Environmental Protection Agency

Rules of Practice Administrative Proceedings Paper Reduction

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40 CFR Part 22 governs the administrative adjudicatory proceedings. Rule 22.5 requires the filing of an original and a copy of a document. In addition, during the process copies of all documents are also served to the Presiding Officer and the respondent. At this time an original and at least 4 copies have been generated. If the case goes to a hearing, the EPA attorney is required under Rule 22.22(e) to submit an original and a copy of an exhibit and a copy for the other party. These documents have already been submitted to the Presiding Officer, to the other party and filed before the Regional Hearing Clerk during the Pre-hearing Exchange (Rule 22.19(a)(2)(i). In summary, at least 8 copies of the exhibits are made, when only one is actually submitted into evidence. Both the Presiding Officer and the otherparty have received copies during the Prehearing Exchange. In order to work towards paper reduction in our agency and serve as an example to other agencies which follow similar procedures, all documents to be served on employees of EPA shall be notified by e-mail in a pdf format, this will save not only paper, but will reduce the cost of mailing such documents, in the extent possible, after an attorney appears on behalf of a Respondent, the other parties shall also be served the same way. During the hearing, only the original of an exhibit will be required for submital into evidence. No other copies need to be provided since they have been previously submitted during the Prehearing Exchange. this idea will have to be addressed in the Consolidated Rules of Practice in 40 CFR Part 22. In a tipical administrative case, the office uses enormous amounts of paper for copies, faxes, correspondence, when we could substantially reduce and or eliminate it by notifying documents buy e-mail in pdf format. In addition, there will be a reduction in costs for mailing the documents.

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Idea No. 4241