Via this blog post comes word that Bob Bauer and the CLC have filed these comments taking the position that the WRTL rulemaking creating an as applied exemption should not extend to disclosure rules. It follows comments Richard Briffault and I filed on this subject on Friday and in opposition to somecomments of the James Madison Center. Writes Bob: “As the CLC and I argue in our joint comments, views may differ on the merits or the constitutionality of disclosure in this instance or others. It is not an issue without consequence, however, and it is neither settled by WRTL, nor ripe for Commission consideration and decision in a rushed proceeding, the purpose of which is to comply with the clear terms, which do not include disclosure, of the Court’s ruling.”