"Here's how the Central States application flunks every condition set by MPRA: First, the application fails to demonstrate that the Central States Pension Fund took all reasonable steps to avoid insolvency ... Second, the plan did not equitably distribute the benefit cuts.... Third, even with the steep and unjust proposed cuts, the ability of the Central States Pension Fund to survive for the long term is extremely uncertain -- a key factor that the law says must be considered before the Treasury Department can approve any application to cut retiree pension benefits.... Mr. Feinberg, please reject the application.... There are better solutions."  MORE >>