I have engaged the services of a Regulatory Attorney for a consultation regarding PACFA Rule Change 19.5.3. In preparation for our meeting this morning, he retrieved all the rule change information pertaining to 19.5.3. He informed me that PACFA has mishandled its rule-making process in creating this rule. Additionally, another “public hearing” has been scheduled for July 15 at 7:00 AM, which appears to be another Zoom meeting opportunity. Prior to this meeting on July 15, they are still accepting written comments.
The lawyer advised us to prepare several distinct scripts, each emphasizing why this rule is detrimental to our industry, constitutes an “abuse of discretion,” and causes harm to our profession. He asserted that there is no rational basis for this rule to be imposed upon groomers, and we must state that clearly. The lawyer believes we have a strong case and that it is not technically challenging on its merits. He indicated that if we are unable to persuade them to reconsider after the July 15 meeting, we will need to seek an injunction.
Regarding the July 15 meeting, the lawyer expressed his willingness to join us and prepare statements and arguments for the meeting. Essentially, we could present ourselves as a unified front with his expertise guiding us. He could complete the necessary preparations and be present on the call, but the cost is $3,500. I understand that this may seem like a significant financial burden, but if we can mobilize 100 groomers to contribute $35, we can overcome this obstacle. I cannot recall the exact number of groomers who participated in the June 18 call, but I am confident that we had at least 100 individuals who provided testimony. PACFA may be more receptive to our concerns if we present ourselves with representation. They have a history of disregarding our input, so if we come in with legal counsel, they may be more inclined to back down. I am seeking the support of the group to determine whether this is a worthwhile endeavor.
