The first step in the rule-making process is for Ohio EPA to identify that a rule needs to be amended, rescinded, or created. There are many different reasons to change a rule, some include a quick change, (e.g., incorrect rule reference), a limited rule change (e.g., difficulties with interpretation or application), a full ORC 119.032 review (five-year review) and changes to state or federal law.

Ohio EPA has added an additional step to ensure stakeholders are brought into the rule process as early as possible. This additional outreach and request for information will allow for early feedback before the rule language has been developed by the Agency. The notifications may be different for the type of rule changes necessary.

• For quick changes and limited rule changes – The notification will identify the rule and the problem, contain a link to the current rule and provide information on how to comment.

• For full ORC 119.032 reviews – The notification will identify the rule, link to the current rule, and provide information on how to comment. If problems with the current rule or concepts on how the rule will be changed have already been identified by Ohio EPA, these may be included in the notification. If the intent is to file the rules as no- change, then this will be identified in the notification.
   
• For changes to state or federal laws – The notification will identify the rule, include the federal or state law that is creating the need for the rule change, link to the current rule and provide information on how to comment.
   
• For other changes not covered by one of the above scenarios - Ohio EPA will provide the best information necessary to allow the stakeholders to comment on the rule.

This notification is not considered an action of the director and would not be public noticed. This is considered an early courtesy to those interested parties that have already signed up to receive rule notifications. The notifications will include a deadline for submitting comments and will ask for feedback to assist the divisions in filling out the Business Impact Analysis required by the CSI process.

If any comments are received, Ohio EPA will consider those comments when drafting the rule changes. Ohio EPA will not create an official response to comments for these comments. If Ohio EPA feels additional outreach with stakeholders is necessary, the Agency may hold stakeholder meetings, send out additional questions to stakeholders or create external advisory groups. This process does not suggest that Ohio EPA is required to send out drafts or negotiate rule language with stakeholders.