Even crediting the contiguity objection, condemnation by yet another . organ was unlikely to slow the settler movement; 76 × 76. See Eugene Kontorovich & Penny Grunseid, At the ., Only Israel Is an “Occupying Power ,” Wall Street J . (Sept. 13, 2016, 7:15 PM), http:///articles/at-the-u-n-only-israel-is-an-occupying-power-1473808544 [ https:///D8VN-JFEA ] (documenting the .’s pervasive anti-Israel bias). instead, it would foreseeably harden Israel’s resolve and expedite its settlement project. 77 × 77. See Chachko, supra note 23. In celebrating 2334, Islamic Jihad, an Iran-funded terror group in the Gaza Strip, discerned what many within the Obama Administration professed not to see: that while the resolution alone wouldn’t deter settlement construction, it would advance the Palestinian lawfare objective of “isolati[ng]” Israel through “prosecutions” and “boycotts.” 78 × 78. Hamas Welcomes . Vote on Israel Settlements , Times Isr . (Dec. 24, 2016), http:///hamas-welcomes-un-vote-on-israel-settlements/ [ https:///X5HJ-NWSH ].
If the Department decides to consider group benchmarking, you should also consider opening some of those meetings to organizations other than the Department and industry representatives. Unlike the traditional notice-and-comment process in federal agencies—where advance notice and opportunity for public comment on proposed rules are routine  —the Department does not make it a practice to provide the public with an opportunity for advance comment on its key enforcement policy statements and compliance guidance.  In this case, however, an additional infusion of transparency into your process could enhance the Department’s private sector credibility.
Every week, I receive letters from people across the country urging me to address issues involving state and local justice systems, about which there is often frustratingly little that anyone in the federal government can do. State and local officials are responsible for most policing issues, and they are in charge of the facilities that hold more than 90% of the prison population and the entire jail population. 45 × 45. Peter Wagner & Bernadette Rabuy, Mass Incarceration: The Whole Pie 2016 , P RISON P OL’Y (Mar. 14, 2016), https:///reports/ [ https:///N4WB-4T8C ].