Thread Subject: Subpart A- Draft Document- Review and CommentsRequested

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From: Deborah Buck
Date: Wed, Mar 14 2007 4:25 PM

Dear Colleagues, I?ll bet that you thought the Subpart A co-chairs fell into
an abyss. While it may seem that way, we have actually been trying to pull
together a document that reflects the input, discussions and opinions that
have transpired over the last few months. We felt that we had reached a
point where it was necessary to get something on paper so that workgroup
members could review and make substantive comments and suggestions.



This is the process we plan to undertake. A draft document is attached. I?m
not certain if attachments will go through the list serv so I?ve also
excerpted the document into this message. The content of the document will
also be posted on the TEITAC, Subpart A section of the Wiki.



We are requesting that you do the following:

1) By Friday March 30, 2007, please review the document and submit
written comments through the list serv.

a. All of the comments will be collected, synthesized and summarized.

b. A summary of the comments and input will be distributed, when
complete, following the March 30th deadline.

2) A Subpart A conference call will be scheduled. We are currently
finalizing the date of the call to ensure availability of the co-chairs. The
call will either be Thursday April 5th or Thursday, April 12th. The call
will be held at 1:00-3:00 eastern time. When finalized a notice will be
distributed thru the list serv and it will be posted on the TEITAC Wiki and
calendar. The purpose of this conference call will focus on trying to come
to consensus on language and identify remaining issues that need to be
addressed (like back office in case no one offers additional language).
Please plan to participate in the call.

3) As you review the document is important to take the following into
consideration

a. The document is divided into the sections that correlate with the
sections of Subpart A that we have been addressing:

i.
§1194.2 Application.

ii. §1194.3
General exceptions.

iii. §1194.4
Definitions.

4) In particular, you should note that under §1194.2 Application
several options are provided under subsection (c) because it became clear
during our discussions that many interpretations exist. In no way should it
be assumed that the options crafted are an endorsement of one method over
another. In fact, the options laid out are mutually exclusive and must be
considered independent of one another as they conflict if combined.

5) In crafting your comments and responses to the document, please
frame them in the following manner.

a. If you agree or disagree with the language drafted, or favor one
option over another, please identify your preferences and identify what you
see as the pros and cons of the proposed language or approach.

b. If you think alternative language would be more appropriate- please
include it and be as specific as possible. Please keep in mind that our
intent is to make Subpart A clearer to increase implementation in a
consistent manner.

c. The draft document follows- there are lines between the sections to
distinguish the transition. Within each section the language is lifted from
the current regulations. Language that is being proposed to be deleted is
struck through and new language is distinguishable because it is underlined
and in bold type. Where we could, we provided explanations or comments to
help clarify the intent of the language drafted.

6) As always, if you have questions, please let us know. Deborah

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