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A
Now,
I
hope
that
your
your
bellies
are
full
of
candy
or
you're
trying
to
keep
it
away
from
your
children
as
best
you
can
so
we'll
start
by.
Let
me
get
my
thing
here,
we'll
start
by
with
Alex
thanks
or
welcome
to
the
second
committee
on
rule
making
regulatory
enforcement
on
regulatory
enforcement
manuals
we'll
start
with
Alexandra
sibo.
Who
will
who
will
call
the
two
roles?
The
first
rule
will
be
the
names
of
committee
members
and
alternative
committee
members.
B
Thank
you
so
much
I
appreciate
it
virtual
for
those
of
you
who
weren't
here
last
time.
My
name
is
Alexandra
sibo,
as
but
you're
all
said,
I've
been
very
pleased
to
be
staff
counsel
at
acus
for
this
project
and
we
will
go
ahead
and
get
started
with
our
first
roll
call
from
members
of
the
committee
on
rulemaking.
Thank
you
all
so
much
for
joining
us
today
and,
as
virtual
said,
please
unmute
when
you
hear
your
name
and
then
re-mute
yourself,
much
appreciated
and
of
course,
we'll
start
with
virtual.
Our
wonderful
committee,
chair,
I.
A
B
B
B
B
Great
thank
you
all.
We
will
move
on
to
our
second
roll
call,
acus
Members,
not
on
this
particular
committee
and
alternates
who
are
present
today.
Thank
you
all
for
joining
us
much
appreciated,
and
we
start
here
with
our
wonderful
akos
Williams
fellow
our
project
consultant
Jordan
Perkins
here.
Thank
you.
Jordan
next
up,
James
giara
puto
alternate
for
OSHA.
C
B
N
B
A
Thank
you.
I
get
this
right
somehow
so
I'll
start
by
explaining
the
standard
meeting
protocols.
So
please
note
that
only
acus
members,
including
government
members,
public
members,
senior
fellows
liaison
representatives
and
special
counsels,
whether
or
not
on
the
committee
and
their
designated
alternates,
have
full
speaking
privileges.
To
avoid
background
noise,
though,
I'd
ask
that
you
keep
your
microphone
on
mute
and
either
use
zooms
hand,
raise
features
or
add
a
comment
on
the
chat
feature.
If
you'd
like
to
speak,
I'll
then
call
on
you
and
you
can
unmute
yourself.
A
A
Particip
participation
requires
a
unanimous
consent
of
the
committee
members
time
permitting
I'll
consider
calling
on
such
attendees
at
appropriate
points
and
we'll
presume
that
committee
members
consent
absent
their
raising
an
objection.
If
any
such
participant
would
like
to
speak,
please
so
indicate
in
the
chat
feature
or
by
using
zoom's
hand,
raise
features
and
wait
to
speak
until
I
call
on
you.
You
can
then
unmute
yourself
and
please
remute
yourself
when
you
are
done
speaking
for
all
participants.
A
Please
use
the
chat
feature
only
to
indicate
that
you
like
to
speak
or
for
committee
members
in
their
alternates
to
vote
when
asked.
Please
do
not
hold
any
sidebar
discussions
or
put
substantive
comments
in
the
chat
feature.
Only
members
of
the
rulemaking
committee,
including
government
members
and
their
designated
alternates
public
members,
senior,
fellows
liaison
representatives
and
special
counsels,
have
a
vote.
Please
do
not
vote
unless
you're
a
member
of
the
committee.
We
have
a
list
of
committee
members
in
case
you're
unsure.
A
A
A
Please
let
me
know
if
you
need
me
to
slow
down
as
we
work
through
them
and
and
feel
free
to
go
back
to
previous
recommendations.
If
a
thought
or
idea
comes
to
mind
that
that
is
that
that
we
should
consider
okay,
so
after
working
through
the
recommendations
and
and
and
seeking
out
feedback,
I
will
turn
to
our
project
consultant
Jordan
Perkins
to
to
get
his
views
on
on
various
matters
and
thoughts
that
are
presented
and
as
part
of
our
revision
process.
A
Okay,
so
the
first
recommendation
has
to
do
with
developing
enforcement
manuals
recommendation
number
one
I,
don't
believe
there
has
been
have
been
any
edits
to
the
to
the
actual
recommendation
itself.
But
let's
go
through
it
again
to
see
if
there
are
any
thoughts
or
feedback
on
on
recommendation
number.
One
I'll
give
you
a
moment
to
read
through
it
and
then
ask
if
there
are
any
comments,
feedback
or
suggested
changes.
A
G
B
A
A
M
M
M
P
J
I
think
that
the
background
of
the
changes
in
this
subsection
sub
paragraph
in
part
we're
in
response
to
comments
I
made
at
our
last
meeting
concerning
the
extent
to
which
the
Manual's
content
may
be
relied
upon.
I'm
thinking
of
the
general
public,
and
you
may
recall
that
I
based
my
comment
on
experience.
I
had
when
I
was
on
detail
in
a
regulatory
agency's
ombudsman's
office.
J
We
had
received
complaints
from
the
public
that
there
was
would
appear
to
be
guidance
on
the
webs
and
the
agency's
website
that
when
people
relied
on
it
during
that
not
to
be
reliable
so
that
that
was
the
point
I
made
then
and
suggested
there'd
be
some
language
to
deal
with
that
situation
and
I
what
it.
What
the
the
draft
Now
does
not
address
that
directly,
but
I
suspect.
That's
part
of
why
the
language
that
you
see
was
placed
in
there.
A
So
maybe
there
could
be
clarifying
language.
Maybe
the
language
of
the
manual
does
not
necessarily
reflect
the
views
of
other
agency
officials
is
not
the
best
language
with
with
the
language
does
not
bind
the
agency
as
a
whole.
Is
that
responsive
to
your
comment
David
from
the
earlier
meeting?
Or
do
you
think
that
there
needs
to
be
other
language,
reflect
better,
reflecting
your
thoughts.
J
A
A
C
And
first
thanks
Bill
for
raising
this
when
we
last
met
I
I
struggled
with
as
an
agency
official,
the
meaning
of
this,
and
just
the
explanation
of
the
problem
being
resolved.
I
think
this
edit
helps.
My
assumption
is,
after
it
says,
does
not
necessarily
automatically
bind
the
agency.
We
would
get
rid
of
reflective
views
of
other
agency
officials.
I
just
have
a
hard
time.
Thinking
that
an
agency,
let's
say
OSHA
for
deal
hour,
the
Mind
safety
and
health
administration
would
put
out
an
enforcement
manual,
and
you
would
have
people
within
that
agency
saying.
C
Well,
no,
we
don't
necessarily
follow
it.
You
know
it
could
be,
there's
an
issue
where
it's
outdated
guidance
or
things
like
that.
But
I
would
have
a
hard
time
thinking
that
you
would
have
something
out
there,
where
agents
officials
would
hopefully
say
I,
don't
necessarily
agree
with
that.
Maybe
there
would
be
Rogue
or
uninformed
officials,
so
I
think
it's
hard
to
see
of
a
situation
where
Emmanuel's
put
out
out.
You
know
people
saying
oh,
no,
it
doesn't
reflect
the
views
of
that.
C
The
agency
that
put
it
out
so
I
think
this
edit
makes
me
feel
a
little
better
and
again
the
comment.
The
explanation
is
why
this
was
first
raised.
You
know
I
just
recall
the
last
Administration
we
went
through
so
much
energy
on
posting
guidance.
It
was
no
longer
an
effect
but
indicating
it
was
no
longer
effect.
I
don't
know
if
that
goes
to
the
concern
that
there
may
have
been
enforcement
manuals.
C
A
Q
Yeah,
so
for
clarification,
the
language
preceding
the
does
not
bind
the
agency
as
a
whole
was
in
the
last
draft
that
the
committee
considered
it
was
previously
an
a.
It
was
only
moved
to
b
c
for
clarification,
so
David
it
was
not
added
in
response
to
your
language.
This
was
intended
to
account
for
situations
in
which
enforcement
bureaus
within
agencies
develop
enforcement
manuals
and
they
do
not
carry
the
impromatter
of
agency
heads
so
I,
don't
know
if
Jordan
has
additional
thoughts
on
that,
but
that
is
the
situation.
J
I
I
all
right,
I
I'd,
like
the
the
previous
suggestion
to
include
my
words,
necessarily
automatically
and
delete
the
phrase
about
not
reflecting
the
views
of
other
officials.
I
think
that
that
goes
a
long
way
to
solving
the
problem
and
as
for
the
comment
about
things
being
out
of
date
and
unreliable
in
that
sense,
in
the
prior
Administration
or
at
any
time,
I
think
there
are
other
sections
in
the
current
draft
that
address
that.
A
Q
It
okay,
as
for
the
word
necessarily
or
automatically
I,
would
say
the
the
words
does
not
bind
the
agency
as
a
whole.
That
was
added
in
response
to
Nina
Mendelson's
comment,
the
previous
meeting
that
we
should
pull
in
language
from
recommendation
2017.5,
which
states,
although
a
policy
statement,
should
not
bind
an
agency
hold
without
qualification,
so
that
is
for
consistency.
Sake,
I
raised
that
for
the
committee's
consideration,.
A
Okay,
so
there's
kind
of
two
points:
I
hear
you
raising
Jeremy
the
first
one
with
respect
to
the
language,
reflective
views
of
other
agency
officials
is
responsive
to
the
context
in
which
the
political
appointee
may
not
share
the
views
of
the
regulatory
enforcement
manual
that
is
perhaps
made
by
a
prior
Administration
or
by
the
civil
servants
in
the
agency.
Unless.
Q
A
M
M
All
right
I
mean
that
would
just
be
here's
your
enforcement
manual,
but
it
may
not
reflect
the
views
of
the
head
of
the
agency.
I
mean
no,
you
it's.
If
the
head
of
the
agency
wants
to
change
it
get
to
change
it.
If
he
doesn't
care
about
it,
then
it's
the
agency,
adopting
it
I
mean
I.
Just
under
a
delegation,
I
just
think
saying:
hey,
we
got
lots
of
people
running
around
out
here.
This
doesn't
necessarily
reflect
the
views
of
of
the
agency.
M
M
If
it
binds
the
agency
as
a
whole,
then
maybe
it
has
to
be
a
notice
of
comment,
legislative
Rule,
and
we
don't
want
that
to
want
to
be
able
to
make
clear
that
it
doesn't
bind
the
agency
as
a
whole,
even
if
it
binds
individual
employees
within
the
agency
to
be
responsive
to
David.
Pritzker
I
think
you
could
add
at
the
end
after
the
whole,
and
that
members
of
the
public
should
not
necessarily
rely
upon
what
is
contained
in
the
manual.
M
A
Okay,
so
we
have
that
change.
Put
forth.
I
also
want
to
return
to
Jeremy's
point
that,
insofar
as
we
were
adding
necessarily
or
automatically
we're
deviating
from
the
language
in
a
prior
Acres
manual,
2017-5
that
Nina
pointed
out
as
as
something
we
should
look
to
for
consistency
purposes.
So
I
don't
know
if
that
changes
our
views,
whether
we
want
to
include
it
or
not,
but
I
just
wanted
to
kind
of
repeat
that
point
that
Jeremy
made
Kevin.
L
Yeah
thanks
for
Phil
two
thoughts,
one's
just
a
little
small
word.
Spiffy
thing,
which
is:
should
we
strike
do
I,
don't
know
if
we
need
general
public
in
the
language,
just
just
added
that
is
connect,
the
public
should
I,
don't
know
what's
going
on
with,
should
not
generally
rely
on
I
I.
Think
about
that
one.
Let
me
go
I'm
I.
Think
I'm
opposed
to
the
idea
of
deviating
from
the
prior
recommendation
on
this
question
of
necessarily
automatically
I.
L
Think
this
kind
of
puts
the
agency
in
the
position
of
the
default
almost
seems
to
be
that
it
would
bind
the
agency
as
a
whole.
Maybe
that's
what
we
think.
I
don't
know,
but
now
it's
just
it
doesn't
necessarily.
It
almost
seems
like
the
implication
is
that
it
would,
unless
the
agency
said
it
didn't,
and
maybe
that's
the
right
presumption,
I
don't
know,
but
I
I
haven't
gone
back
and
read
the
other
recommendation,
but
I
wonder
and
the
manual
does
not
should
not
Bond
the
agency
as
a
whole.
L
L
The
agency
have
to
say
in
its
guidance
or
in
its
manual
every
time
I
mean
maybe
they
should
I,
don't
know
I'm.
Just
raising
that
question
there
and
I
guess
on
the
second
now
back
to
the
second
generally
and
the
agency
as
a
whole,
and
that
the
public
should
not
I,
don't
know
what
we
mean
by
should
not
generally
rely
upon
the
manual
or
I'm,
not.
I
J
J
A
A
A
A
M
K
G
A
P
So
this
is
related,
I
think
I
think
as
a
general
rule
for
the
20
or
so
manuals
I
looked
at.
They
almost
never
climbed
the
agency,
and
part
of
that
is
from
foia
that
they
need
to
be
promulgated
through
notice
and
comment
or
something
like
that
if
they
are
binding
generally,
these
reflect
the
views
of
the
as
Jeremy
said,
either
the
General's
council's
office
or
the
centralized
division
of
enforcement
for
the
purpose
of
controlling
the
discretion
of
line
official
of
lying
enforcement
staff.
P
Usually
the
agencies
that
make
these
publicly
available
make
them
available
as
sort
of
a
service
to
the
public
where
they
can
see
the
the
agent's
internal
decision-making
process.
But
it's
not
really
meant
to
be
a
clear
statement
to
the
public
of
what
the
agency
thinks.
The
public
needs
to
know
about
the
rule,
so
I'm
not
sure
that
the
language
necessarily
is
for
most
enforcement
manuals.
P
A
J
If
I
may
interrupt
again,
maybe
and
I
hope
for
the
last
time
on
this
section,
I
I
am
completely
persuaded
by
by
what's
just
been
said,
because
on
re-reading
the
beginning
of
this
describing
the
purpose,
scope,
organization
and
legal
effect
of
what
follows.
Yeah
I
think
I.
Think
that
that
if
the
agency
does
that,
then
we
don't
need
my
modifiers
okay.
F
A
M
Does
that
really
solve
the
problem,
because
I
mean
when
I
originally
read
this
thing,
I
had
the
same
thought
that
Michael
did
and
I
thought,
but
no
no,
of
course,
you're
not
going
to
identify.
You
can't
possibly
read
it
that
way,
and
so
I
said
well,
you
could
you
can
just
leave
it
the
way.
It
is
because
you
couldn't
possibly
tend
to
mean
identify
the
individuals
and
and.
R
M
F
A
E
I
I
kind
of
agree
with
Bill's
I
think
original
comment
that
giving
it
as
employees
people
will
figure
it
out
and
I.
Think
with
this,
and
even
our
discussions
early
on
see
did
the
lead
into
this
whole
paragraph
I
think
it's
a
lead-in
from
whatever
it
is
to
you
know.
It
says
this
is
I,
think
it
sounds
like.
Is
it
like
weather?
It
has
it
to
say
it
felt
before
it
should
consider
these
are
the
things
to
consider
I
think
we
don't
need
to
nail
it
down
so
tightly
having
it
say.
E
You
know
the
agent
employees,
I
think
is
fine,
I
think
saying
positions
a
little
bit
strange
because
it
might
apply
to
an
office,
but
that
office
might
have
10
different
positions
in
it.
So
I
think
positions
almost
makes
it
more
potentially
confusing,
but
I
honestly
think
with
the
lead
in.
We
just
don't
need
to.
E
F
A
A
K
G
G
A
F
I
think
there
it's
actually
appropriate
to
the
to
for
it
to
be
the
person
again.
It's
all
of
this
is
optional
because
of
the
heading
and
optional
because
of
the
or
office
here
right,
when
you're
being
told
to
get
in
touch
with
the
agency.
Often
agencies
say
here's
the
person
to
get
in
touch
with,
and
that's
a
useful
thing
for
agencies
to
do
and
not
mandatory.
Under
this
proposal,.
A
M
I
don't
understand
why
it's
here,
whistle
more
protections
are
certainly
a
lot
broader
than
enforcement
actions.
In
fact,
I'm
not
even
sure
that
they
come
up
most
often
with
respect
to
enforcement
actions.
It
doesn't
nothing
in
them,
ties
it
to
enforcement
actions.
All
the
other
recommendations
are
tied
to
enforcement
actions.
I
just
don't
understand
why
it's
here
at
all.
Okay,.
A
P
Right,
as
you
said,
this
was
an
addition
based
on
some
trying
to
remove
language
from
one
of
the
other
letters.
I
can't
remember
exactly
what
was
going
on
there,
but
there
are
situations
in
which
agency
enforcement
manuals
describe
whistleblower
Provisions
as
part
of,
for
example,
the
complaint
process,
so
the
nuclear
regulatory
commissions
enforcement
manual,
for
example.
P
If
you
have
some
kind
of
complaint
against
a
nuclear
facility
at
which
you
work,
then
it's
in
the
enforcement
manual,
how
you
would
bring
that
or
sort
of
how
the
enforcement
staff
would
input
those
in
sort
of
incorporate
them
into
an
ongoing
investigation
or
use
them,
as
the
basis
of
you
know,
opening
an
investigation.
So
it's
something
that
does
come
up
in
enforcement
manuals,
but
whether
this
is
you
know,
part
of
the
recommendation
on
is
obviously
not
my
expertise.
Okay,.
C
Thanks
since
I
was
the
one
who
suggested
it
and
I
recall
when
our
last
meeting
there
was
conversations
about
this
general
area
and
I
think
the
my
recognition
came
from
that
I
think
Jordan's
right,
I,
I,
don't
think
this
is
something
that's
critical
we
have
in
there,
but
I
think
sometimes,
enforcement
actions
do
touch
on
whistleblower
protections
and
knowing
there
are
other
avenues
available
to
folks.
So
in
you
know,
in
the
sense
of
good
government,
I
think
it's
always
a
good
idea
to
include
this
language.
C
M
I
wanted
to
respond.
I
would
follow
up
with
Jordan
because,
as
he
described,
it
was
people
working
in
the
nuclear
plant
who
would
be
making
some
statement
to
NRC
agency
personnel
and
and
our
whistle
does
whistleblower
law
apply
to
that
I
mean
I
I,
don't
think
it
does.
I
mean
whistleblower
protections
are
for
agency
employees,
not
for
private
employees.
M
Who
would
you
know
right
on
their
their
employers,
so
I
I
mean
I,
mean
I
now,
I'm
really
confused,
because
this
seems
to
talk
about
whistleblower
protections
for
agency
Personnel
rather
than
for
people
outside
the
agency
would
would
be
making
complaints
to
the
agency
Personnel,
so
I'm
I'm,
even
stronger
against
it
than
I,
was
before,
and
I
I
understand,
Peter's
Point
coming
from
social
Council,
but
you
know
you
know
it's
again.
It
just
I.
P
Yeah
I
think
Bill
is
right
in
that
this
wouldn't
be
part
of
sort
of
a
general
whistle
protections.
This
I
may
be
getting
over
my
skis
here,
but
I
my
Recollections.
This
would
be
something
that
would
be
part
of
the
enabling
act
or
the
statute
of
the
agency
itself
is
responsible
for
governing
a
specific
whistleblower
provision.
You
know
for
employees
and
nuclear
plants
as
opposed
to
the
general
whistleblower
protections.
C
Hearing
the
conversation
since
I
was
on
recommended
I'm
fine,
taking
up
because
I
struggle
with
it
and
I've
also
seen
situations
where,
even
with
an
agency,
an
investigator
may
make
the
recommendation
there's
an
enforcement
action
that
should
be
done
and
it
doesn't
go
forward
and
they're
like
where
do
I
take
these
here.
In
this
conversation,
I
think
the
language
raises
more
confusion
than
any
benefit.
It
has
so
I'm
fine
taking
it
out.
Okay,.
G
A
F
I
think
I
would
just
delete
such
as
by
providing
a
table
of
contents
in
an
index
it
in
a
way
it's
sort
of
undermining.
In
other
words,
the
the
recommendation
seemed
a
lot
more
ambitious
until
it
turned
out
that
the
kind
of
thing
we're
talking
about
is
a
table
of
contents
in
an
index
which
almost
goes
without
saying,
and
it's
in
you
know,
and
so
so
it's
actually
sort
of
more
more
forceful
in
a
way
slightly
clearer.
Without
that,
okay.
P
P
It
has
an
index,
it's
very
easy
to
find
what
you
need
in
the
enforcement
manual
as
compared
to
going
to
the
agency's
website
and
going
through
a
list
of
you
know
a
thousand
guidance
documents
that
have
been
promulgated
over
the
past
10
years
and
trying
to
find
the
one
that's
responsive
to
what
you
need
so
I
think
what
I
tried
to
flag
is
this.
This
is
one
of
the
key
features,
an
enforcement
manual
that
makes
it
more
useful
than
other
forms
of
guidance
documents.
If
you
don't
know
exactly
what
you're
looking
for,
but.
F
A
M
M
I
I
still
think
that
there
may
be
agencies
where
you
know
it's
easier,
cheaper,
not
to
have
a
a
searchable
electronic
format
and
an
internal
Network
and
have
something
that's
more
old-fashioned.
I
mean
I,
have
no
right,
no
problems
and
sorry
suggesting
that
searchable
electronic
format
is
preferable
right
but
to
say
it's
sort
of
absolutely
necessary.
It
just
seems
to
me
maybe
to
go
too
far
and
I.
You
know,
I
I
was
Jordan
sort
of
can
just
if
not
be
others
last
time,
and
so
I
like
to
hear
from
him.
P
Yes,
I,
don't
have
any
dispositive
thoughts
on
the
matter.
I
think
the
advantage
of
it
being
electronically
available
is
that
that
can
be
kept
up
to
date
more
more
readily
than
you
know,
reprinting
a
200
Page
book
for
every
member
of
the
enforcement
staff
on
a
periodic
basis,
so
I
do
think
it's
preferable,
but
you
know
I,
don't
have
any
expertise
on
exactly
the
issue
of
the
building.
A
G
N
Yeah
I
think
just
going
with
was
just
said:
I
just
wanted
to
add
that
in
my
experience,
Version
Control
is
easier
to
manage
electronically
and
it
can
be
very
difficult
to
to
get
those
old
manuals
out
of
the
hands
of
people
when
they've
been
updated,
and
so
you
know,
I
think
it
might
be
wise
to
encourage
electronic
dissemination.
For
that
reason,
yeah
I
just
wanted
to
add
that.
G
G
I
A
A
A
P
A
K
P
Q
I
A
G
M
You
know
why
not
make
10
sort
of
a
sub
or
part
of
seven
so
make
it
clear
that
you
know,
because
eight
and
nine
could
follow
what's
10
now
10
doesn't
have
to
be
after
that,
so
I
I
think
get
across
this
idea
better.
If
you
could
just
sort
of
either
move
10
up
and
make
it
the
new
eight
or
put
it
as
part
of
seven.
G
A
M
A
A
J
A
J
F
F
F
It's
a
little
unclear
to
have
a
and
b
as
sort
of
subsections
of.
What's
now
seven
I
think.
What's
now
seven,
and
what's
now
seven
a
and
what's
now
7B
are
three.
You
know
stand-alone
propositions
right.
One
is
not
a
subset
that
you
know
the
a
current
A
and
B
are
not
really
subsets
of
seven
right,
though.
J
Well,
I
agree
that
they're
not
subsets,
but
the
what
I
had
in
mind
when
I
suggested
putting
these
together
is
that,
to
some
extent
what
used
to
be
10
was
brought
up
in
the
conversation
as
modifying
or
limiting
seven.
So
to
the
extent
that
the
that
there
is
some
modification
or
commentary
on
seven,
that
was
what
I
was
thinking
of
when
I
suggested,
putting
them
together
in
some
form
right.
F
I
totally
see
that,
but
then
maybe
the
thing
to
do
is
rather
than
making
old
ten
eight,
in
other
words,
going
back
to
the
question
that
virtual
asked
of
Bill.
Should
this
be
part
of
seven
or
should
should
old,
ten
be
part
of
seven,
or
should
it
be
eight?
Maybe
it
really
should
be
part
of
seven.
For
that
reason,
okay,
and
because
those
really
are
connected,
what's
going
to
go
up
right,
what
are
the
portions?
F
A
And
then,
and
then
old
seven
would
still
be
seven.
It
would
just
be
yeah
yeah
and
that's
kind
of
hard
to
work
with
on
track
changes
moving
things
up,
but
seven
old
seven
would
still
stay
seven
and
it
would
just
be
what
is
now
seven.
There
would
just
be
after
remain
up
to
date,
just
adding
that
sentence
to
the
end
of
seven
yeah.
A
D
I
wonder
if,
if,
as
there
are
cousin,
seven
to
post
versions
on
websites
that
aren't
in
eight
to
avoid
making
eight
seem
like
agencies
should
always
be
posting
versions
on
the
website.
You
can
say
something
like
when
an
agency
posts
a
publicly
available
version
or
when
an
agency
posts
publicly
available
versions
of
enforcement
manuals.
Sure
and
then
also
in
that
section.
D
I
think
I
understand
this
to
mean
that
the
agency
should
be
describing
like
what
the
manual
is
in
a
clear
and
logical
fashion,
but
because
there
is
I
think
in
section
three
earlier
a
recommendation
that
the
manuals
themselves
be
clear
and
logically
presented.
I
wondered,
if
maybe
the
word
present
could
be
if
I'm
understanding
what
this
is
supposed
to
mean,
then
the
word
present
could
be
swapped
with
describe
Maybe.
A
G
C
Thanks
I,
like
this
edit
I,
think
originally,
my
focus
was
Less
on
describing
it,
but
also
presenting
them
for
folks
who
may
not
have
access
or
normally
use
the
web.
Things
like
that
that
they're
easily
find
that
can
be
found
observed,
searched
in
an
easy
manner,
but
I'm
fine
with
the
descriptions
but
I
just
want
to
get
some
context.
I
was
thinking
more
in
terms
of
actually
yeah.
Where
is
it
on
the
web
page?
How
is
it
made
available?
D
Well,
I
just
want
to
make
sure
I
understand
was.
It
was
the
suggestion
also
as
long
as
the
suggestion
was
not
also
suggesting
like
they
should
be
available
in
paper
form,
and
you
know
document
library
or
something
like
that.
Then
then
I
think
I
think
it's
capturing
both
what
I
was
wondering
about
and
the
intent
okay.
I
A
M
Well,
I
want
to
argue
strongly
in
favor
of
present
rather
than
describe
okay,
because
I
I
thought.
That
was
the
idea
that
you're
posting
them
in
an
easily
identifiable
location
and
they
should
be
presented.
That
is
the
publicly
available
versions
of
the
enforcement
panels,
should
present
them
in
a
clear
and
logical
fashion.
So
people
can
can
access
them.
Well,
they
shouldn't
describe
the
manual
I
mean
that
you
don't
want
to
describe
the
man
you
want
them.
M
A
A
J
D
D
That's
what
easily
identifiable
location
means
like
he
needs
to
be
easy
to
get
to
and
then
I
just
don't
quite
know
what
present
means
and
I.
Don't
have
any.
You
know
dog
in
the
fight
about
like
what
what
it
should
mean
I
just
as
a
reader.
It
was
not
clear
to
me
what
you
were
asking
the
agencies
to
do
so,
if
it's
not
naming
the
document
or
describing
the
document,
it's
something
else.
That's
fine,
but.
A
That's
that's
a
good
point,
so
yeah,
that's
a
question
of
what
percent
is
doing
in
addition,
or
is
it
redundant
to
posting
them
in
an
easily
identifiable
location
and
if
it's
redundant
then
does
adding
describe
as
a
next
sentence.
Add
some
meaning
that's
helpful
to
this
particular
recommendation.
Emily.
M
Let's,
let's
take
the
Post
in
an
easily
identifiable
location
and
put
that
after
present
them
in
a
clear
and
logical
fashion
and
post
them
in
an
easily
identifiable
location.
Okay,
that
makes
it
clear
that
there's
these
two
separate
ideas
that
this
a
place
that's
easily
found
and
that
what's
presented
is
presented.
A
A
K
K
A
G
A
P
One
is
just
you
go
to
the
page
that
says
enforcement
manual
and
you
get
a
PDF
of
the
manual
and
I
think
the
better
practice
that
I've
seen
in
my
research
is
that
when
you
go
to
the
page
on
the
way
to
see
website
it's
this
enforcement
manual,
you
don't
go
straight
to
the
manual
there's
an
intermediate
step,
and
that's
a
separate
page
that
says
this
is
the
agency's
enforcement
manual
it's
promulgated
on
such
and
such
date.
It
is
the
product
of
the
division
of
enforcement.
P
It
is
not
necessarily
buying
the
agency
or
interested
parties.
There's
sort
of
a
presentation
of
what
the
manual
is,
what
it's
used
for,
that
is
helpful
to
sort
of
the
outside
party.
So
if
the
present
has
some
kind
of
reference
separate
to
you
know,
what's
in
paragraph
three
I
think
that
would
be
what
we're
referring
to.
So
maybe
that
needs
to
be
in
the
recommendation.
Maybe
it
doesn't,
but
as
a
matter
of
best
practices,
I
think
there
are
different
ways.
You
can
present
the
manual
on
the
website.
K
K
P
K
But
but
just
if
you're
saying
present,
then
you're
presenting
the
manual
you're
not
presenting
a
description
of
the
manual
which
is
I,
think
what
you
were
talking
about
season
that
you're
either
going
to
describe
the
manual,
which
is
that
interim
step
or
you're
just
going
to
present
them
if
it
was
just
represent
the
manual
we've
already
addressed
it
in
three.
If
you're
going
to
describe
it,
we
need
to
go
back
to
where
we
were
originally.
A
A
K
Mean
I'm
indifferent.
It's
just
that
I
I
think
it
looks
to
me.
What
we
have
there
now
is
all
we're
talking
about
is
disseminating
okay,
we're
just
posting
a
clear
and
logical
version.
If
we
want
to
say
that
there's
two
things
you're
going
to
post
the
version
but
you're
also
going
to
post
a
description,
that's
the
interim
step,
then
it
has
to
go
back
to
post
a
description
or
describe,
or
you
have
to
describe.
You
have
to
explain
that.
There's
an
interim
step
here
and
I,
don't
think
either
of
the
versions
that.
A
M
I
agree
that
Jordan's
explanation
for
this
would
make
makes
the
present
sound
a
little
strange.
Although
I
didn't
think
that
this
was
just
redundant
of
three.
Because
three
is
what
is
the
manual
that
the
agency
uses
internally
and
what
was
talking
about
here
is
whatever
is
publicly
released,
which
might
be
substantially
different
actually
from
what
the
agency
itself
has
depending
upon
what
they
include
in
and
what
they
include
out.
M
I
mean
in
terms
of
the
capture
Jordan's
point
of
some
sort
of
introduction
to
the
to
the
manual
the
ideas
rather
than
present
or
describe.
But
you
know,
with
the
introduction
to
the
manual,
be
some
sort
of
language
ideas,
but
I'm
I'm,
I,
I,
sort
of
I
sort
of
take
the
point
that
that
neither
present
or
describe
captures
Jordan's
point.
F
F
F
You
know
that
that
they
should
post
the
manual
in
a
clear,
accessible
and
user-friendly
format,
something
like
that
which
sort
of
steers
us
away
from
half
the
conversation
we've
been
been
having
and
and
I
do
sort
of
agree
with
lawn
that,
in
terms
of
like
what
are
the
contents
of
the
manual
and
is
the
manual
self-clear
and
logical
yeah,
that
was
covered
back
in
three,
and
we
avoid
the
duplication.
By
focusing
in
this
paragraph
about
how
the
public-facing
version
is
presented
to
the
public
and
made
accessible
to
the
public.
So.
F
A
H
So
I
I
think
we're
headed
in
the
right
direction
and
I
think
we're
right
to
junk
both
present
and
describe
I
mean
I.
Think
we
should
figure
out
how
to
explain
what
we're
getting
at
by
maybe
revisiting
the
reason.
That's
provided
at
the
end
of
the
sentence
just
to
ensure
potentially
interested
persons,
including
members
of
historically
underserved
communities,
can
easily
find
and
use
it.
And
it's
about
you
need
more
than
just
a
description
of
what
the
document
is.
You
need
to
be
able
to
find
it.
H
It
needs
to
be
a
a
document,
that's
in
a
usable
format,
and
you
need
to
have
sufficient
context
provided
so
that
you
know
what
it
is
and
how
it
used
and
and
how
to
use
it
and
I.
Think
it's
that
contextualization
that
maybe
we
were
trying
to
get
at
with
the
word
present
and
described,
doesn't
quite
get
it
and
present
isn't
clear.
H
I
I
also
would
suggest
that
we
kind
of
try
to
vomit
out
all
the
things
that
should
be
included
and
then
maybe
have
the
the
committee
on
style
figure
out
a
way
to
say
it
more
concisely,
because
this
thing
keeps
getting
longer
in
a
way
that
I
think
is
probably
making
it
less
clear
and
I
suspect
that,
once
we
figure
out
exactly
the
concepts
that
we
want
to
include,
we
can
probably
find,
with
a
bit
of
wordsmithing,
that's
difficult
to
do
in
this
context.
A
more
straightforward
and
concise
way
to
communicate.
It.
A
H
Yeah,
so
all
of
the
speak
to
me
about
the
document
I
mean
I
think
it
should
be.
You
know
readily
findable
in
an
accessible
in
a
usable
format,
and
you
know-
and
this
is
where
I
struggle
is-
you
know
you
know
adequately.
You
know
introduced
in
a
way
that
provides
adequate
contextualization
but
I.
That's
that's
a
terrible
phrasing.
Don't
use
that
and
and
I
think
when,
when
we
find
the
right
word,
then
the
meaning
of
it
will
be
illuminated
by
the
language
at
the
end.
That
explains
the
purpose
of
these
requirements.
Okay,.
K
K
R
K
Disseminate
something
different
from
that
that
explains
what
the
agency
is
using.
Are
we
simply
saying
look?
It
ought
to
be
usable
searchable
by
by
your
employees,
and
you
ought
to
disseminate
that
to
the
public
with
that
same
usable,
searchable
document,
so
I
can't
tell
they
have
one
we're
trying
to
get
the
idea
of
one
usable
searchable
document
or
two
documents
here
and
I'm,
not
sure
we're
having.
A
K
P
So
I
think
my
point
was
not
that
we're
talking
about
a
completely
separate
document,
but
we're
talking
I'm
still
talking
about
the
way
the
manual
is
presented
on
the
website
to
members
of
to
outside
entities.
So
I
think
it
was
Emily
who
brought
up
the
idea
that
you
may
have
Council
who
are
representing
entities
before
the
agency
who
have
no
idea
what
an
enforcement
manual
is
or
sort
of
general
counsel,
and
they
don't
know,
is
this
the
document
that
I
need
in
order
to
look
up.
P
You
know
what
Discovery
privileges
the
agency
respects,
or
is
there
something
else?
Is
there
another
guidance
document
so
I'm
not
to
the
extent
I'm
talking
about
sort
of
a
separate
point
of
the
website?
It's
just
the
overall
presentation
of
how
does
the?
How
is
the
enforcement
manual
presented,
so
that's
useful,
those
two
sort
of
non-experts
or
to
people
who
are
outside
the
agency
who
need
it
I.
Think
that
addresses
the
point.
Okay,.
H
H
A
B
G
F
So
I
think
that
this
is
okay,
it's
a
little
more
Bare
Bones,
but
it's
okay.
It
totally
loses
Emily's
point
about
and
Jordan's
point
about
that.
We're
talking
about
two
things
here:
one
is
the
format
of
the
document
itself
and
the
other
is
this
contextual,
what
Emily
called
contextualization
and
so
assuming
people
are
on
board
with
that
being
a
distinct
but
also
important
aspect
of
this,
we
can
keep
everything
bill
just
suggested,
but
add
a
sentence.
A
Okay,
so
we
have
kind
of
three
parts
here
that
I
read
into
it,
so
we
have
location,
easily
identifiable
format
accessible
and
in
the
contextualization,
which
is
a
company
description,
explanation
or
whatever
the
committee
on
style
decides
it's
the
best
language
to
put
in
there,
and
so
that's
an
attempt
to
capture
all
three.
Yes
David.
J
A
We
could
have
basic
programs
right,
so
we
have
in
a
user-friendly
format
instead
of
accessible,
so
we
have
to.
They
should
provide
an
accompanying
explanation
and
post
the
manuals
in
an
easily
identified
location
on
their
website
and
in
a
user-friendly
format
to
ensure
that
potentially
interested
persons,
so
Emily
has
some
suggested
language
in
the
comments.
I
can't
get
to
the
comments,
because
my
cursor
is
not
working.
H
A
A
A
A
F
Michael
so
so
this
makes
lots
of
sense,
I,
I,
sort
of
have
a
couple
minor
suggestions
which
actually
mainly
began
with
Bernie
Bell.
When
we
were
talking
about
this
one
is,
you
know,
notice
of
availability
in
the
Federal
Register
right
agencies
are
always
concerned
about
the
costs,
and
this
is
not
a
sort
of
setting
where
it's
obvious
it.
F
G
A
A
A
J
Lost
track
of
all
the
numbers,
but
what
is
number
six
is
the
only
thing
here
that
pertains
to
internal
use,
all
the
rest
of
it
is
public
use.
So
my
suggestion
is
to
move
six
up
to
the
previous
section,
which
is
about
managing
enforcement
manuals
and
to
rename
this
section
to
have
it
clear.
This
is
about
public
availability,
okay,.
G
Q
Q
G
A
A
A
A
M
I
have
a
problem
with
the
second
and
third
sentences
in
the
in
the
paragraph
it
says:
statutes
agency
rules
whether
adopt
after
a
dose
and
comma
or
otherwise.
An
agency
policies
govern
the
exercise
of
agencies,
enforcement,
Authority
and
direct
the
activities
of
enforcement
personnel,
and
this
idea
that
non-legislative
rules
govern
The
agency's
Authority,
all
right.
It
doesn't
govern
The
agency's
Authority
and
then
the
next
sentence
says
these
laws
and
policies
might
explain.
Well
the
laws,
don't
explain
the
relevant
statutes.
M
I
mean
it
just
there's
sort
of
three
steps
here:
all
right
where
the
first
we
have
statutes
and
agency
legislative
rules
that
provide
the
law.
That
says
what
agencies
have
the
authority
to
do
and
must
do,
and
then
we
have
agency
policy
guidance
documents
that
then
explain
and
interpret
relevant
statutes
and
rules,
established
standards,
priorities,
procedures,
assume
complaints,
etc,
etc.
M
Be
adding
and
after
statutes
say
statutes
and
agency
rules
and
delete,
parenthesis,
weather
and
delete,
or
otherwise
parenthesis
and
then
and
agency
policies
got
it
and
then
the
next
sentence
would
say
agencies.
Polish
agencies
apply
apostrophe
policies.
Instead
of
these
laws
say
it's
agencies,
policies
explained
strike.
Might,
for
example,.
A
I
P
G
A
So
we'll
move
to
paragraph
two
of
the
Preamble
and
we
do
have
a
suggested
change
to
paragraph
two
that
is
based
on
comments
that
are
provided
by
Matt
Weiner.
If
Matt
is
still
here,
I'm
hoping
he
could
provide
any
sort
of
further
explanation
beyond
the
comments
that
he
shared
with
us
with
respect
to
the
proposed
change
and
whether
the
language
reflects
his
thoughts
accurately.
R
This
is
Matt
here,
I,
don't
have
anything
to
add
to
it.
It
was
just
a
some
suggestion
for
the
committee's
consideration.
The
only
thing
I
guess
I
might
add
is
that
this,
this
understanding
of
of
enforcement
manuals
constraining
or
circumscribed
in
the
discretion
of
lower
agency
officials
is
to
some
extent
born
out
of
my
own
experiences
dealing
with
agencies.
As
a
lawyer
on
any
number
of
occasions
had
and
in
every
number
of
situations,
dedication
to
say
to
sort
of
a
higher
up
in
an
agency.
R
Look
you're
you're,
you're,
you're
you're,
your
first
level
enforcement
folks
are
not
complying
with
the
rules
set
up
forth
in
your
manual
no
they're,
not
it's
not
a
legislative
role.
I
understand
that,
but
I
think
they
do
provide
I
think
they
can
provide
an
an
important
rule
of
law
function.
So
beyond
that,
I
don't
really
have
anything
to
add.
Unless
there
are
any
questions.
J
After
the
changes
that
we
made
have
nauseam
on
what
I
think
is
to
see
which,
among
other
things,
has
a
modifier
that
says,
including
a
disclaimer,
if
applicable,
this
the
sentence
that
begins,
although
enforcement
manuals
should
not
is
going
farther
than
what
it
says
in
2C,
so
I
would
suggest
to
make
it
consistent
with
2C
change
that
should
not
to
either
may
not
or
do
not
necessarily,
but
the
easy
way
is
may
not.
Okay,.
J
A
J
M
In
order
also
to
be
consistent
with
what
we
added
in
the
recommendation,
perhaps
this
sentence
here
saying
and
something
about
the
public
shouldn't
necessarily
know
why,
on
on
the
enforcement
law,
enforcement
I
should
not
bind
it.
That's
them
and
I
mean
a
sentence
right
following
what
we
just
said,
because
that's
where
it
is
in
the
recommendation
right.
M
A
F
Yeah
not
not
really
I
mean
there's
no
point
in
going
through
every
word
of
this.
The
the
impulse
here
was-
and
this
is
what
we
discussed
at
the
at
the
last
meeting-
to
have
a
slight
kind
of
nudge
towards
foia's
presumption
of
openness
and
the
importance
of
disclosure,
and
so
the
additions
are
to
begin.
You
know
with
the
proposition
that
under
foia
in
general
manuals
staff
manuals
have
to
be
made
public
right
and
we're
concerned
about
secret
law
and
so
on.
F
You
know
understand
that
enforcement
manuals
are
kind
of
an
outlier
with
regard
to
agency
materials
and
manual
generally,
and
manuals
in
particular,
so
that
was
that
was
the
first
goal
that
the
second
was
to
just
sort
of
make
clear.
This
idea
that
you
know
to
the
extent
you're
in
facilitating
and
enhancing
compliance
disclosure
is
a
good
idea
to
the
extent
you're
facilitating
enhancing
circumvention
and
law.
F
Breaking
disclosure
is
a
bad
idea
and
that's
that's
sort
of
the
basic
trade-off
here
and
and
then
third
again
to
make
clear
the
possibility
of
redaction
and
force
to
it
closes
with
this
statutory
against
statutory
presumption
of
openness
that,
even
when
something
is
not
required
to
be
disclosed
under
the
statute.
It
has
to
be
unless
the
agency
can
really
articulate
a
foreseeable
harm
from
disclosure
which
it
will
often
be
able
to
do
with
enforcement
manuals.
F
P
So
I
think
what
Michael
says
makes
sense.
My
initial
report
and
I
think
the
recommendation
based
on
it
were
initially
drafted
very
cautiously
in
terms
of
advising
agencies
on
what
their
obligations
and
policy
should
be
regarding
foia,
but
I
have
no
problem
with
this,
especially
could
better
harmonizes
it
with
other
recommendations
that
they
cuss
is
currently
working
on.
P
A
A
A
F
G
A
A
A
Okay,
guess
that's
where
we
are
so
I
mean
one
question
that
arises:
is
whether
many
members
think
that
there's
a
need
for
a
third
minute,
a
meeting
on
the
enforcement
manuals?
We
have
one
set
of
changes
that
aren't
sort
of
embedded
in
the
document,
yet
with
respect
to
adding
language
with
respect
to
public
Reliance
on
in
the
Preamble,
but
other
than
that,
I
think
we've
Incorporated
all
the
suggested
changes
and
the
wording
of
the
document
we
could.
A
G
A
G
A
A
S
So
hopefully
we
won't
need
a
third
meeting,
because
the
third
meeting
is
10
will
be
scheduled
for
the
15th.
So,
let's,
let's
try
to
avoid
that
and
hopefully
the
the
council,
six
of
whom
are
new.
You
you
met.
You
may
know
so
like
our
chairman.
They
they
will
be
doing
this
for
the
for
the
first
time
and
hopefully
won't
I
won't
make
many
changes.
So
so
thank
you
and
I
have
a
great
rest
of
your
day.
Oh
a
special
thank
you.
A
Thank
you
so
much
Andy
I
appreciate
that.
Thank
you,
Alexandra.
Thank
you,
Jeremy
for
guiding
me
through
the
chairing
of
this
meeting
and
thanks
to
all
of
you
for
your
contributions
and
for
being
patient
with
my
with
me,
and
my
mistakes,
I
look
forward
to
seeing
you
all
again
soon
at
our
next
meeting
on
whatever
matter
is
presented
to
us.
Thank
you.
Thank
you
virtual.
Thank
you.
Take
care.