6/1/20
On Mondays, Rogan’s List features a listing of proposed rule and regulation changes that are currently accepting public comment. Commenting is the way to show government agencies how we feel about these proposed changes. Our comments also become part of a record that will be reviewed by courts if and when a reg change is contested. Courts use comments to judge whether an agency is acting arbitrarily and capriciously.
Organization
Closing SoonRecent Section I – ICE, DHS, DOL, NLRBSection II – everything environmental – EPA, BLM, DOESection III – Civil rights, housing, education, healthcareOther: More on regulations (tracking the trackers/general information)
(Note: After a couple of weeks items are moved from “Recent” and “Closing soon” into the Roman numeral sections. A note on regulatory processes: there are three stages – Notice, Proposed Rule, and Rule. There’s usually a time lag of a few months to a few years between them, and they must be published in the Federal Register before appearing on Regulations.gov. Comment time varies from 10 days to 2 months, sometimes with extensions.)
This week’s list – I removed expired items. I want to highlight the EPA proposed guidance regulation that would govern all EPA guidance documents and petitions henceforth – this is huge. It’s no. 4 under recent – “Comments due 6/20/2020. EPA Proposed Rule. Guidance: Administrative Procedures for Issuance and Public Petitions. Major implications for how the EPA listens to, or doesn’t regard, public input on policy t0 include “cost-benefit analysis” of environmental regulation. https://www.regulations.gov/document?D=EPA-HQ-OA-2020-0128-0001Read more: EPA Proposes Rule To Formalize Guidance Document Process – calls it a “sea change”: https://www.jdsupra.com/legalnews/epa-proposes-rule-to-formalize-guidance-25183/and How a revised calculation could hurt future climate rules https://www.eenews.net/stories/1063128561and https://www.jdsupra.com/legalnews/epa-proposes-rule-to-improve-83492/
This week’s list: https://drive.google.com/file/d/13tAohSt8P21zjFvvfQhQUT_jmIedYt7v/view?usp=sharing
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