The Communication/Feedback System: Panel Discussion

December 1990
Citation:
20
ELR 10538
Issue
12
Author
Jon Greenberg, David Morell, and Jon Greenberg

JOHN A.S. McGLENNON: I have two or three suggestions that EPA should consider in order to develop a more formalized feedback system. One is to  incorporate an annual review process into some of our regulations. There would be no harm in convening an annual or biennial meeting of representatives of the regulated community to ask how well we are doing and how well the regulation is working.

Another suggestion concerns the regulatory negotiation process. We are required to form a committee under FACA, the Federal Advisory Committee Act. Members are appointed by EPA, and the charter is approved by OMB. Since we go through all of those steps, why not keep such a committee in operation? It would not need to operate continuously over the period of implementation of a rule, but perhaps cold be reconvened—as the committee that was responsible for writing the rule in the first place—perhaps annually for a three-year period to ensure that the rule gets off on the right foot.

John A.S. McGlennon, President, ERM-New England. David Morell, Ph.D., President, EPICS International. Jon Greenberg, Browning-Ferris Industries.

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