Since the various boards for Air Pollution Control, Water Pollution Control, and Solid Waste Management are the actual rulemaking bodies within IDEM, would negotiation with IDEM staff that are not associated with those boards, concerning ..

Published 08/06/2007 03:31 PM   |    Updated 02/17/2009 05:34 PM

Since the various boards for Air Pollution Control, Water Pollution Control, and Solid Waste Management are the actual rulemaking bodies within IDEM, would negotiation with IDEM staff that are not associated with those boards, concerning the content of a rule constitute executive branch lobbying?

No.  Rulemaking is within the scope of executive branch “action” governed by the Executive Branch Lobbying Rule.  However, to influence rulemaking according to the rule, one would need to influence a “decision” of an agency regarding the “proposal; drafting; development; consideration; promulgation; amendment; repeal or rejection of a rule.  Since IDEM would not be the “agency” making the decision concerning the proposal, drafting, development, consideration, promulgation, amendment, repeal or rejection of the rule in question, then they would have no “decision” to try to influence. 

 

For more information, see the Executive Branch Lobbyist Registration Rule, visit the Executive Branch Lobbyist website at http://www.in.gov/idoa/2885.htm,  or call (317) 234-4431.

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