Email from David Lewis/please help
Ladies and Gentlemen: This is an issue that I need your help in stopping an un-elected body from pushing a significant change to sexual education in our state. The letter below is from Rep. Paul Stam. The Rules Review Commission holds a great amount of power and can be stopped by having input from citizens. Please help me let the RRC know that this change is not acceptable. David Thursday, March 20 the Rules Review Commission (RRC) meets, and on their agenda is a proposal for a Rule Change requested by the Public Health Commission (PHC). This change would effect qualifications for programs in the Teen Pregnancy Prevention Initiative (TPPI), ending Abstinence, as an allowable standard and requiring these programs be based on "Comprehensive Sexual Education." A copy of the proposed change approved by the PHC is attached to this Email, along with my letter objecting to the Rules Review Commission's approval that is based upon what I consider to be legal grounds. I urge you to write an original letter of your own, addressed to Bobby Brown <mailto:bobby.brown@ncmail.net> , (919) 733-0928. He is counsel for the Rules Review Commission on this issue, and his mailing address is: Bobby Brown, Co-Counsel Rules Review Commission Office of Administrative Hearings 6714 Mail Service Center Raleigh, NC 27699-6714 Your letters can be faxed, also, to (919) 733-9415, and it is wise to include your contact information in return. It is important you send a copy of your the commissioners themselves, and I have also attached a list of their addresses with this Email. And I would greatly appreciate if you would also Email or otherwise send a copy of your letter to the commission to JoelR@ncleg.net, also. Here are some ideas to consider, remembering the Rules Review Commission has different concerns - concerns other than the substance of policy, and more regarding their own "standards of review:" Comprehensive Sexual Education is undefined, either in the language of the proposed Rule change or in our General Statutes, and can therefore, quite literally, mean anything. This seems to be an important point reported to have had some persuasive influence with the commission's counsel whose recommendation has strong influence over the commission's eventual decision. It is important to be careful to only address the rule change - as it fits in the Rules Review Commission's standard of review as outlined in G.S. 150B-21.9 and to refrain from editorializing on the benefits of abstinence. Those questions are outside the commission's "scope of review." As you know, more than a decade ago when Republicans held a Majority in the House, the General Assembly set abstinence-until-marriage as the standard for all sex education curriculums primary public schools. This public policy in North Carolina became the model for all Title V grant programs throughout the United States, and it remains part of the U.S. Code. It is important to note the objections we have raised before the Rules Review Commission are in areas of concern to the commissioners by statute. I my attached letter, I argue that the proposed Rule change "creates new and original policy" very different than standards we have set for our public schools and appearing nowhere in our statutes., that this proposed action in my opinion crosses the line into areas in the prerogatives of the legislature and, further, touches on legislation considered and rejected by the General Assembly as recently as the 2007 General Assembly. The Family Policy Council will also file an objection generally in agreement with these positions, saying the proposed Rule change does not meet the standards for review set for the Commission, "exceeds the authority granted to (DHHS) by the General Assembly, is set against a larger state public policy of teaching abstinence to children in the classroom and that the proposed rule change does not meet the 'clear and unambiguous' standard for review, (because 'Comprehensive Sex Education' is nowhere defined, and could mean anything. Again, this meeting of the Rules Review Commission occurs on March 20, the day of the called Extra Session. Mr. Brown has asked letters be in the hands of the commissioners and RRC staff if possible no later than Tuesday, March 18. A similar effort two months ago has been so far successful persuading the Rules Review Commission to reject a similar change in personnel policy sent by the State Personnel Commission. But I believe your help, with a concise and original letter is critical if we are to head off this unnecessary and strange Rule change. Respectfully, Skip Stam
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