Criterion 83.7(c) requires that the petitioner has maintained political influence or authority over its members as an autonomous entity from historical times until the present.
Summary of the Proposed Finding
The PF concluded, based on the available evidence, that the petitioner did not meet criterion 83.7(c) at any point in time. The PF evaluated the petitioner's case over four distinct periods: (1) 1600 through 1800; (2) 1800 through 1900; (3) 1900 through 1975; and (4) 1975 through the present.
For the period before 1800, the PF concluded that the available evidence did not demonstrate that the petitioner's members or its claimed ancestral family lines were part of any Western Abenaki Indian tribe in either Quebec or Vermont. Additionally, the petitioner lacked evidence that its ancestors were part of the group led by the colonial period's known Western Abenaki chiefs, like Grey Lock and Joseph-Louis Gill. Furthermore, the petitioner did not provide evidence that its specific claimed ancestors were a group exercising political influence before 1800 (Abenaki PF 2005, 93-94). Consequently, the available evidence did not demonstrate that the petitioner's ancestors maintained political influence or authority over its group before 1800.
For the period from 1800 to 1900, the available evidence did not demonstrate that the petitioner's claimed ancestors were a group from 1800 to 1875, exercising political influence or authority. During this period there were several land claims made by Iroquois Indians who claimed land in northern Vermont. However, the available evidence does not show that an Abenaki group from northern Vermont was a party to these land claim activities. Furthermore, the accompanying discussions did not mention the presence of an Abenaki group residing in northern Vermont who might also have claim to lands in the northern part of the state.
The PF concluded, "no Western Abenaki entity containing the petitioner's claimed ancestors existed in northwestern Vermont in the 19th century capable of exercising political authority or influence," but encouraged the petitioner to provide evidence demonstrating how its claimed ancestors exercised political influence or authority as a group during this period (Abenaki PF 2005, 95).
Later in the 19th century, in particular, for the period from 1875 to 1900, the petitioner claimed that Nazaire St. Francis provided food and clothes to children, and that Cordelia (Freemore) Brow was a midwife; consequently, the petitioner argued, these two ancestors served as informal leaders of a community of its claimed ancestors. The PF concluded, however, that these activities alone did not constitute an exercise of political authority, but encouraged the petitioner to investigate the activities of these individuals further (Abenaki PF 2005, 95-96). Neither the petitioner nor any other party submitted comments that addressed this request by the Department.
For the period from 1900 to 1975, the PF concluded that the petitioner "presented little evidence demonstrating informal leadership among any group of the petitioner's claimed ancestors" (Abenaki PF 2005, 107). Although the petitioner provided a few examples of individuals who allegedly exercised political influence, the PF found this evidence insufficient and requested more substantive evidence that these individuals influenced members of a distinct group and evidence that their authority extended beyond their family members. Furthermore, the PF encouraged the petitioner to provide information documenting how the group's ancestors responded to the Vermont Eugenics Survey or the Iroquois land claims of the 1950's, two events that would have been likely to elicit a political response from the petitioner's ancestors.
For the period since 1975, the PF noted the creation of the SSA as an active political organization, particularly as evidenced by the leadership of Homer St. Francis and Leonard Lampman. During this period, the SSA engaged the State of Vermont in several legal disputes, started its pursuit of Federal acknowledgment, and instituted several social and cultural programs. However, the PF concluded that the available evidence was not sufficient to demonstrate widespread participation by the group's members in these political processes; instead, the available evidence suggested the "political influence is limited to the actions of a few group members pursuing an agenda with little input from the membership" (Abenaki PF 2005, 108). Political influence should exist bilaterally between leaders and followers . 20. The PF recommended that the petitioner submit additional evidence, including meeting minutes and sign-in sheets, which might help clarify the nature of the political processes and the group's participation in those processes (Abenaki PF 2005, 102-103, 106).
In summary, the PF concluded that the available evidence was insufficient to show that the petitioner met the requirements of criterion 83.7(c) at any time during the period from early historical contact to the present.
Comments on the Proposed Finding
On May 15, 2006, the Department received a letter from the petitioner, signed by April St. Francis-Merrill and six additional council members that included four brief essays by Frederick Wiseman that constituted a partial response to the PF. Only one of these four essays, an essay about a "chief' in a souvenir postcard, addresses criterion 83.7(c).
On May 17, 2006, the Department received comments from Lester M. Lampman and several individuals associated with the petitioning group. These comments consisted of a photograph of Senator Patrick Leahy of Vermont with Leonard Lampman, a photograph of the "Grandma Lampman Site," and 11 pages of additional documents. Some of these comments apply to criterion 83.7(c) for the modern period.
20. The Department has interpreted the regulations in past decisions that, "[i]t must be shown that there is a political connection between the membership and leaders and thus that the members of a tribe maintain a bilateral political relationship with the tribe .... If a small body of people carries out legal actions or makes agreements, ... the membership may be significantly affected without political process going on or without even the awareness or consent of those affected" (Miami FD 1992, 15).
On August 22, 2006, the Department received comments from the governing body of the petitioner, including a set of photocopied treaty documents, four Internet essays entitled "Abenaki History," and a collection of meeting minutes from the 1970's, 1980's, and 1990's. Much of this material applies to criterion 83.7(c).
John Moody submitted a set of comments that the Department received on May 15, 2006. His submission included 9 pages of comment and discussion; and 10 pages of photocopies of primary sources. Some of his comments apply to criterion 83.7(c).
The petitioner did not submit any additional information, as the PF requested, describing how its ancestors responded politically to the Iroquois land claims in the 19th century, or the Vermont Eugenics Survey (Abenaki PF 2005, 107). Similarly, the petitioner did not provide any further evidence, as the PF requested, describing the activities of Nazaire St. Francis and Cordelia (Freemore) Brow, the two women whom the petitioner alleged were informal political leaders (Abenaki PF 2005, 107). Moreover, although the petitioner submitted a collection of meeting minutes from the 1970's, 1980's, and 1990's, the petitioner did not submit any information, as the PF requested, demonstrating bilateral political influence between the SSA leaders and the broader membership.
Analysis for the Final Determination
For clarity, the FD will present its findings using the four periods of analysis that that the PF used. These four periods are: (1) first contact through 1800; (2) 1800 through 1900; (3) 1900 through 1975; and (4) 1975 through the present.
Political Influence, First Contact through 1800
In its August 2006 submission, the petitioner included comments that apply to the Abenaki Indians before 1800. These comments include the set of Internet essays from the "Manataka American Indian Council" on Abenaki history and culture during the 16th, 17th, and 18th centuries. These Internet essays, as described above under 83.7(b), are entitled to little weight as evidence within the meaning of the regulations. These essays provide some evidence in support of the PF's conclusion that there was an Abenaki entity in or around northern Vermont before 1800 that exercised political authority. However, the available evidence does not show that the Internet essays are discussing the petitioner's ancestors, and therefore these Internet essays do not help demonstrate that the petitioner's ancestors exercised political influence within a group in or around northern Vermont.
In the same August 2006 submission, the petitioner submitted several treaty and proclamation documents from the 18th century. These documents are described above under criterion 83.7(b). These documents speak of Indians in non-specific, generic terms and do not link the petitioner to any specific Abenaki Indians from northwestern Vermont. Therefore, these documents do not provide evidence that the ancestors of the petitioner exercised political influence within a group in northwestern Vermont before 1800.
In his May 2006 comments, Moody discusses two sets of documents that were allegedly created in the late 18th century but, at present, either are not locatable or do not exist. Moody speculates that, if found, these documents might help describe Abenaki leadership in northwestern Vermont during the 18th century in a manner that would satisfy criterion 83.7(c). Moody's speculations, however, cannot be verified and thus do not provide evidence for the purposes of this criterion. As this FD discusses elsewhere, the Department makes its decisions based on available evidence (see criterion 83.7(e) for a further discussion of these documents and their unavailability).
Political Influence, 1800-1900
For the period from 1800 to 1900, there is one piece of information submitted in the comment period that pertains to criterion 83.7(c). This is a copy of the Treaty of Ghent, submitted by the petitioner in August 2006. This treaty, signed in 1814, secured peace between the United States and Great Britain following the War of 1812. As discussed under criterion 87.3(b) above, Article IX of the treaty discusses matters pertaining to Indians, but uses only the generic terms "Indian," "tribe," and "nation" to refer to Indian entities. The treaty makes no specific reference to an Abenaki entity or an Indian community in northwestern Vermont. Therefore, the Treaty of Ghent does not provide evidence to help the petitioner meet criterion 83.7(c).
Political Influence, 1900-1975
Although the petitioner provided a few examples of individuals who allegedly exercised political influence during this period, the PF found that this evidence did not demonstrate political influence as described by the criterion. The PF requested more substantive evidence that these individuals influenced members of a distinct group and evidence that their authority extended beyond their family members. Furthermore, the PF encouraged the petitioner to provide information documenting how the group's ancestors responded to the Vermont Eugenics Survey or the Iroquois land claims of the 1950's, two events that would have been likely to elicit a political response from the petitioner's ancestors. The petitioner did not submit any of this requested additional evidence during the comment period.
During the comment period, the petitioner resubmitted a black and white postcard picturing an unidentified "chief' to support its claim of political influence of an historical Abenaki Indian tribe in Vermont in the early 20th century. The PF stated the "chief' depicted on the souvenir tourist postcard did not provide evidence of political influence connected to the group's claimed ancestors. The petitioner's "Against the Darkness" video presentation contains the same black and white postcard showing a man sitting in a small boat. The photograph is undated, but the petitioner estimates that it dates to around 1900. The provenance of the postcard is unclear, but the petitioner stated earlier that "[t]he postcard was purchased from the Internet from a California collector" (Wiseman Catalog 2005). The postcard contains the caption "Chief of the Wabanacus, Highgate Springs, VT." In "The Case of the 'Chief of the Wabanacus' Post Card," Fred Wiseman states:
The BAR/BIA requires Euroamerican evidence of historical political activity and/or status by Vermont Abenakis to document political continuity. There is no
more important signifier of Native political status in turn-of-the-century Anglo-America than the term "chief," especially when closely tied to an ethnic identifier.
One of the more interesting misinterpretations by the BAR/BIA of the Missisquoi documentary record is the case of the ca. 1900 postcard with a picture of a dark-complexioned man in a boat.... BAR/BIA attacks this simple, common sense evidence of political status by Euroamericans, making an implausible argument that the postcard does not mean what it says.
The specific term "Chief' was applied to the individual in the boat through a negative-incised legend at the bottom of the postcard. This postcard inscription was reinforced by the Ben Gravel memoir (e.g. Voice of the Dawn, page 144) that refers to a chief during the same general period in Swanton. (Wiseman 5/15/2006)
The name of the "chief," however, is scratched out, making identification of the individual impossible. If this man was a "chief' of any Abenaki community, the petitioner needed to provide a name for him, and describe at least some actions carried out under his leadership to be meaningful evidence under 83.7(c). The petitioner provided no documented information regarding this individual. This souvenir postcard does not provide evidence of political influence under 83.7(c) for the petitioner during this time.
Political Influence, 1975 to the Present
The PF analyzed ASHAI meeting minutes for the years 1978-1984 and 2001-2005. The petitioner censored some of the original ASHAI meeting minutes. The PF requested that the petitioner submit uncensored copies of the censored minutes, along with copies of meeting minutes for the years not yet submitted. The PF also analyzed SSA council meeting minutes for 1976-1984 and 1996-2005, but requested meeting minutes for the 1985-1996 period (Abenaki PF 2005, 102).
In its August 2006 submission, the petitioner submitted additional meeting minutes. There are three types of meetings for which the petitioner submitted minutes: council meetings, ASHAI meetings, and joint meetings of the council and ASHAI. During the comment period, the petitioner responded by submitting 293 pages of minutes of ASHAI meetings for the years 1987 to 1995, along with minutes from 15 joint meetings of the ASHAI and the council that spanning 1988 to 1997. The new submissions also included 600 pages of council minutes for 1976 to 1996.
With the previously submitted minutes, the petitioner's "tribal council" minutes cover a span from 1976 to 2005. The new and previously submitted ASHAI and joint minutes span from 1988 to 1995. There are some months for which the petitioner did not submit meeting minutes, indicating that there may not have been meetings during those months, or that the minutes were unavailable for submission; the petitioner did explain why certain months had no meeting minutes. As requested, the new submissions contained names of those who participated in the
meetings. The comments, along with previous materials, support the PF's finding that the petitioner first created its political organizations in the 1970's.
The group began recording meeting minutes in the 1970's. In 1975, with the encouragement of Ronnie Cannes, a non-Abenaki, the group founded the ASHAI (SSA 10/1982 Petition, 105). It formed the "Abenaki Tribal Council," in late 1976 or 1977 (ATC 1977, 1). The two organizations often shared board members and overlapped in their activities. As a whole, the organizational minutes of ASHAI and the council showed some attempts by the group to seek support or to establish relations with Indian organizations, State agencies in Vermont, and Federal agencies. The group also became interested with tribal recognition issues beginning in the 1970's and continuing to the present. Their pursuit of tribal recognition issues brought them into contact the Native American Rights Fund, the State of Vermont, and Federal agencies.
Since 1995, most of the petitioner's political activities within its organizations were mainly the product of the St. Francis family and its limited number of supporters. The PF stated:
In 1995, he [Homer St. Francis, 1935-2001] led a successful drive to change the group's constitution to make the position of "Chief" a lifetime appointment limited to members of his family, a move that many in the group disagreed with and which contributed to a split within the group (Walsh 11/7/1995). When he became too ill to handle the daily responsibilities of the group, he named his daughter "Acting Chief' and then became the "Grand Chief" He remained in this position until his death in 200, and his daughter April (St. Francis) Merrill currently serves as "Chief." Two of St. Francis's sons served on the group's governing body with their father and sister for many years, as did a number of nieces and nephews.
... [A newspaper report from 1979 stated that] St. Francis's "authoritarian style" and his disregard for the opinions of others led to the formation of the breakaway group. This would not be the last time that a portion of the group split away from the main body nor would it be the last time that St. Francis's leadership was cited as the reason. (Abenaki PF 2005, 104)
The PF also stated:
The September 27, 1998, general meeting includes the information that 14 people were in attendance, but does not say whether those 14 included the people who were already serving on the council, or if all 14 of those people were eligible to vote. Nominations were made for members to serve on the ASHAI board and on the group's governing body, but instead of ballots being cast, the minutes indicate that ... the Chief cast one ballot, to elect Tribal Council and ASHAI board of directors by acclamation (SSA 1998.09.27, 1). Further, the minutes read as follows: "We don't have to have an election. You are all now all Tribal Council and ASHAI board of directors. . . ." (Abenaki PF 2005, 103)
The petitioner did not provide evidence that the membership as a whole cared about, agreed, or disagreed with the decisions and actions of its leaders. An important task for the petitioner during the comment period was to provide evidence of bilateral political influence between the council members and ASHAI officers on the one hand, and the broader membership on the other.
The available minutes from the council, ASHAI, and joint meetings did not show that members participated in the decision-making process or that they expressed concern about the importance of political issues. That is, the minutes do not show bilateral influence between the council members and ASHAI officers on the one hand, and the broader membership on the other. For example, on March 12, 1977, a special membership meeting called to adopt a "Constitution for the Abenaki Nation/Vermont" had only 19 members present.
Another example that suggests a low degree of participation in the SSA's political process can been seen by examining the attendance at nomination meetings. The petitioner's nomination meetings represented one of the few times that the general membership could nominate and vote for candidates to run for offices of the petitioner's organizations. Yet, the SSA had only limited attendance at these meetings. While petitioner's membership during the late 1970's and early 1980's varied between 300 and 1,670 members, the attendance at the nomination meetings were very limited. The following is a list of the SSA's nomination meetings and the number of people who attended them:
On September 26, 1977, 39 people attended.
On August 13, 1979, 18 members attended.
On August 5, 1981, 37 people attended.
On September 30, 1982, 19 people attended.
On December 7, 1982, 17 people attended.
On August 30, 1983, 24 people attended.
On September 27, 1984, 10 people attended.
On September 2, 1985, 13 people attended.
On September 17, 1986, 9 people attended.
On August 27, 1987, 16 people attended.
During this 10-year period, an analysis of the 120 members attending the nomination meetings demonstrated:
85 members attended only one meeting.
14 members attended two meetings.
5 members attended 3 meetings.
2 members attended 4 meetings.
4 members attended 5 meetings.
3 members attended 6 meetings.
0 members attended 7 meetings.
1 members attended 8 meetings.
0 members attended 9 meetings.
2 (Homer St. Francis and Leonard Lampman, Sr.) attended all 10 meetings.
After 1987, council minutes of nomination meetings are not available.
The minutes show the group first created its political organizations in the 1970's, but they engaged only a few members of the petitioner's group. The evidence does not demonstrate a bilateral political relationship between the rest of the members and the group's leadership. For example, on September 11, 1978, 24 people attended the meeting. Homer St. Francis spoke about "having more people attend meetings and having more volunteers instead of the same ones all the time." The PF commented that this low rate of participation in the group's decision-making process and elections showed a lack of a bilateral relationship between the group's leadership and the broader membership (Abenaki PF 2005, 103). Between August 1976 and October 1996, a review of 194 council meetings and the number of participants revealed that the average attendance of council meetings was between 8 and 9 individuals of whom 4 to 8 were board members. The available information reveals that attendance at council meetings did not represent an attendance high enough to demonstrate the involvement of a substantial portion of the group's members. High levels of meeting attendance are not required to demonstrate the existence of political processes, and this final determination has evaluated the evidence about meeting attendance together with other evidence of political participation for this period. However, the evaluation of that other evidence for both the proposed finding and the final determination does not show that the group's political activities involved a signification portion of the group's membership or that a bilateral relationship existed between the members and the group's leaders.
Since the 1970's, the petitioner has claimed, to varying degrees, as many as 1,500 to 2,000 members in its group. However, as indicated by the minutes, the petitioner lacks a clear understanding of the numbers of its claimed members. As discussed above in criterion 83.7(b), at a September 10, 1996 "tribal council" meeting, "potential citizens" had been "selected more-or-less at random from the genealogy computer and the phone book" (ATC 9/10/1996). Recruiting "potential citizens" from the Internet and a phone book demonstrated that the petitioner lacked a community over which to exercise political authority. Moreover, the minutes clearly demonstrate that only a fraction of the members participated in political decision-making processes regardless of the actual number of members. Attendance at meetings is only one way that a group may document political processes. In this case, however, the petitioner did not provide other evidence to show that the members were aware or involved in issues of concern to the governing body.
Based on the available evidence, the petitioner's political influence is similar to that maintained in social clubs, nonprofit groups, or other voluntary organizations. Generally, a small number of the petitioner's members carried out political actions affecting the political interests of only a small number of active members, but the available evidence shows that the rest of the claimed members had little or no participation in the council's actions. Under the acknowledgment regulations, a petitioner must be a distinct political body, able to exercise significant formal or informal influence over its members, who in turn influence the policies and actions of the leadership as defined under criterion 83.7(c)(1)(iii). The available evidence demonstrates that participation in the group's political processes was not widespread across the claimed members.
Lester Lampman's comments indicated his concern about the process to achieve Federal recognition and attempted to provide some support for the group's petition. Lampman's cover letter included a short history of his family and the petitioning group. His comments included: (1) A letter from Congressman Leahy to Chief Leonard Lampman, (2) Picture of Grandma Lampman's Plaque [See discussion in criterion 83.7(a) above], (3) Internet descriptions of a few corporations, associated with the petitioner and (4) other materials. Mr. Lampman's letter referred to oral tradition materials, but during an extended comment period, he did not submit these materials. Mr. Lampman's comments generally lacked supporting documentation and explanation of the political processes of the petitioner as defined under criterion 83.7(c).
John Moody also submitted comments regarding political influence for the petitioner for this period. He stated:
... leadership among the Missisquoi Abenaki has clearly been a matter of following by example rather than by an imprimatur granted by a Euro-American sovereign. This Missisquoi leadership pattern is found extensively from the 19th and 20th century with both women and men. Although Homer St. Francis and Blackie Lampman were major leaders, and chiefs, in the 1970's to 1980's Missisquoi re-emergence, their daughters Chief April St. Francis Merrill and Louise Lampman Larivee, are major leaders in the current time period.
... Even in the 20th century, when all non-Native institutions and law inveigh against it, there are still some examples of matrilinearity at Missisquoi. There are also numerous examples of women in major leadership roles, including the role of community leader. (Moody 5/5/2006, 4)
Moody did not provide additional names of leaders nor did he document his claims of the political leadership for the petitioner. Moreover, he did not demonstrate the group had maintained political influence over its members throughout history as an autonomous Indian entity.
For the period since 1975, the petitioner did not demonstrate its leaders could influence and mobilize the claimed membership. The petitioner did not show that there was widespread knowledge, communication or involvement in political processes by most of the group's members or that its members considered issues and actions by the leaders to be of importance. The council's activities did not show that a bilateral political relationship existed. The available evidence for both the PF and the FD does not demonstrate that the claimed membership as a whole was aware of or affected by council activities in significant ways.
Final Determination's Conclusions on Criterion 83.7(c)
The PF concluded that there was an Abenaki entity in or around northwestern Vermont through the late 18th century. The PF also concluded that the available evidence did not show that the petitioner's ancestors had a historical connection to these 18th-century Abenaki Indians. During the comment and response periods, the Department received no additional evidence showing that the petitioner's ancestors belonged to an Abenaki Indian entity living in Vermont prior to 1800.
The petitioner submitted documents that discussed 18th-century Abenaki Indians, but no evidence that these Abenaki Indians were the petitioner's ancestors. John Moody alluded to 18th century documents that were allegedly missing; however, Moody's speculations cannot be verified and thus do not provide evidence for the purposes of 83.7(c). The Department makes its decisions based on available evidence. Therefore, the FD affirms the PF's conclusions and determines that petitioner does not meet criterion 83.7(c) before 1800.
For the period between 1800 and 1900, the PF concluded that the record did not contain any evidence that demonstrated the exercise of political influence as required by criterion 83.7(c). In particular, the PF noted the lack of political activity on the part of any Vermont Abenaki group to dispute claims made by the Iroquois Indians to lands in Vermont. The petitioner mentioned two ancestors, Nazaire St. Francis and Cordelia (Freemore) Brow, who provided food to children and served as a midwife, respectively. However, the information provided about these women does not constitute sufficient evidence to demonstrate that the two were "exercising political authority or influence" as required by criterion 83.7(c). The PF encouraged the petitioner to submit more information on the activities of these two ancestors during the comment period (Abenaki PF 2005, 96); however, the petitioner did not do so. During the comment period, the Department received only one document that referred to political activity in the 19th century, a copy of the 1814 Treaty of Ghent. This document does not specifically refer to the petitioner and is too vague to assist in addressing the criterion. Therefore, the FD concludes that the available evidence is not sufficient to satisfy criterion 83.7(c) between 1800 and 1900.
For the period since 1900, the PF encouraged the petitioner to submit evidence that its ancestors maintained political influence or authority over each other as an autonomous entity from historical times to the present. Similarly, the PF asked the petitioner to provide documentation of the political authority of "family bands" and political leaders before the formation of its 1970's council. The petitioner's comments did not demonstrate what its claimed ancestral leadership or families were doing to exercise political influence or authority, nor did the petitioner show its claimed ancestors exercised political influence or authority over each other as an autonomous entity since 1900. Petitioner did not offer evidence of its general membership acknowledging the heads of petitioner's recent organizations as leaders. The petitioner's comments did not contain sufficient evidence to remedy the deficiencies noted by the PF. For the period from 1900 to the present, the petitioner did not demonstrate political influence and or authority as an autonomous entity. Therefore, this FD affirms the PF's conclusion that the petitioner does not meet criterion 83.7(c).
Based on the available record, the FD concludes that there is insufficient evidence to demonstrate that the petitioner maintained political influence or authority over its members as an autonomous entity at any point in time. Because the available evidence does not demonstrate that the petitioner maintained political influence or authority over its members as an autonomous entity from historical times until the present, the petitioner does not meet criterion 83.7(c).
Criterion 83.7(d) requires a copy of the group's present governing document including its membership criteria. In the absence of a written document, the petitioner must provide a statement describing in full its membership criteria and current governing procedures.
Summary of the Proposed Finding
The PF found that the petitioner satisfied criterion 83.7(d) by submitting a copy of its governing document, a document entitled "Constitution of The Sovereign Republic of the Abenaki Nation of Missisquoi." This constitution "was presented to the citizenry at a Special General Meeting on November 5, 1995" and "ratified at a Special General Meeting" on February 25, 1996 (SSA Constitution 02/25/1996, 11). This document described the group's membership criteria and current governing procedures. The petitioner also submitted a copy of a superseded 1982 constitution and meeting minutes. However, the PF noted several minor issues with the 1996 constitution and suggested that the petitioner remedy these issues. (Abenaki PF 2005, 110-112).
Summary of the Comments on the Proposed Finding
The Department received no comments, from either the petitioner or any other party, on the PF's conclusions under criterion 83.7(d).
Final Determination's Conclusions on Criterion 83.7(d)
The Department's PF concluded that, based on the available evidence, the petitioner satisfied criterion 83.7(d). Although the petitioner did not respond to the Department's suggestions in the PF, the available evidence satisfies the criterion. Therefore, the FD affirms the PF's conclusion that the petitioner meets criterion 83.7(d).
FASCINATING-ENLIGHTENING-INFORMATIVE ISN'T THIS DOCUMENTATION? THERE IS MORE TO BE POSTED.....