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Idea#951

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Rulemaking »

Rebuttal Comment Periods

Why Is This Idea Important?: The advantage of electronic rulemaking is that it opens up the process. But to truly benefit the agency the parties should have an opportunity to exchange their views one with the other. I may be being too optimistic here but not all rulemaking controversies are black and white matters for the stakeholders. Interchange between parties can minimize the contested issues and also develop a more detailed record.

Electronic rulemaking should encourage dialogue between the stakeholders. This often does not occur because of standard gamesmanship. Parties file their comments on the last day of the comment period and no interaction can occur.

Submitted by bbrandon 2 years ago

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Comments (1)

  1. btozzi1 said:

    The Sixty Day Notice and Comment Period Allowed by the Administrative Procedure Act is Obsolete

    After the end of the public comment period up through the publication of a final rule, the government has a monopoly over the regulatory process. In essence the public, including the regulated community, is shut out of the process.

    The same problem occurs after a rule is promulgated and the agency goes into program implementation; in this instance the agency makes numerous decisions which could not have been envisioned at the time of the NPRM.

    In our wired society, the generation of information on a regulatory issue does not cease at the end of a public comment period. In essence, the sixty day notice and comment period in the Administrative Procedure Act is obsolete; notice and comment is now a 24/7 endeavor

    Read complete article http://www.thecre.com/Forum/?p=30

    2 years ago
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