Net-buoy,
Please come back to work on the FAPE and other IDEA articles.
I haven't looked at this article in a few months, or I would have responded to you sooner. I think you're right in many respects, though there may be other aspects of the statute and related case law to be considered. (I don't think I've deleted any of your text, but I could be mistaken.)
Part of the skew may be my attempt to be objective --- as the parent of 2 children supposedly being served under IDEA, I don't look at IDEA, the DOE, OSEP, or any state or local education agency through rose colored glasses. The laws and their implementation (or the lack thereof) has not served my children well, so I've worked hard to approach the subject objectively. I may have leaned too far in the opposite direction.
It would be great to have an attorney who practices law in this area to participate. Please come back!
Best,