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<br />-' - <br /> <br />Mr. David L. Wegner <br />October 10. 1988 <br />Page .& <br /> <br />IMPLEMENTATION <br /> <br />Concerning implementation of the study plan <br />discussion in this category of the draft <br />larger outline of interim efforts that are <br />is a very vague reference to that subject <br />for interim efforts prior to adoption of <br />discussed for the benefit of all concerned. <br /> <br />when adopted, the <br />should begin with a <br />contemplated. There <br />but Clearly the need <br />the plan should be <br /> <br />Our greatest concern under implementation, however. comes from <br />cur review of the second paragraph ~de~ that subject. The <br />language of that second paragraph appears to differ from the <br />directive given to the agencies in the Assistant Secretaries' <br />letter of June 16. 1988. We would strongly oppose any attempt to <br />ignore that directive or redefine its parameters. For that <br />reason. we repeat the request we made at the September 20 meeting <br />that the second paragraph of the discussion under implementation <br />be deleted and in its place be substituted the first two <br />paragraphs of page 2 of the June 16, 1988 Assistant Secretaries' <br />letter. <br /> <br />We would be remiss if we did not include in our comments a <br />mention of the chart attached to the draft. It became clear very <br />early on in the meeting that the chart was substantially flawed <br />and did not reflect the text of the doc~ent, the intent of the <br />staff or the relationships of the studies to the other ongoing <br />processes within the department. I believe it is fair to say <br />that there was a consensus that the chart needed to be <br />substantially revised in order to more accurately reflect. the <br />processes involved and the relative timing among them. <br /> <br />PROCESS <br /> <br />As you can easily see from our comments, we believe that the <br />draft needs substantial revision. Because of this necessity, we <br />have the following suggestion concerning the process of <br />developing a final program document: (1) Distribute written <br />comments received to other commentors; (2) Develop responses to <br />the comments; (3) Prepare a revised draft and submit it and the <br />comment responses to interested parties who then will ~e given <br />additional time for review; (4) Call a meeting of interested <br />parties in Phoenix. Emphasize to both the Las Vegas and <br />Flagstaff attendees that all views need to be represented at this <br />meeting. Ask the invitees to come prepared to discuss points of <br />agreement and disagreement with a view toward solving problems <br />related to this program document. Advise invitees that problems <br />not resolved will be resolved by the Executive Review Committee. <br />