPARATE items. Do the math, $20,400,000 / 84 = $242,857 per position. It doesn't add (or divide) up to a number that would represent actual salaries.

And please keep in mind that these are only proposed figures. The budget hasn't been passed.

Ride on


It's about $24K Brew you slipped in two extra zero's buddy, which means to me many of these must be part time, but again if they have the nerve to ask for this, why not more for grants:confused:...TJ

It's about $24K Brew you slipped in two extra zero's buddy, which means to me many of these must be part time, but again if they have the nerve to ask for this, why not more for grants:confused:...TJ

Nope, no extra zeros. And with your figure, it would have been only one zero. Try again after a good nights sleep.

Ride on
Brewster

I think some might be missing the point here, if it's so bad then agian why are they asking for it in the first place:confused: OK Brew what's your point:shaking:

For me, its the 84 new persons Divison will have to pay - year after year - amounting to roughly 3.75- 4.5 million dollars just in payroll, for ongoing permanent positions.

And yet, not one new real opportunity.

This is what is out of wack. And the proposed budget released by the Gov calls this a mandate from SB 742. Could anyone show me where SB 742 requires 84 new positions in the Division?

Let say we give the Division maybe one million more. Would it not be nice to at least give BLM & FS at least the same to manage the visitorship of the Every else.... and far and away has to blow away the visitorship of the SVRA's?

Come on folks, we can impact this decision.

What the heck are we waiting for:confused:...TJ

Tom, the parks that I have been to have been WOEFULLY understaffed... the last decade of budget cycles and staff turnover have lost positions through attrition, many of which have stood unfilled, or just quietly been done away with altogether. A good chunk of those 80 sum-odd positions would re-staff Parks and Division to where we were ten years ago... I don't know the exact split on this, but I can say for certain that's what I see at my local SVRA.

As well, there has been a surge in popularity in the hobby and number of 4x4s sold in that time... does it not make sense to grow the Division correspondingly?

Let say we give the Division maybe one million more. Would it not be nice to at least give BLM & FS at least the same to manage the visitorship of the Every else.... and far and away has to blow away the visitorship of the SVRA's?
Tom, you just named the two agencies MOST resistant to sustaining (let alone expanding) OHV opportunity. With what USFS is doing to our hobby with Route Designation, how can you possibly want to give them MORE money? Local to me, we lost 2000-plus miles of recreational access on the Eldorado, and we stand to lose another several thousand on the Tahoe... exactly how many thousands of dollars per mile of trail closed should Division be paying the Forest? :confused:

Randii

:confused: OK Brew what's your point:shaking:

And yet, not one new real opportunity. TJ

My point is that you have been posting incorrect figures.

Hey, they tried to get a new SVRA near Bakersfield.

Would it not be nice to at least give BLM & FS at least the same to manage the visitorship of the Every else.... and far and away has to blow away the visitorship of the SVRA's?

I guess that you have never been turned away at the gate of a SVRA because of too many people there. It happens at Hollister Hills SVRA. Yes, the same SVRA that opened up NEW riding opportunity this year.

Ride on
Brewster

You perhaps mean I've been quoting incorrect figures, I'm not the one that but in a a budget proposal buddy, the answer I was expecting was it's in people years which means we don't know how many years their funding. What I'm quoting is your links off the State web site, so don't bang on me about incorrect figures, there your sweeties my friend not mine...TJ

Tom, the parks that I have been to have been WOEFULLY understaffed... the last decade of budget cycles and staff turnover have lost positions through attrition, many of which have stood unfilled, or just quietly been done away with altogether. A good chunk of those 80 sum-odd positions would re-staff Parks and Division to where we were ten years ago... I don't know the exact split on this, but I can say for certain that's what I see at my local SVRA.

As well, there has been a surge in popularity in the hobby and number of 4x4s sold in that time... does it not make sense to grow the Division correspondingly?


Tom, you just named the two agencies MOST resistant to sustaining (let alone expanding) OHV opportunity. With what USFS is doing to our hobby with Route Designation, how can you possibly want to give them MORE money? Local to me, we lost 2000-plus miles of recreational access on the Eldorado, and we stand to lose another several thousand on the Tahoe... exactly how many thousands of dollars per mile of trail closed should Division be paying the Forest? :confused:

Randii

OK the opportunity is on everything but the State SVRA's down here, now I hear three Forest up there are not applying for any more green sticker money, why and how is this effecting the route designation process?

What the hell has Division done that's worth this kind of money?

OK we don't know the flipping breakdown and you guys wont ask because your too in love with Daphne, what I know is this the down payment is $20.4 Million Dollars. I here estimates the continuing cost will be $3.75 to $4 Million Dollars annually, yeah I hear Tahoe will be down to 53 Miles, are they going to apply for any OHV money, and if not why not...TJ

Dude, this ain't about Daphne Greene, and each time you air your vendetta against her, you reduce your credibility. :(

As far as I can tell, the Forests 'up here' and 'down there' both pumped the Division for cash for a pretty good inventory, and then undermined that by publishing a poor range of DEIS alternatives that annihilate most of those inventories.

If forests subsequently elect not to pursue OHMVR grants, that seems like a separate issue... to me, as I read the regs, it looks like the proposed processes are a sane, simplified system compared to what has been before... and if the Forests won't apply, that tells us more about their intent for spending the money than it does about the proposed Division process.

Randii

Vendetta that's a new one, whenever I bring up a topic you guys don't want to deal with I get called very name in the book, you score points for originality that's a new one. As far a credibility you got it back wards, no one says it publicly but I hear it all the time, "gee who many guys is that women bouncing on" for lack of any other reason why you guys defend Division no matter what.

As someone with formal training in trail lay out and design your way off base, to say available funding is not effecting the route designation process, as far as the Eldorado your loosing trials because no one provided a means to maintain them. Eco's filed a law suite for one reason somebody had the idea to but in 8 foot water Barr's, so I must agree funding is the their only problem but the bottom line is, no workable maintenance plan no trail...TJ

Revisions to the 2008 draft regulations as a result of public comments.
August 1, 2008

4970.05(f)(3) General Application Requirements

The word "agency’s" was added to clarify the sentence. The revised sentence reads, "Cash value for volunteer time shall be determined using the agency’s hourly reimbursement rate for…"

4970.06.3(d) Soil Conservation

The word "adapt" was changed to "adopt". The revised sentence reads, "The Soil Conservation Plan shall reference, adopt, and utilize the methods, considerations, and other…"

4970.07(f) Application Submission

The word "only" was added to the sentence for clarity. The sentence now reads, "Prior to the final Application submittal, Applicants may only modify their Application as a result of OHMVR Division preliminary review and/or public comments."

4970.10.1(c)(1) Ground Operations

The first deliverables was restructured with the sixth deliverable for clarity. Sentence now reads, "Maintenance of OHV Opportunity including necessary rerouting of roads and trails to address operational concerns,"

4970.13(e) added "Voluntary sound testing station" as a sample deliverable.

Criteria:

General Criteria item 1

Clarified term "visitor day"

General Criteria item 7

The "Yes" box mistakenly directed applicants to explain the response and skip to item 9. It should read item 8.

General Criteria item 9

The "No" box mistakenly directed applicants to skip to item 11. It should read item 10.

General Criteria item 11

The "Yes" box mistakenly directed applicants to explain the response and skip to item 13.

It should read item 12.

Development Criteria item 13

The presence of "No" riparian/wetland issues now earns applicants 10 points.

Planning Criteria, item 4

The word "proposal" was added to clarify the question. The question now reads, "The Project proposal was developed with public input employing the following…"

Planning Criteria, item 10

Deleted
Restoration Criteria, item 2

The fifth check box was removed. Archeological and historical resources are captured in the second check box.

Restoration Criteria, item 11

Expanded examples in question

Sorry Brew I'm putting this up, if we wiat for Division we're going to be wiating a long time...TJ

This is nuts... we have close to the same goals, I think --- better motorized recreational opportunity in California? How does that general issue allow for such arguments? None of this should be personal... let's address the issues.

I know a few things about the Eldorado... and a few things about the offered maintenance and Route Dez. We're losing trails because Region 5 is bullying ENF into that... funding is at best a tiny part of that.

Randii

I can tell you what's going on in every forest, OHV managers are outnumbered 8+ to one dealing with resource people, just keeping what they can it takes an OHV manager that's willing to stick their neck out big time. Yet me ask you this how many miles will you get on the Eldorado, Tahoe just sucks big time, and if the problems with the Region you need to stand behind the Forest. Encourage them to stand up to the region, not write mass letters to the Commission trying to kill their grants, I know what your going to say now "then why do you bang on Division" it's because the people that should never do.

Also the fights not over with this process, closed don't mean gone forever just closed unless restored, do what you can to get closed high value trails moved to the bottom of the restoration list. Show the valve these trails have, demonstrate how they can be maintained, as long as the trails this there the fights not over. I hate the rules but I didn't make them, I don't think there's any way in hell to designate 2000 miles under the current system, but I bet whatever you get beats the SVRA's hands down...TJ

http://quietbike.org/icon/focus.gif
OK Bottom line, if we want more for grants they have to spend what they have, the caps are too low so they need to be increased. The reason for the caps was to prevent one large applicant from wiping out a category, if there too low they prevent us from allocating the funds, which means no more or even less in the future:smokin:...TJ

TJ
Take a look at the 2007-2008 OHV Grant requests, especially the Non-CESA projects. The total amount requests for ALL grants was only $9.161 million. The 2008-2009 OHV Grants for O & M is scheduled to be $13 million. That would cover ALL of the 2007-2008 Non-CESA grants. And, there will be less project types that will be under the O & M catagory.
For the 2007-2008 OHV Grants requests, only 3 out of the 69 Non-CESA Grants hit the $500,000 cap they had at the time.

Ride on
Brewster

OK there's $13 Million there now, what your saying just adds to my argument the Caps are not only too low, also they are not needed.

Gallons of gas
Total------Jan. 9, 2007** -Jan. 16, 2007-July 27, 2007--Jan. 17, 2008-----July 15, 2008

IMPERIAL County
4,996,626---375,448.03--------236,376.53---395,679.22----242,578.59---356,294.85

Look at all the Gas the burn Down South, now the the Commission wont be hassling them BLM El Centro will be applying for more...TJ

Gallons of gas
Total------Jan. 9, 2007** -Jan. 16, 2007-July 27, 2007--Jan. 17, 2008-----July 15, 2008

IMPERIAL County
4,996,626---375,448.03--------236,376.53---395,679.22----242,578.59---356,294.85

Look at all the Gas the burn Down South, now the the Commission wont be hassling them BLM El Centro will be applying for more...TJ

Looks like Imperial County will be getting a big chunk of the in-lieu funds from the Green Sticker registration.

Ride on
Brewster

OK there's $13 Million there now, what your saying just adds to my argument the Caps are not only too low, also they are not needed....TJ

TJ
Why do you feel that any of the agencies would not be satisfied with $1.5 million (the cap) for O & M ?
If all but 3 of the agencies asked for less than $500,000 (the cap) last session, why do you say the caps are too low? I just don't understand your reasoning.

Ride on
Brewster

El Centro IE Glamis has only been applying for less do to intimidation by the Commission, what happened was under the scoring system the Commissioners couldn't get them down where they wanted them under O&M. So now they should be applying for what they need, which could be in the Millions. No one will admit it but the caps were done for one reason to check El Centro, the year before they applying for over $2 Million in Law Enforcement which ruffled a lot of feathers at Division (I have the emails to prove it).

OK the Commission as we knew it no longer exist, they wont be low scoring large grants they don't want to deal with under the cut line, there's a good chance we could wind up with money left over under O&M. Believe me politically that's the last thing we want, what I want for this year is to drop the caps, if there's too much of a short fall then put them in. I personally think we should be hammering the Legislators for more funding, rather than finding ways to box in the applicants...TJ

No one will admit it but the caps were done for one reason to check El Centro, the year before they applying for over $2 Million in Law Enforcement which ruffled a lot of feathers at Division (I have the emails to prove it). TJ

It also ruffled the feathers of the other agencies that were requesting funds and the public, me included. El Centro got greedy.

OK the Commission as we knew it no longer exist, ...TJ

For now, I think that the caps are a needed safety factor. Remember, grants for projects that provide "motorized access to nonmotorized recreation" can be applied for. This is one of the holes the enviros got and I don't trust the Spitler types to play fair with this one.

(A) Fifty percent of the funds appropriated by the Legislature
pursuant to subdivision (a) of Section 5090.61 shall be expended
solely for grants and cooperative agreements for the acquisition,
maintenance, operation, planning, development, or conservation of
trails and facilities associated with the use of off-highway motor
vehicles for recreation or motorized access to nonmotorized
recreation.


I hope that someone besides you and I are finding this converstation helpfull.

Ride on
Brewster

Caps perhaps should only come into play after there's so much of a short fall, the primary mission is to allocate the funds, if we're going to have caps they should make sense. When we had almost $4 Million less applied for last year, then whats available this year, any caps at all are not necessary, as far as getting greedy tell me one thing why only under Law Enforcement:confused:TJ

as far as getting greedy tell me one thing why only under Law Enforcement:confused:TJ

Not just LE! Have you forgotten the $5 plus million that USFS Region 5 asked for? That would have wiped out the catagory.

Ride on
Brewster

Wasn't that an F'S deal, I remember they said they'll pull it if they couldn't get it under restoration, then they reneged at went for the bucks under NON CESA. That's nothing to do with El Centro BLM however, they always had issues with O&M in which me and the Dunes manager have had much "conversation", most of which was quite heated. They swore Spitler had a vendetta against them, being sure they never got enough money to overcome the monitoring overhead for the area, now there problem is the caps.

Also that cycle we had so much under NON CESA because it was the dumping grounds, for everything that wouldn't fit under the restricted category's. Last year we only had just over $9 Million even with this still in effect, this year it's not an open unrestricted category, it's O&M and is is restricted. The cycle you are referring to we had around $20 Million that year under NON CESA, last year we had only $9 Million and this year it's restricted, and there's $13 Million available. My fear is we're fixing to break the 1st Commandment of grants, "Thy shall leave no money UN applyed for"...TJ

TJ
Neither of us seem to be making any headway at changing the other guys position so why don't we drop the subject? No need to clutter up the forum.

Ride on
Brewster

TJ
Neither of us seem to be making any headway at changing the other guys position so why don't we drop the subject? No need to clutter up the forum.

Brew I think that translates out to this don't concern anyone up North, as far as the regs I just don't see any other issue, other than perhaps better clarification on spending the so called left over restoration money...TJ

http://ohmvr.com/ftp/OHVFUND.jpg

http://ohmvr.com/ftp/Tags.jpg

http://ohmvr.com/ftp/countysm2.jpg

http://ohmvr.com/ftp/state2.gif

I feel the caps being considered are arbitrary in nature,a knee jerk reaction to a very large grant submitted under Law Enforcement on the last cycle, and around $20 Million being submitted under NON CESA the previous cycle. Both these conditions no longer exist under the new laws due to the passage of SB742 last year, NON CESA was an unrestricted category that no longer exist, and Law Enforcement is now an entirely different process all together. This limitation also is unfair to areas where one Agency managed the bulk of there opportunity, such as Imperial County which used more fuel than any other County in the State, and only has one real applicant EL Centro BLM.

Any past history being used is now null and void, and in this case violates the simple US Constitutional need for basic representation for taxation, the people that pay the most are in-titled to their Fair share. New data is needed before considering any caps in any category.

Here's a copy of what I submitted as a comment on the Regulations concerning this matter, only took about five minuets, your call folks I got work to do...TJ