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Here response definately represents a subtle change in position. Why else, would she write a 1,000+ word response with the meet of the issue buried about 600 words deep into the letter. Such as:
"As you may or may not be aware, under current law, the Army Field Manual can be revised by the Executive Branch without prior consent from Congress. This is to allow for the possibility of incorporating other legal, humane and noncoercive interrogation techniques that might be discovered to be effective in the future. Just because the Army Field Manual is currently the best available standard for interrogation does not mean we can’t do better."
There is plenty of wiggle room here to alter it. It's a mini-head fake with implication being that we, can make the rule "even more moral and ethical.''
But as GG has documented on numerous occassions, the current crop of Congressional Democratic leadership no doubt will use this vagueness for the exact opposite purpose - to make the Army Field Manual "tougher" on those suspected terrorists.