February 29, 1984IN THE MATTER OF: ) PERMIT AND INSPECTION FEES ) R84—1DISSENTING OPINION (by J.
D.
Dumelle):
The Emergency Rule enacted by the Board majority todayis of doubtful legality, serves no purpose, is much too complex,does not follow the statute, and will, if finally enacted inP.84-7, generate a great many needless appeals.
The adopted rule is much too complex.
It has levels of
surveillance determined by a subjective point system.
If, in the future, the Board sets fees for air
and water and water supply inspections then those too will haveto be on a billing basis for actual inspect...
Allowed
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