Learning Checks – After EQC Action
Administrator/EMT Member
Title of Rulemaking: AQ Permit Program Streamlining and Updates
Administrator/EMT member: John Becker/Representing RDA's
Questions after EQC action
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1. Were you kept appropriately informed about key issues during the rulemaking process? Yes. Sarah did a nice job of keeping all reviewers included in the rulemaking process.
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2. Did your involvement in this rulemaking meet your expectations? Why, or why not? Yes. Although review time was tight, Sarah provided all rule information as timely as possible, and did review each and every comment that I made during the process prior to the next step.
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3. Could this rulemaking effort have been streamlined or made more efficient? For example, were there stages in this rulemaking process (drafting of the rules, work of the external advisory committee, the public comment process, etc.) that could have gone smoother? As a reviewer, I was actually comfortable with my role in the rulemaking process. Actual time allowed for review was somewhat short. Given the many requirements asked of the rule writer, however, I am not so sure that Sarah had it as easy as I did.
Any recommendations for streamlining any portion of the rulemaking process that might help with future rulemakings? Again, as a reviewer, I had no issues, other than time allowed for review was short, but deadlines often dictate such a short timeframe.
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4. Is the implementation of these rule changes being adequately addressed? The new rules contained in this rulemaking package were actually straightforward, so implementation should not be too difficult.
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5. Given the timeframe to complete this rulemaking, was the appropriate level of resources made available? As a reviewer, as well as an Air Quality Program manager, I did not feel that I was short on resources for my role in this review. I was well acquainted with the rule needs prior to rule drafting.
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6. Do you have any other recommendations, suggestions or comments? Yes. As a manager, I have heard that employees do not particularly enjoy participation in the rule writing process. If employees do have such concerns, hopefully we (as an Agency) are listening to those concerns, or at least making them feel comfortable so that they can share those concerns. This is not to imply that Sarah had issues with this specific rulemaking process, as I was not privy to any such comments from her. From what I could see, Sarah did a nice job of presenting information to me as the reviewer, and I am not aware of any specific rulemaking concerns that Sarah had with is rulemaking package.
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