Notice of Proposed Rulemaking 395.16

I believe that we'll find the new EOBR rule, when it is made public, to be largely consistent with the Notice of Proposed Rulemaking (NPRM)395.16. This NPRM is a reasonable compromise, weighing the needs of small and large companies. It allows competing technologies, is reasonable and clear. There are some troublesome areas, but it's about as good as we can hope for when this many parties are involved.