Bill to Eliminate Board Generated Proposals
Apparently representative Wilson introduced a bill to eliminate board generated proposals. While this system may have been created with good intentions, it has been abused and IMO needs to go. Thank you Ms. Wilson.
I do not think this bill is what one wants as written. The BOF sometimes is the best group to generate a compromise proposal and get it out to the public for review. The problem is when they do it at a meeting and no one has seen it or commented on it. That excludes the advisory committees which is part of the BOF process.
What needs to happen in my opinion is the following:
1. The BOF holds a regulatory meeting and combines or generates regulations just like in the past but they do not vote final approval. They put everything in regulatory language and then postpone final action for 30 days. That lets the ADF&G have a better chance of review and comment for errors and lets the public go back and see exactly what they are proposing. At the end of the 30 day comment period (written only) they take final action on the regulations. If the regulation changes significantly they start the 30 days over.
2. The Commissioner of ADF&G must write immediately following the first meeting an analysis of each regulation and what it means to fishery management and resource protection and harvest, including costs associated with the regulation. Presently when the BOF passes something quickly ADF&G has no time to develop an analysis of the real impact of the regulation.
Ms Wilson does not have the full picture here and what her legislation does is really nothing. The BOF will just take a proposal submitted by an individual and modify it with substitute language and be fine. It really does not fix anything.
Good points Nerka.
Originally Posted by Nerka
Surprise! We can agree on something. Wilson is reacting to BOG issues, not BOF. BGPs have a place and can help resolve important issues when the other processes do not work. If i recall correctly, the BOF has a policy for BGPs that requires the Board to consider issues such as the ability of the public to participate, whether there is a conservation issue and whether the petition or ACR process would be available. This is posted on the Dept website. Some people are confused between the BGP and substitute language process. I was told that we were the victims of last minute substitute language contained in a RC last meeting where we were moved out of traditional fishing areas in order to supposedly allow passage of fish to the ND. There was very little time for the public to understand the impact of the new language and before we knew it it passed 7 to 0, thanks to Kluberton and the judge's back room meetings. This process has benefitted us in the past. This time it bit us. Perhaps that process can be improved. But having separate meetings to look at either BGPs or last minute substitute language would be very time consuming and costly. That won't happen because of the revenue shortfalls. But requiring substitute language to be provided to the public for a reasonable length of time would help. That process has been part of the BOF process forever and is here to stay. But it currently is flawed.
Originally Posted by Nerka