Of the eight WAC chapters reviewed against the University of Washington's rule review criteria, all have proceeded from that review to rule-making activity. This fact alone points out the need for an ongoing mechanism to review agency rules, as all eight WAC chapters reviewed required some type of amendment or repeal - sometimes a minor adjustment, other times a complete overhaul. Consequently, as the University of Washington continues its rule review plan, the governor's goal of regulatory reform is being achieved at this agency.

During this past year, the University of Washington completed the expedited repeal of one entire WAC chapter and has begun the expedited adoption process for sections of two other WAC chapters. Without the ease of these relatively new rule-making procedures (expedited repeal and expedited adoption), the regulatory reform required by EO 97–02 would have been more difficult to achieve within the given timeframe (see Section 5 for more on this topic).

Finally, as stated in the University of Washington's rule review plan, the university will implement an ongoing process of rule review once the current plan is completed. This ongoing process will schedule Title 478 WAC rules for review whenever a WAC chapter has gone without rule-making activity during the previous ten years. Additionally, the University of Washington will continue to implement a complete review of any WAC chapter whenever any WAC section within that chapter requires rule-making activity. In this way, the University of Washington will continue to bring all interested parties (i.e., University of Washington faculty, staff, and students; pertinent community members and local governmental bodies; and the general public) to the table for WAC rule review discussions.

2. Total Number of Rule Sections Reviewed, Amended and Repealed, and the Number of Pages Eliminated in the WAC: Since the effective date of Executive Order 97–02, the University of Washington has:

• Reviewed a total of 174 WAC sections.

• Amended a total of 66 WAC sections.

• Repealed a total of 62 WAC sections.

• Not eliminated any pages of the WAC, since the University of Washington also adopted 65 new WAC sections during this same period.

3. Percent of Rule Sections Reviewed to Date: The University of Washington has reviewed 78% of the rule sections intended for review. The final 22% of the rule sections to be reviewed are scheduled during the next and final year of the University of Washington's rule review plan.

4. Other Regulatory Reform Factors:

a. The University of Washington continues its ongoing effort to identify, summarize, index, and make available its policy and interpretive statements.

b. During the past year, the University of Washington received no petitions for adoption, amendment, or repeal of rules under RCW 34.05.330.

c. University of Washington rules reviewed, created, amended, and repealed under chapter 34.05 RCW have not imposed reporting requirements on businesses.

5. A Summary of Recommendations Developed for Statutory or Administrative Changes Resulting from Regulatory Review: In order to further the goals of EO 97–02, wherein agencies are encouraged to create and utilize ongoing procedures to review their rules after the mandated rule review of EO 97–02 is complete, it will be critical to continue providing state agencies with access to the expedited adoption process. Unlike the expedited repeal process (per RCW 34.05.354), the current expedited adoption process (per RCW 34.05.356) is scheduled to expire on December 31, 2000.

The expedited adoption process, unlike full rule making, allows state agencies to quickly update necessary organizational information (such as departmental name changes; phone and fax numbers; e-mail, web and building address changes), reflect changes by reference to state and federal law, correct typographical errors, and clarify language without holding costly and time-consuming public hearings that lack substance. The public has a right to expect accurate agency rules, and these small yet critical housekeeping changes can make the difference between rules that function correctly and rules that slowly become outdated while awaiting a substantive change that warrants full rule making.

Therefore, in keeping with the goals of regulatory reform, the University of Washington recommends repealing the expiration date for RCW 34.05.356 (expedited adoption) and extending the use of this timely and frugal tool in maintaining accurate agency rules.

[Excerpt Applicable to this Agency From:]

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