Balancing Wetland Management with the Military: Using Special Area Management Plans (SAMPs) to protect wetlands on U.S. Air Force Installations

U.S. Air Force installations by virtue of their isolation and often remote locations provide protection to critical habitats that would otherwise be susceptible to development and other stressors. While Air Force activities may not always compliment environmental protection, a balance between environmental protection and Air Force requirements must be achieved to minimize conflict. Special Area Management Plans (SAMPs) are a possible solution in the quest to balance conservation with mission requirements. Beale Air Force Base, California is the first military installation to pursue implementation of a SAMP. This project found that SAMP implementation could be a tool to successfully balance conservation efforts with military requirements on other Air Force installations; however, further education on the SAMP process would be required.

Comment Letter on Rule 14a-8(I)(10), Securities & Exchange Commission, June 18, 2015

This letter focuses on SEC interpretations of Rule 14a-8(i)(10). The provision allows issuers to exclude shareholder proposals that have been “substantially implemented.” This has traditionally been used to allow for the exclusion of proposals rendered “moot” by the company’s actions. Companies, however, need not implement the shareholder proposal “exactly.” As a result, the staff is often asked to determine whether changes made by the company are substantial. The comment letter discusses positions taken by the staff where the company adopts a proposal asking that shareholders with a specified percentage of shares have the right to call a special meeting but limits eligible shares to those held for a specified period of time.