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Large, permitted truck negotiated rulemaking:
public comments, and lots of 'em!

With our first round of comments completed, it was time to decide on the framework of this rulemaking. As you'll recall, this project began with no draft rules or suggested changes to rules. But, the first round of public comments was definitely a success, as more than 40 stakeholders submitted 300+ pages of documentation.

So, the action needed was for the Rulemaking TEAM to begin analyzing the submitted information, materials and comments. This is no easy task, and as with most things, starting is often the most difficult part. Now, my memory is a bit foggy as to how many meetings we held to work through these comments, but it was probably a half dozen, and these meetings exclusively discussed and categorized each comment and submission.

However, one meeting definitely stands out in my mind, and that was the one we held on June 4. This meeting was unique for a couple reasons. First, it happened to coincide with my one-year ITD hiring anniversary and to be honest it was actually a pretty surreal moment for myself. I couldn't believe that in only one year I already felt as though I had been completely welcomed into the ITD family and that my supervisors were already trusting me with such an important project.

Secondly, this was an all-day meeting on a Saturday! But, because we had such an awesome, close knit Rulemaking TEAM it was easy to agree working on the weekend. Additionally, those surreal moments in my head became very real when I looked around the room that Saturday morning and saw Tim Thomas, Lisa Hoag, Reymundo Rodriguez and Scott Stokes. I thought to myself, "WOW, I am really part of something special here, and to be sitting with such strong, exemplary ITD employees was truly a privilege." (Technically, Tim and Lisa work for the Idaho Attorney General's Office, but who keeps track, right – ¿Mr. Larry Allen?)

As we plowed through the pages and pages of documentation, we established that there would be 17 categories in which we could fit each and every comment, suggestion or concern. These affectionately became known as our concept papers. Now, another challenge we were working through was making sure that our entire rulemaking process was open and transparent. Specifically, we needed to ensure that the Idaho Transportation Board was a part of every step along the way. So, we couldn't ask the Board to simply advance proposed rules from nothing, there had to be some type of interim step. Therefore, on June 8, we held a Special Board Meeting and I was given the opportunity to present all of the work we had done developing those concept papers out of mountains of documents. In about an hour, I walked the Board through each concept paper. Of course, when called upon, I had subject matter experts such as Reymundo, supporting me the entire way.

Of the 17 rulemaking concepts presented, five were selected to advance to the negotiated rulemaking process. So, we now had direction and could actually start drafting rule changes/modifications. But yikes, the Board wanted to see those draft rules presented at the regularly scheduled monthly Board Meeting in just ONE week! And so, the fun continues…