One move at a time

From left, National Archives' Sharon Whitt, EPA's John Moses and Rick Otis, GPO's Selene Dalecky and EPA's of the E-Rulemaking project team.

Susan Whitney-Wilkerson

E-Rulemaking team makes small steps

When the Environmental Protection Agency took over the Online Rulemaking project in October 2002 from the Transportation Department, it wasn't in uncharted territory.

Program managers could glean lessons from other projects, such as Grants.gov, about what types of communication, governance and funding models work.

But even with this experience to work from, bringing together 12 agencies to develop an electronic rulemaking system was no game of tiddlywinks. In fact, Rick Otis, EPA's deputy assistant administrator for environmental information, thinks it was more like a chess match.

'Part of the process is to be smart enough to recognize in advance the potential problems and deal with them,' he said. 'You also have to recognize that not everyone is going to play fair and that there will be a little Machiavellian behavior, and you must be prepared to deal with that too.'

Otis, project manager Oscar Morales and the entire interagency team dealt with the Machiavellian behavior and the other issues to launch Regulations.gov in January 2003. The project team used a Government Printing Office and National Archives and Records Administration front end, which lets users find proposed and final rules. EPA and the Food and Drug Administration put together the back end, which lets users send comments about proposed rules to the correct agency.

The project team now is preparing module two of the initiative, a governmentwide centralized docket management system that will let citizens access and search regulatory material and public comments.

'The process we've gone through is similar to how a rule is written,' Morales said. 'We brought together a diverse group of people and, through a lot of compromises and discussions, we became one.'

Morales, Otis and other agency partners said there is no magic bullet to making cross-agency projects work, just communication, making agencies take ownership of the initiative'and a feeling that they weren't allowed to fail.

'We all had one common goal and I think everyone recognized that,' said Selene Dalecky, GPO's E-Rulemaking project manager. 'Agencies dropped their baggage and histories to focus on coming together for the one common goal.'

Morales said one of the first steps for any cross-agency initiative is to establish how the project office will communicate with its partner agencies. E-Rulemaking set up a monthly newsletter, online collaboration tool and contact database.

'At every agency we had to deal with at least three different groups of people: legal, IT and the rulemaking or docket-making people,' Morales said. 'The regulation writers were the hardest group to get to because they work in isolation and somewhat ad hoc.'

Otis said it was important to get the business process people involved from the beginning because they were key to making the project work. The first all-hands meeting for E-Rulemaking drew more than 200 people from the three groups, as well as political appointees, Morales said.

In another important step, project officials set up an advisory board to handle the day-to-day decisions and an executive committee to deal with the major technical and resources decisions.

The executive board, chaired by EPA CIO Kim Nelson and OMB's Office of Information and Regulatory Affairs deputy administrator Don Arbuckle, included agency CIOs, deputy secretaries and chief financial officers.

Reynold Schweickhardt, GPO CIO, said the committee helped get executive level buy-in, which was important for the project to succeed. But the advisory board played an even larger role in pushing the program forward, Schweickhardt said.

'The confidence agencies have in the program comes from the advisory committee,' he said.

Otis said he didn't want any agency to feel its problem was steamrollered by the project team.

'When we had issues, because we were a small agency, it would have been easy for the project management office to ignore us,' said Sharon Whitt, NARA's E-Rulemaking project manager. 'But the project management office listened to everyone and made us feel like our two cents was welcomed as much as anyone's.'

Beyond communication and governance, funding usually is the biggest problem for cross-agency projects. E-Rulemaking followed an approach similar to the ones used by Grants.gov, the Business Gateway and the Integrated Acquisition Environment initiatives. Agency contributions are based on nine criteria, including the number of regulations they issued and comments received in 2002, Morales said.

True costs

'Simply dividing up the costs was not fair,' Otis said. 'Our model is a predicate to a service-level agreement that we will eventually go to.'

The rulemaking team also signed an agreement with every agency outlining expectations and an agreement to transfer funds from one agency to another.

'A lot of agencies didn't know the full costs of their rulemaking systems and so they were a bit surprised when they got the bill,' Morales said. 'But when we walked them through their costs, they realized what it takes to manage the system.'

The funding model worked so well this year that it has been left in place for 2005 and 2006. GPO's Dalecky said the recent meeting went 'amazingly smoothly.'

Otis said that, looking back over the last two years, he would have set up the governance process more quickly and had agencies more firmly commit to staff resources.

'We struggled to get people to come to work on this project,' he said. 'The executive committee could have set up a system to make sure the office was staffed properly on a rotating basis.'

Morales said all the collaboration slowed down the project, but it was necessary to getting it done correctly and making it truly interagency.

'This proved we could work across agencies and do it well,' Morales said. 'We did it quickly, for less than $300,000, and never had any technical problems.'

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