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October 13, 2013, JAPC New Rules Review Letter
Last Post 05 Dec 2013 12:41 PM by SuperUser Account. 0 Replies.
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05 Dec 2013 12:41 PM
    On October 13, 2013, JAPC sent the attached letters regarding their review of the "proposed amendments to rules 62-761.100 and .300, and to rules 62-772.100-.400, .401, .402 and .600 FAC. There appear to be a number of unacceptable, proposed petroleum cleanup program rule changes. The letters repeat phrases like "does not meet the definition of a rule" and "impermissibly vague" (my personal favorite), and "vests unbridled discretion in the department to...", and "arrogation of unbridled discretion to the department" which apparently means an "invalid exercise of delegated legislative authority".


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