FDA opens comment periods on two issues regarding Substantial Equivalence Requirements

[tombaker]

No, CASAA is entirely WAY too small, powerless, and underfunded.
And you are most certainly not helping.

Now that the "enemy" is onto us, they are marshaling their enormous resources and preparing well in advance.
They are also trying to sneak a lot of these bans through without notice these days.

We are starting to lose more often because they are getting serious about beating us, and bringing money into the equation.

And as for CASAA being ineffective, I would hardly call things like this being ineffective...
http://www.e-cigarette-forum.com/fo...ion/511758-what-has-casaa-been-up-lately.html

per CASAA summary "Many possible regulations that do not appear to be a ban on paper would serve as a de facto ban of the entire category, or at least of the higher-quality products and the innovative improvements that happen every month."

Many possible regulations (they don't exist, legally many things are not possible, including banning tobacco Products, as stated fully under the law passed in 2009.....anything is possible is just false, by logic, and by the letter of the law)

that do not appear to be a ban on paper (they are not on paper anywhere)

would serve as a de facto ban of the entire category (false, misleading, something that BLU would be far more concerned about than a user group, not legally allowed, would be tied up in the courts for years if such a folly of a notion was taken)

or at least of the higher-quality products and the innovative improvements that happen every month(CASAA believe that a Provari can be banned, which is their fear here, its just non-sense. And they think this is the least that will happen, when it can not even happen.....geez)

Attendance is not accomplishment, sorry no trophy for everyone

 

[Jman8]

Usage bans do seem to be happening in a lot of places and increasing at a rapid rate. IMO, this is the number one issue facing the vaping community currently.

Worse yet, if ECF threads are any indication of how usage bans may play out, then some vapers will be right on board with those bans being enforced, perhaps even tattling on fellow vapers who dare to vape just anywhere.

I wish I had answer to usage bans that works for everyone, though it becomes a lot more challenging when opposition is all to willing to use deception to make the case for non-safety and nuisance factor. And battle becomes almost hopeless when people who are allegedly on your side are seen agreeing that exhaled vapor (indoors) is always a nuisance, always a concern. Especially for the children. Won't anyone think of the pawns children?

 

[tombaker]

I said I DID read it, and I understood pretty much every word of it.
What I did not understand is WHY they are asking for comments on substantial equivalence exemptions.

The part I bolded is exactly why there is concern for how the FDA has been denying substantial equivalence in so many cases thus far.


And even if we get past that, we are still just talking about grandfathered products here.
Those products that are not grandfathered are not even eligible to apply for this exemption to substantial equivalence.

They are NOT just talking about grandfathered products, they are talking about substantial equivalence to preceding products approved, some of which may be grandfathered.....if they are the same, they get approved. This is why they are asking for comments, among other reasons.

A manufacturer can ask for a full exemption for another of their products, this is good thing. But it does not change that anyone can ask for a ruling of Substantial equivilance based off any product approved or grandfathered. This is troublesome Why???? One E-Cig is in, they all are in, its a minor paperwork battle to get them in. One in, equals barn door open, All E-Cigs are the same, electric Coil, fluid with food grade items, nicotine, vapor, unfiltered. Unlike the FUD, E-Cigs are simple devices, easily compatible to each other, and without 4000 different chemicals.

You think the FDA inspects flavored coffee for what food grade flavorings are inside of it? They all get heated up too, not burned, heated. You have evidence that heated flavorings are toxins, better tell the world, because the Food and Drug Admin, is not on the same page as that.

 

[DC2]

Many possible regulations (they don't exist, legally many things are not possible, including banning Tobacco Products, as stated fully under the law passed in 2009.....anything is possible is just false, by logic, and by the letter of the law)

The possible regulations do exist, and they are all on paper already and have been since 2009 when the FSPTCA was approved by Congress.
All that is required is for the FDA to deem that those regulations apply to electronic cigarettes.

Our primary hope is that never happens, although you yourself have stated that it is a fantasy to think they won't be.
Our secondary hope is that when the deeming regulations are proposed, the proposal includes numerous exemptions or changes from what is currently written.

Our final hope is that if we get screwed, there will be lawsuits.

 

[tombaker]

Usage bans do seem to be happening in a lot of places and increasing at a rapid rate. IMO, this is the number one issue facing the vaping community currently.

Yup.
Vaping anywhere is a whole topic though. I have no issue with bans in schools or around schools, or school playgrounds. I have a major issue with parks, and public places, and vapers being pushed into smoking areas, with zero rain protection.

I have a major issue with people that go inside of libraries and want to Vape. Plenty of kids in them, just don't do it. You already have in California and other places people going in an watching porn, on the free internet in public libraries. ACLU in San Francisco and all. Next we will have porn viewing while vaping in libraries. Sorry but any vapers in public libraries, I think do huge public relations damage with the localities.

 

[tombaker]

The possible regulations do exist, and they are all on paper already and have been since 2009 when the FSPTCA was approved by Congress.
All that is required is for the FDA to deem that those regulations apply to electronic cigarettes.

Wrong everywhere, The only thing that FDA has agreed to in 2011, is they will deem E-Cigs a Tobacco Product.....that is all. 2 years later, nothing, they still have not even done that.

Once deemed, after the 6 months it will take to get that through after first submission.....then they can seek to write regulations as controled by the 2009 Tobacco Control Act. Those regulations are windmills in one's mind, they don't exist, but you think they are monsters out to get you.

In 1964 the surgeon general made it clear that smoking kills, yet plenty of people took up the legal act, acting as if they did not know. The FDA never stopped Cigarettes, and now the theory is around that a much safer nicotine, will be banned by the FDA, even though they never could do it with Cigarettes.

Meanwhile you want to donate to the fools errand of protecting the world from the big monster that is out to take away the Provari.
Or take credit for what the locals will do, in something that they just noticed the day of. Make a million predictions, only tell you about the ones that come true....cite the earlier prediction....carnies are not new.

 

[DC2]

They are NOT just talking about grandfathered products, they are talking about substantial equivalence to preceding products approved, some of which may be grandfathered...

No, they are not. This entire thread is about EXEMPTIONS from having to submit application for substantial equivalence.

This notice solicits comments on exemptions from substantial equivalence requirements for tobacco products.

What they are NOT doing is soliciting comments on how substantial equivalence applications should be handled.
Which is unfortunate, because that is where our problem is.

But it does not change that anyone can ask for a ruling of Substantial equivilance based off any product approved or grandfathered. This is troublesome Why????

Why? Tell me what was on the market in 2007 and you will understand why.

One E-Cig is in, they all are in, its a minor paperwork battle to get them in. One in, equals barn door open, All E-Cigs are the same, electric Coil, fluid with food grade items, nicotine, vapor, unfiltered. Unlike the FUD, E-Cigs are simple devices, easily compatible to each other, and without 4000 different chemicals.

The way the FDA has handle substantial equivalence to this point says you are engaging in wishful thinking.

You think the FDA inspects flavored coffee for what food grade flavorings are inside of it? They all get heated up too, not burned, heated.

How coffee is regulated has nothing to do with how tobacco products are/will be regulated.
I think you know that.

You have evidence that heated flavorings are toxins, better tell the world, because the Food and Drug Admin, is not on the same page as that.

The FDA says there are toxins in electronic cigarettes.
In fact, much of the world quotes them on that when THEY ban electronic cigarettes.

• New Characterizing Flavor

Inadequate information regarding the effect of a new characterizing flavor in
smokeless tobacco products on product initiation and cessation. Addition of a
new characterizing flavor may cause the new product to raise different questions
of public health because initiation may increase and/or cessation may decrease.

Changing the freaking flavor raises questions about public health?
Because changing the freaking flavor may have an effect on increase and/or decrease in cessation?

 

[k3vin]

Never argue with a fool,onlookers may not be able to tell the difference.

 

[DC2]

Once deemed, after the 6 months it will take to get that through after first submission.....then they can seek to write regulations as controled by the 2009 Tobacco Control Act. Those regulations are windmills in one's mind, they don't exist, but you think they are monsters out to get you.

This is just flat-out incorrect.

The proposed deeming regulations, which are in the hands of the OMB at this point, include any and all regulations they seek.
They are not going to write them later, they exist right now, and we will soon find out what they say.

In 1964 the surgeon general made it clear that smoking kills, yet plenty of people took up the legal act, acting as if they did not know. The FDA never stopped Cigarettes, and now the theory is around that a much safer nicotine, will be banned by the FDA, even though they never could do it with Cigarettes.

First of all, the FDA has not banned cigarettes because an Act of Congress has prevented them from doing so.
Whether or not they would ban cigarettes if they could is another discussion entirely.

And yes, they are also unable to ban electronic cigarettes if they are deemed to be a tobacco product.
We all have said that over and over and over and over and over again.

But they can regulate them to the point of crushing everything that is good about them.
What remains to be seen is if that is what they indeed will do.

Meanwhile you want to donate to the fools errand of protecting the world from the big monster that is out to take away the Provari.

Don't put words in my mouth.

Or take credit for what the locals will do, in something that they just noticed the day of. Make a million predictions, only tell you about the ones that come true....cite the earlier prediction....carnies are not new.

Your comments can be extremely rude, and it is very hard to talk to you.
I just wanted you to know that.

It remains to be seen if I will choose to waste any more of my time doing so.
I've said about all I have to say, so I'm thinking not.

 

[SloHand]

...... the substantial equivalence standards as FDA has traditionally applied them will be easy to meet takes a lot of faith or a lot of naivete. Or more likely, loads of both.

BINGO!

4. CASAA puts out that VV battaries can be banned, and that the FDA is signaling it with the topic of the OP. Its just wrong. Is this not specific enough?

Tom get off the battery thing. Stick to the local battles as being the key. Your right on that point.

I read Sottera and Brown vs Williamson, seems clear from both of those readings what the FDA's intentions are and that confirms CASAA's position on the issue in MHO. Reading any other interpretation is pie-in-the-sky thinking. They have absolutely no intention on give vaping an opening ... on anything.

As a Canadian (if that wasn't obvious) I watch with baited breath. You sneeze south of the border and we get a cold.

 

[tombaker]

Never argue with a fool,onlookers may not be able to tell the difference.

View attachment 293131

It is also important to understand that February 15, 2007 was selected as the original Grandfather Date because that was the date that the bill eventually became the Tobacco Control Act was first introduced into Congress, thereby putting the tobacco industry ( i.e. , manufacturers of cigarettes, smokeless tobacco, and roll-your-own tobacco) on official notice that it was going to be regulated by FDA. At the time, Congress had not contemplated including e-cigarettes (which were just being introduced into the U.S. market) or other non-traditional tobacco products in the legislation.

For this reason, it simply would not make sense for the Deeming Regulation to mandate February 15, 2007 as the grandfather date for e-cigarettes. Rather, using the same logic of “first notice,” there are two much more likely potential grandfather dates for e-cigarettes and other deemed tobacco products. The first would be the date that the NPRM for the Deeming Regulation is actually published in the Federal Register ( i.e. , potentially in January 2014, or July 2014, or at this rate 2015).

The second potential grandfather date would be April 25, 2011 – the date the Agency published its letter to stakeholders indicating that it intended to capture e-cigarettes through the Deeming Regulation.

Nearly 3 full years later, E-Cig products all over the place, and the FDA has yet to even get past the first step to deem E-Cigs a Tobacco product....though they said 3 years ago, they were gonna do it.....3 years of FUD of what will most likely be strong rules against marketing and selling to minors, as the 2009 act provided for.

 

[Sundodger]

3. Look at the top of the thread, CASAA gives what 8 hours notice on a hearing tonight. Very late, still good its there, but very late. The FDA can not do anything for many months or years, and thats if they are going to do anything......MEANWHILE, stuff like South San Francisco gets noticed not at all. Yes an email blast late is nice, better than nothing. But its like saying we only lost 28 chickens last night, lets get serious about the one we see in that Fox's mouth over there, we might be able to save it. The CASAA is simply not effective in stopping local bans. Simple google searchs locate other cities lining up, for months, that are just not anywhere on the CASAA radar. Things that can be tracked, and stopped.

Well big guy, why aren't you posting all of this information that you know of right here on ECF? Did you give us a notice of the SSF meeting? Why not? So you think CASAA should know immediately when these cities do this. I'll bet this wasn't even on the public agenda until today, hard to know what they are doing if they don't tell us, don't you think? If you know of bans that are being looked at that aren't addressed here, what's holding you back from pointing them out, by name and location? Especially since you think that the bans are the big fish that needs frying?

You also don't have to be a CASAA member to alert them to any information that you might think they should know. They aren't the NSA ya know, but they will listen.

 

[DC2]

It is also important to understand that February 15, 2007 was selected as the original Grandfather Date because that was the date that the bill eventually became the Tobacco Control Act was first introduced into Congress, thereby putting the tobacco industry ( i.e. , manufacturers of cigarettes, smokeless tobacco, and roll-your-own tobacco) on official notice that it was going to be regulated by FDA. At the time, Congress had not contemplated including e-cigarettes (which were just being introduced into the U.S. market) or other non-traditional tobacco products in the legislation.

For this reason, it simply would not make sense for the Deeming Regulation to mandate February 15, 2007 as the grandfather date for e-cigarettes. Rather, using the same logic of “first notice,” there are two much more likely potential grandfather dates for e-cigarettes and other deemed tobacco products. The first would be the date that the NPRM for the Deeming Regulation is actually published in the Federal Register ( i.e. , potentially in January 2014, or July 2014, or at this rate 2015).

The second potential grandfather date would be April 25, 2011 – the date the Agency published its letter to stakeholders indicating that it intended to capture e-cigarettes through the Deeming Regulation.

I can't say I disagree with any of that whatsoever.

 

[Rossum]

For this reason, it simply would not make sense for the Deeming Regulation to mandate February 15, 2007 as the grandfather date for e-cigarettes.

They're bureaucrats, and you expect them to make sense?

 

[Jman8]

Yup.
Vaping anywhere is a whole topic though.

Agreed, it is another topic from this thread. For the record, I disagree though with your limits to vaping everywhere. The good news (for you) is you're part of the majority that wishes to limit where vaping (even non-nicotine vapes) is limited to.

 

[kristin]

Tom,

How, exactly, do you propose CASAA start fighting these bans to be "more effective?" We would love to know how to get more people involved.

Because, CASAA does what it can. There is a 8-member board of directors (all unpaid volunteers) who cannot know about every proposed ban or tax. We ask our membership to tell us when they hear of a proposed ban in their area. That is what Regional Representatives are for. If no one steps up to represent their area or if the Rep hears about it late, the CASAA board does what it can to get the word out. Politicians don't care what the board says, they care what their constituents have to say, which is why we try to get local people to write and go to hearings.

Given that, is there anyone out there doing a better job of alerting over 8,600 members (of a membership it took us 4 years to build) when they hear of a ban? Is anyone doing a better job contacting the legislators and government officials with letters of opposition, testifying in person in places across the country (when possible), representing the consumer viewpoint to the media and mobilizing and assisting local vapers to write letters and testify to oppose the ban/tax? If so, please ask them to tell us their secret. If someone wants to help CASAA fight against proposed bans in every state, city, county, hospital, university campus and government property we'd be happy to get the help. But expecting eight volunteers to do all of the fighting by themselves is just plain ridiculous. No one could do what you expect without plenty of funding and hundreds of active and involved members working on the local level. If you know how to get people to become more involved, please, let us know the secret. It's taken years just to get a cohesive, dedicated board of directors and maybe a dozen dedicated, hard-working members willing to put in the work it takes just to do everything we do now.

And Elaine may be president of CASAA, but I am Vice President and I disagree with her take on mod-style devices being regulated by the FDA. Her's is still just one opinion of eight directors and giving her personal opinion is not the same as CASAA policy. CASAA's official take on the FDA can be found here: The FDA & Deeming Regulations of E-cigarettes and there is NO claim that devices being banned (including Provari) is the major issue we have with the FDA deeming regulations. You conveniently ignored my entire post disagreeing with Elaine and Bill's view that mod-type devices will fall under FDA control.

And Jay-dub, your statement that implies CASAA would lie, exaggerate or twist facts to build membership or raise funds shows just how little you still know about CASAA's agenda and those of us dedicating our time and effort to it. We aren't trying to build an organization for the future. We don't get paid for our efforts. We don't make a career out of advocacy. We'll honestly be happy when this is all over with and we can get back to our lives. But no one else was stepping up to speak for vapers when CASAA formed and we did. And until recently, we were the only ones doing things at this level. We were so sick of the lies and manipulation that we make a concerted effort not to use the same tactics as our adversaries. If we didn't honestly believe that these possibilities exist and are a significant threat, we wouldn't be talking about them. We don't talk about these possibilities in order to increase membership or raise funds, but ONLY as an effort to raise awareness in the vaping community, in hopes that they will step up and speak out when the FDA does deem regulations. But I'd guess that 85% of the people using an e-cigarette today have absolutely no idea what FDA regulations could mean in the future. If we didn't at least discuss the possibilities and they do come true, we would be blamed for not telling members of our suspicions and concerns and giving them the opportunity to act.

For you to imply we share some of the same self-serving behaviors as groups like the ALA, ACS, etc. (even though you didn't specifically name them), is just revolting to me. The only "self-servicing" we do is as vapers trying to make sure that the FDA doesn't over-regulate these products and ruin it for everyone and fight state/local bans and unfair taxes. Building membership and raising funds is only secondary to that as a means to be more effective and accomplish that goal. But as I state in meeting after meeting - with those dedicated and generous members who actually "bother" to show up to our member meetings - we cannot do our job without active participation and support from the members themselves. If CASAA isn't accomplishing everything it should be, that falls not only on the shoulders of the board of directors, but on the membership who can help but don't and those in the vaping community that don't even bother to join and try.

 

[rothenbj]

BINGO!



Tom get off the battery thing. Stick to the local battles as being the key. Your right on that point.

I read Sottera and Brown vs Williamson, seems clear from both of those readings what the FDA's intentions are and that confirms CASAA's position on the issue in MHO. Reading any other interpretation is pie-in-the-sky thinking. They have absolutely no intention on give vaping an opening ... on anything.

As a Canadian (if that wasn't obvious) I watch with baited breath. You sneeze south of the border and we get a cold.

I think you got the flu right after we sneezed (ie. the '09 dog and pony show leading to a nic ban for e cigs in Canada creating a black market).

 

[rothenbj]

There has definitely been a shift in the approach to bans over the years. Early ban attempts were well advertised in advance and the vaping community was able to organize, put up a good fight and in many cases win. This apparently didn't sit well with the ?non-profit?"health" associations as well as people like the CDC. They went back to the table and discussed a better way. Once they meet too much opposition and weren't successful with their approach, it appears they've worked to set the groundwork to minimize the opposition.

I believe today they are spending a lot of time preparing the health departments of major cities like New York to draw up their battle plans. Once the health departments are sold on the plan, they turn around and get the membership of the city councils on board. Nobody outside the political structure is aware any of this is going on. At that point they are giving very short notice of their proposed regulations, run a required public session and vote shortly after on the predetermined outcome.

If anyone missed NYC's meeting, spend the time to watch the meeting. I personally got through about a third and stopped. It was quite clear the agenda was scripted. I could be wrong, but I need to be convinced. How come no one from San Francisco brought up the proposals there? There must be thousands of vapers in the area and at least a few must get out of the newbie section or General Discussion section to understand that the regulations proposed might effect them. The current vaping businesses in the area would certainly be paying attention, but not a whisper until right before the meeting.

As Kristen stated, if someone has a strategy that can better battle these banning initiatives, step up and lay out a strategy. I've heard the complaints about what they're doing just like Monday morning coaches explain why the home team wouldn't have lost if they'd done the right thing. If you're not part of the solution, you're part of the problem.

 

[tombaker]

Tom, (clipped down with numbering added so as to reply)

1. But expecting eight volunteers to do all of the fighting by themselves is just plain ridiculous. No one could do what you expect without plenty of funding and hundreds of active and involved members working on the local level.

2. And Elaine may be president of CASAA, but I am Vice President and I disagree with her take on mod-style devices being regulated by the FDA. Her's is still just one opinion of eight directors and giving her personal opinion is not the same as CASAA policy.

3. And Jay-dub, your statement that implies CASAA would lie, exaggerate or twist facts to build membership or raise funds shows just how little you still know about CASAA's agenda and those of us dedicating our time and effort to it.

4. If we didn't honestly believe that these possibilities exist and are a significant threat, we wouldn't be talking about them.

5. But I'd guess that 85% of the people using an e-cigarette today have absolutely no idea what FDA regulations could mean in the future.

6. For you to imply we share some of the same self-serving behaviors as groups like the ALA, ACS, etc. (even though you didn't specifically name them), is just revolting to me.

1. I don't expect that CASAA can do it by themselves, my previous thread, was related to a major miss-focus of vapers on the FDA. CASAA seemingly wants to continue to focus on the FDA, which was severly crippled in anything it can do. What is left to do with the FDA, is not going to be changed by writing Senators and Congressman, who don't have standing, against the FDA which is empowered by a law they passed in 2009. So I suggest its a waste of time pointing people to Senators. The major firms like V2, Njoy, and big Tobacco owned BLU, are going to handle the FDA entirely. The FDA has not done anything for years, while those firms have moved aggressively selling E-Liquid and clearomizers (V2), and running large scale TV advertising. NJoy gets a 20 million dollar private equity infusion, and BLU gets bought by Big Tobacco outright. These are the big boys that will handle the FDA. That CASAA continues to push pure out wrong information on the FDA, is in my view giving out directions, in the wrong direction.

2. The President of CASAA speaks for CASAA, period. Ms. Keller testifies with those views. Saying APV hardware will get banned by the FDA is major misinformation. While saying you disagree with the CASAA position, is fine, because it is reality, it does not stop what CASAA is advocating, and perpetuating. CASAA.org has you listed as web and communications, and the President as someone who the person who speaks for CASAA in hearing with the FDA. She is the person in charge of CASAA and speaks for it. APV hardware is not anywhere within the scope of the FDA, and Sottera cemented that completely. V2 sells APV hardware, clearomizers, voltage regulated DC sources, E-liquid. If anyone is going to be worried about the FDA banning hardware, it would be them.

3. CASAA is exaggerating the dangers of the FDA, their legal analysis is wrong, as I have pointed out, and they are saying that the FDA can ban VV batteries. It’s a further exaggeration to say the FDA can simply through up a defacto ban of all E-Cigs. The law prohibits that. Read the OP too, the links.

4. I believe you think the FDA is about to do all sorts of terrible things, but in the face of the facts, CASAA is stuck in a pre-Sottera mindset. The victory was given, and upheld by a uniamos Appeals court. The next step would have been the Supreme Court, but the FDA took its lump in 2011, said it would toss in E-Cigs with the 2009 law, and has in the last 3 years not done it. The wild fears and not reality based, being fearful is not prevention.

5. 85% of vapers might not know about what the FDA can do or not, but I maintain that neither does CASAA. CASAA and Godshall believe APV hardware can be banned, and that all E-Cigs on the market today can just be pulled from the shelves. Wrong is wrong. CASAA is part of the 85%.

6. Kristin when you say that professionals in association with the American Cancer Society, and American Lung Association, lie, and cheat, and don’t care if people die as a result, is over the top. It is the kind of attacks that make anything afterwards not very meaningful. Why would any local city listen to someone from an organization that holds those belief’s, Nobody from CASAA is contradicting your assertions. I am sure they care if people live or die, regardless if you are unhappy them. ACS has stated they have some concerns, but have officially stated have not position to them as of yet.

Some of information from links of the OP, which contradicts so many fears.

An order under section 910 is not required, however, if a manufacturer
submits a report under section 905(j) of the FD&C Act (21 U.S.C.
387e(j) demonstrating the new tobacco product's substantial equivalence
to an appropriate predicate product, and FDA issues an order finding
the new product to be substantially equivalent to the predicate product
and in compliance with the requirements of the FD&C Act.

FDA has established a pathway for manufacturers to request
exemptions from the substantial equivalence requirements of the FD&C
Act in Sec. 1107.1 (21 CFR 1107.1) of the Agency's regulations.
As described in Sec. 1107.1(a), FDA may exempt tobacco products that are
modified by adding or deleting a tobacco additive, or increasing or
decreasing the quantity of an existing tobacco additive, from the
requirement of demonstrating substantial equivalence if the Agency
determines that: (1) The modification would be a minor modification of
a tobacco product; (2) a report demonstrating substantial equivalence
is not necessary for the protection of public health; and (3) an
exemption is otherwise appropriate.

Notice it says, “to an appropriate predictate product, Not their own product. If one E-Cig is in, they are all in. The core of the invention of the E-Cig is not changed. This is good news, and should quell FUD.

CASAA wants to focus on the FDA, go in front of them also, talk about what may be in regulations where regulations don't exist. The draft deeming regulation is written, it does not contain a bunch of regulations. Deeming a product IN, is the first step, after that the marketing to minors, selling to minors.

 

[tombaker]

If you know of bans that are being looked at that aren't addressed here, what's holding you back from pointing them out, by name and location? Especially since you think that the bans are the big fish that needs frying?

I did a 5 minute search and found what I believe is a big local ban flying under the radar of everyone. Will post it, after I spend more minutes tomorrow after confirming nobody has mentioned it. As they say, the local bans are the low hanging fruit, very easy to find and pick off.