| June 2004 RSL Newsletter |
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| Newsletter |
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Welcome to the second issue of our regular digest of news and information on the regulatory streamlining initiative. Please drop me a line if you have any questions or suggestions.
Patrick Allen, Manager
Office of Regulatory Streamlining
(503) 947-7061
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| Agency Focus |
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The Department of Environment Quality now has an online permit tracker for Water Quality permits issued by the department. This provides 24/7 access to a wide variety of information about the status of permits. The tracker is searchable by number, company or location. You can find the tracker at http://www.deq.state.or.us/permittracker/.
Take a moment to look at this site, where permit applicants can review the status of their permit. Once you click in to the site, enter facility number 9272, which is Weyerhaeuser, and then click on "Search." Once the Weyerhaeuser info appears, click on "View Permits." You'll see a list of their permits. Click on the last one, #988257 to see what actions have been taken and when.
Mitch West, Ranei Nomura and the Business Services Division and the Water Quality team at DEQ have done a great job with this.
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| Survey |
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Phase II of our business climate survey will be wrapped up at the end of this month. So far, over 600 Oregon businesses have rated our efforts to protect Oregonians in a way that supports a strong economy. Literally hundreds of comments have already been provided. Look for results of this second phase to be reported out in July. In the meantime, it's not too late for your business stakeholders to be involved. The survey will be available until June 30.
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| PING |
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Process Improvement Networking Group (PING)
Process improvement is a big part of how agencies make their rules faster, cheaper, and easier for regulated businesses. A number of agencies have in house capacity for this work, but these professionals didn´t have many opportunities to interact with each other, share suggestions, and discuss difficult challenges. At the same time, many small agencies and boards don´t have any in-house capacity at all.
To address these apparent gaps, we´ve organized a group of state agency employees with process improvement expertise to share information with each other, and to assist other agencies in improving their regulatory processes . The Process Improvement Networking Group meets monthly, usually over a lunch hour, for networking, problem solving and mutual learning. Over time, members may be asked to assist the regulatory streamlining efforts of agencies which do not have internal capacity for process improvement, and which have requested help in their efforts. These projects will be negotiated individually with the Office of Regulatory Streamlining, the agency requesting assistance, and the agency with staff resources. Compensation for loaned staff time may be required.
If you have an interest in participating in PING, or if you need process improvement help, contact Laura Lesher at (503) 947-7061.
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| Practice Tip |
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Admin Rule Fiscal Impact Statements
As you know, fiscal impact statements are an important part of the administrative rulemaking process. For about the past three months, we´ve begun reviewing impact statements for proposed rules that seem likely to have potentially significant business impacts. A few trends are emerging, and we´ve got some tips to pass on as a result:
- Statements of Need and Fiscal Impact are part of the public notice for every rule making. This means they need to be readily available in response to public inquiries. A number of agencies make this information (along with the draft rules themselves) available on their Web sites for ease of access.
- The point of doing a fiscal impact statement is for the agency decision-maker to consider costs and impacts before a rule is adopted. That means it´s better to do earlier in the process, not at the last minute before filing.
- Many agencies are giving very short shrift to the required elements of evaluating impacts on business generally, small business specifically, and the cost of compliance in particular for small business.
- ORS 183 only requires you to use "available" information, but that can include data from Web sites, inquiries to places like the Employment Department of Office of Economic Analysis, and inquiries to trade groups and other organizations (especially when trying to assess cost of compliance).
- ORS 183.540 gives agencies the authority to use a range of tools to reduce the impact of a rule on small business. These tools include alternative compliance or reporting requirements, consolidated or simplified compliance and reporting, use of objective criteria standards, and even waivers for small business.
We´ll continue to review rules, and make suggestions as appropriate. If, at any time, you would like to discuss a rulemaking, just give a call. Remember, we can´t provide legal advice, and your assigned Asst. Attorney General is always an appropriate source for advice in the rule making process.
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| Suggestion Box |
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Have you ever gotten a form at home, maybe from your bank or insurance company, that asks you to fill out lots of information you're sure they probably already have? Do you find yourself thinking: 'didn't those people keep what I sent the LAST time?!'
Now, have you ever wondered how customers might feel about license renewals at your own agency? Here's a suggestions: look at license renewals and consider whether systems can be changed to send out a form to licensees that is "pre-filled," contains an instruction that boxes don't need to be filled in if nothing has changed, or in some other way avoids asking for the same information year after year. Not only can you cut down on licensee frustration, you might find ways to do this that save work or cut down on data entry errors.
If you have suggestions, good ideas to share, or topics you'd like to see addressed, please let me know.
Pat.
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