Does anyone know what kind of change triggers a requirement for a public Q&A comment period? TSA got a wrist slap because it did not hold the required public Q&A comment period before implementing NoS. Now it's gotten a wrist slap and been told to use taxpayer money to conduct the comment period - with the understanding that regardless of the outcome, the NoS are here to stay. Is the implementation of the BDO program the same thing? Is it the kind of change that should have triggered a public Q&A comment period?