Dear Ms. Sapin:

The Committee on House Administration submits the following comments and regarding the revised proposed amendments to the Procedural Rules of the Office of Compliance (“OO C”) which were submitted for publication in the Congressional Record on September 9, 2014. The following comments are submitted in the Committee’s capacity as a representative of House employing offices pursuant to 2 U.S.C. § 1383(b).

Introduction

The Committee welcomes a number of the changes the 00C has proposed to the Procedural RLiles (“Rules”). However, some of the proposed changes appear to exceed the OOC’s authority and/or are inconsistent with the Congressional Accountability Act (“CAA”), and/or are one-sided and unduly benefit complainants to the potential detriment of employing offices. Our comments therefore include suggestions for proposed changes to the Rules intended to ensure the efficient administration of claims and fairness to all parties. Further, there are a number of instances where the language of the proposed changes to the Rules is unclear or ambiguous and we request clarification in these areas. Finally, during our review we noted minor typographical inconsistencies in the text of the proposed changes to the Rules and we have identified these issues in the comments below.

Comments

  1. Filing and Computation of Time: pages 6-9. Sections 1.03(a). 1.03(a)(4), 1.03(b), 1.03(d). and 1.04(b). We strongly applaud the OOC’s decision to permit filing and service of documents by email. Because mail to House employing offices is delayed (and sometimes damaged) due to the irradiation process, combined with the fact that the federal courts have now moved to electronic filing, this change is a welcome modernization to OOC’s administrative processes. To further enhance this amendment we propose that the OOC incorporate the additional changes discussed below.
    a. Clarify ambiguity in section 1.03(a)(4) regarding email time display. There is some ambiguity regarding the effective date of email service.