RED TAPE REVIEW COMMISSIONFINDINGS AND RECOMMENDATIONSAPRIL 30,2014

SUBMITTEDBY

Honorable KimGuadagno, Lieutenant Governor, ChairHonorable Brian P. Stack, Senator

Honorable Steven V. Oroho, SenatorHonorable John J. Burzichelli, AssemblymanHonorable Scott T. Rumana, Assemblyman

HonorableBrianD.Levine,Mayor,TownshipofFranklinEdward B. Deutsch, Esq.

John Galandak Tony Monteiro

April 30, 2014

Dear Governor Christie:

In accordance with Executive Orders No. 41 and 155, the Red Tape Review Commissionsubmits thisreport,the delivery ofwhichfurthers our commitment to improving New Jersey’sbusiness and regulatory environment.

As this report demonstrates, the bi-partisanRedTapeReview Commission, inconjunctionwiththeExecutiveBranchandtheLegislature, has brought a systemic culturalchangetoTrenton.Working collaborativelytoachieveregulatoryrestraint,theseeffortshaveimproved NewJersey’sregulatoryprocess, eliminatedburdensome red tape, and promoted jobcreation, job retention, economicgrowth, and investment in New Jersey.

This report focuses on the Red Tape Review Commission’seffortsto eliminateneedlessly burdensomerequirements and to streamlinebusiness-to-government interaction –effortsthathave made NewJerseyamorehospitable climate forbusiness.Inadditiontocataloging our public outreach over the last two years,thisreport also highlightssome of theState’s regulatory and legislative accomplishmentsin this regard and provides recommendationsto continue improvements to the State’s regulatory environment.

Although New Jersey has and continues to make significantprogressinimprovingitsregulatory environment,streamlining government, reducing needless burdens, and cutting redtape, moreremains to be done. I look forward to continuing this importantmission, working withthe Commission’s elected and public members, andseekinginvaluableinputfromtheregulatedcommunity, impacted businesses, substantive experts, entrepreneurs, andall manner ofcitizenswhoseideashaveandwillcontinue to informour collectiveefforts.

Wethankyoufortheopportunitytoservethepeople of New Jerseyinthisendeavor.

Respectfully,

KimGuadagnoLt. Governor

PursuanttoExecutive Orders Nos.41and155establishingabi-partisanRedTapeReview Commission (“RTRC”) and requiring periodic reports to the Governor, this Reportrecaps recentsuccesses in cutting redtape to reduceregulatory burdens andstreamlinegovernment, aswellas making recommendationsfor continuing efforts to improve the State’sbusiness environment.

I.A BRIEF HISTORYOFTHERED TAPE REVIEWCOMMISSION

a.The Genesis of the RedTape Review

Immediately afterGovernorChristieandLieutenant Governor Guadagno were elected inNovember 2009,theyorganizedan informal “red tape” transition teamtotacklethe impedimentsto economic growth,jobcreation,and investment inNewJersey.Duringtheensuingtwomonths,theteamheldeighteenroundtablediscussionswithbusinesspeoplerangingfromentrepreneurs to executives frommajorblue-chipcorporations,aswellaseducators,healthcareprofessionals, environmentalists, lawyers, andlocal government officials.Thegoalofthesediscussionswastogatherconstructive reformideas froma widecross-section of New Jersey’sregulated community as to our State’s poor reputation for business and how to improve it.

Those conversations informed the Administration’s recognitionthatthe elimination ofunworkable, overly-proscriptive, and ill-advised rules and regulations was not mutuallyexclusivewiththeregulatoryintent of safeguarding societal goods suchascleanair, water, andconsumer protection.

b.ExecutiveOrdersandCreationof theRedTapeReviewCommission

OneoftheGovernor’sfirstactionswassigninga series of Executive Orders to cultivate anewapproachto administrative rule-making.Executive Order No. 1 suspended 128 proposedadministrative rulesandregulations(16ofwhichwere ultimately withdrawn) and prohibited thepromulgation of new rules and regulations for 90 days, absent enumerated,compellingrationales.Executive Order No.2established“Common Sense Principles” for State agency rule-making designed to make the regulatory processunderstandable, consistent, and predictable.

Thatorderfurtherrequireda departmental review of existing regulations for compliance with theCommonSensePrinciples.Asaresult,six chapters of the Administrative Code were abolished,99 regulations amended, and 31 regulations repealed.

With Executive Order No. 3, Governor Christie establishedabi-partisanRedTapeReviewGroup,chairedbyLt.GovernorGuadagno,to “review all pending and proposed rules and regulations . . . to assess their effects onNew Jersey’s economy and to determine whethertheirburdensonbusinessandworkersoutweigh their intendedbenefits.”TheRedTapeReviewGroup issued two reports that madelegislative, regulatory, and policyrecommendations:a 90-day report and a 180-day report. On September 23, 2010, Acting Governor Guadagno signedExecutive Order No. 41 to create a bi-partisan Red Tape Review Commission (“RTRC”).InadditiontoLt.GovernorGuadagno,other members of the RTRC are:Senator Brian P. Stack,

Senator Steven V. Oroho, Assemblyman John J.Burzichelli, Assemblyman ScottT. Rumana,Mayor Brian D. Levine, Edward B. Deutsch, John Galandak, and Tony Monteiro.

Finally,andinrecognitionoftheinvaluable contributions of the RTRC to improvingNewJersey’sregulatory climate, onApril30, 2014, Governor Christie signed Executive OrderNo. 155, extending the RTRC’smission to December 31, 2015.

The Administration recognizes that sustaining the red tape reforminitiative requires theengagement of all stakeholders who participateintheregulatoryprocess.Tothatend,earlyin2010,the Department ofState(“DOS”)establishedaredtapereviewdevoted email account: . DOS also created red tape review web pages so that the publiccouldprovideinputandtrackredtape developments, news,andevents.

c.TheGuidingCommonSense Principles of Executive Order No.2

Executive Order No.2setforththe ChristieAdministration’s guiding Common SensePrinciplesofregulationincluding:

  • Engaginginthe“advancenoticeof rules” by soliciting the advice and viewsof knowledgeable persons fromoutside of State government;
  • Adoption of the “time of decision” rule whereby permits orapprovalsaregoverned by the rules, regulations, and standards in effect at the time anapplicationisfiled;
  • Adoptrulesforwaivers;
  • Employ the use of cost/benefitanalyses;
  • Adhere to federal standardsexcept when requiredby statuteorexceedingfederal requirements is necessary toachieve a New Jersey specific publicpolicy goal;
  • Value performance-based outcomes and compliance, overthepunitiveimposition of penaltiesfortechnicalviolationsthat do not negativelyimpactthepublichealth,safety,or environment;
  • Impose theleastburdenandcoststobusiness,includingpaperworkandothercompliance costs, necessary to achieve the underlying regulatory objective;
  • Treatthoseaffectedbyrulesand regulatory processesas customers andtreatthemconsistentlyacrossregions,offices,and departments;
  • Coordinatewithotheragenciestocombine and minimize regulatory filingsand to minimize worksite interruptions;
  • Strivetoreducetheprocessing time for regulatory approvals, permits,licenses, and other actions requiring agency response; and
  • Leverage information systems andothertechnologiesto improve efficiencyand processes.

These Common Sense Principleshave beena guiding principleof the Administration’srulemaking restraintduringthelast four years.As this Report and prior RTRC reportsdemonstrate, bysteadfastlyapplying these CommonSensePrinciples,theChristie

Administration hassubstantially improved the State’s regulatory environment,making NewJersey more hospitabletobusiness,while simultaneouslysafeguarding thepublic’shealth,safety,andwellbeing.

One metricforanalyzingthis culture of regulatoryrestraint isthe size ofthe New JerseyRegister – the official Officeof Administrative Law publication, produced twice each monthcontainingallnoticesofproposed regulations, adopted regulations, and miscellaneous noticesfromstate agencies. The chart belowdepicts the Administration’s commitment toreducingregulatoryburdensasevidencedbythesignificantlyreducedsizeintermsof page count of the annualNewJerseyRegister volume overthe last four years whencompared to the yearsimmediatelypreceding theChristieAdministration.

d.Public Meetings

Over the last two years, the RTRC heldsix publicmeetings (3each year) dispersedthroughout New Jersey as follows:

Date / Location / Topic
1 / April 24, 2012 / Camden County College, Cherry Hill / Energy and Infrastructure
2 / July17,2012 / NewJersey Small Business DevelopmentCenter at the College of New Jersey, Ewing / The ProcurementProcess
3 / October 9, 2012 / Morris County Community College,Randolph / Open Forum
4 / April 16, 2013 / Eagle Theatre,Hammonton / Insurance Matters
5 / December 18,2013 / LivingstonPublic Library, Livingston / Startinga Business inNew Jersey
6 / December 19, 2013 / State Museum Auditorium, Trenton / Business Red Tape

Thosewhotestifiedincluded:AssemblywomanAmy H. Handlin, the New Jersey SmallBusiness Development Center,theCenter for Non-Profits, the New Jersey Law RevisionCommission, officials fromthe Department ofBankingandInsurance(“DOBI”), Department ofEnvironmental Protection (“DEP”), DOS, Department ofTransportation(“DOT”),theDepartment ofTreasury (“Treasury”), and the Board of Public Utilities (“BPU”), not to mentionnumerous individuals and businesses ranging from large restaurantfranchises toa forensicaccountant.

II.REDTAPEACCOMPLISHMENTSINCOMPLIANCEWITH THECOMMONSENSEPRINCIPLESOFEXECUTIVEORDERNO. 2

The following section summarizes noteworthyredtape accomplishments overthelasttwoyears, organized in accordance withthe most salient CommonSensePrinciplesofExecutiveOrder No. 2.This recapitulation is not– nor could itbe–anexhaustivelistofall Administration-wide efforts to reduce red tape,butratherisintendedtoput forth representative examples ofefforts accomplished bymyriad State departments and agencies.

a.Pre-Proposal Stakeholder Input

Executive Order No.2requiresState rulemaking bodiestoengageinthe“advancenoticeofrules”bysoliciting,in advance of any rulemaking, the advice and views of stakeholders andknowledgeable persons fromoutside of State government. This insight on proposed rules notonly prevents unworkable, overly-proscriptive,and ill-advised rules frombeing proposed – let aloneadopted–butalsoensuresthatproposedregulationshavebeenvettedtoavoidunintended consequences and provide the regulatedcommunity with greater certainty.

Although all State departments and agencies have made great strides in increasing pre-proposal stakeholder input, the most illustrative example isDEP’seffortsinthisregard.Sincetheenactment ofExecutiveOrderNo.2,DEPhas proactively convened earlymeetings of state

environmental groups,theregulated community, impacted departments, agencies,andlocalgovernments, and citizens for scoping meetings atDEP using its large LISTSERV.The earlyexposure allows DEP to ensure that all stakeholder interests, voices, andconcernsareheardthroughouttheprocessandservestohelpensurethat any regulatory changes are workable.

Moreover,DEP’swebsitehaspagesdevotedto“OpportunitiesforPublicComment/Participation Priorto Formal Rulemaking” – a laudable example of a state agencyleveraging technology to furtherpre-proposal stakeholder input.

b.Adherence to Federal and National Standards

Executive Order No.2requiresStateagenciestonotexceedtherequirementsoffederallawexceptwhenrequiredbyState statute or where exceeding federal requirements isnecessarytoachieveaNewJerseyspecific public policy goal.A corollary ofthatprincipleisforNewJersey to adhere to nationally accepted standards where appropriate.This Common SensePrinciplehasbeenputintoeffect throughout State government.

i.Electronic Prescriptions

The Drug Enforcement Agency recentlyissuedaninterimfinalrulepermitting thesubmission of prescriptions electronically for Schedule II controlled dangerous substances.Therules of both the Board of Medical Examiners andtheBoardof Pharmacy werethereafteramended to allow practitioners and pharmacists toaccept electronic prescriptions for controlleddangerous substances if permitted byFederal law.This amendmentaligned New Jerseypracticewiththe amendments toFederallaw,leadingtomore efficient electronic processes that are lesssusceptibletoerror.

ii.Conforming withNationalInsuranceStandards

DOBI amended numerous regulationstobringthemin conformity with national laws orstandards, reducing confusion, time-wasting paperwork,andfees.For example:

•Formation of Domestic Property and Casualty InsuranceCorporationandSurplusLines Insurance.Thefederal Non-Admitted andReinsuranceReformActof2010revisedvariousissuesconcerningtheregulationofsurpluslines insurers.DOBI adopteda rule to comport with this federalstatute, thereby reducing and/oreliminating filingrequirements and fees.

•ActuarialandAcceleratedDeathBenefits.DOBIadoptedstandards for accelerateddeathbenefitsforinsurancepolicies consistentwiththestandardsset by the InterstateInsuranceProductRegulationCommission (“IIPRC”), effectively establishing one set offiling guidelines. New Jersey is a member of theIIPRC, along with 40 other states,thereby furthering uniformity acrossstate lines.

•SeasoningRule.DOBIadoptedaruletoreduce the time an out-of-state insurer mustbe in operation in the state of its domicile fromfive years to three years.Now DOBI is

consistent withthemajority of states that have a three-year operational requirement,known as the “seasoning rule.”

•Advertisement of LifeInsurance and Annuities; DisclosureRequirements for AnnuitiesDirectly Solicited to Consumers and Requirements for Annuities Directly Solicited toConsumers.Toprovideguidanceand uniformity andreduceconfusion,DOBIadoptedthe final National Association of InsuranceCommissioners (“NAIC”) model forSuitability in Annuity Transactions Model Regulation.

•FilingsbyPropertyandCasualtyInsurers. DOBI deletedtherequirementtofileaNewJersey-specificformand conformed therulestothe national standard,asreflectedintheNAICmodel.

c.Performance–Based Outcomes Rather than Proscription

AnotherCommonSensePrincipleisforagenciesto cultivate an approach to regulationsthat valuesperformance-basedoutcomes and compliance, rather than the punitive imposition ofpenalties for technical violations that do not result in negative impacts to the public health,safety, or environment. Put simply,departments andagenciesshouldregulatesubstance,notform.

i.Providing Clarification to County andMunicipalEntities

Toavoidviolationsthatoccurfromconfusionratherthanintent,the Department ofHuman Services (“DHS”) provides clarification of federal and/orState statutes and regulationswhen requested by county and municipal welfareagencies, public advocacy groups, and staff.

ii.Grace Periods to Encourage Compliance and Cure

DEPincorporatedthis Common SensePrincipleintoitsAir Administrative Proceduresand Penalties.In response tostakeholder suggestions,environmentalimpact (or lack thereof)willbe taken into consideration when adjusting penalty amounts.By classifyingcertaintypes ofviolations as “minor” and allowing for a 30-90 day grace period to correct a minor violationwithout penalty, DEPwill encourage compliance and prompt correctionof minor violations.

iii.Improving Certainty for Tenants

The Department of Community Affairs (“DCA”)amended the Uniform ConstructionCode by adopting thePlan Release with Conditions, to address the problem that businessprofessionals are stymied fromgiving accurate move-in datesbecauseof plan “re-reviews.”Oncelocal officials completetheir initial planreviewperiodin20days,plansforalterationandreconstruction projects in business, factory,mercantile or storage facilitiesare releasedwith a listof conditions specifying code deficiencies, enumeratingdeferredsubmittals, and listing pendingapprovals, with a time-line for their submittals.As they proceed with construction, developers

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arethenrequiredtocomplywiththe“conditions,”orcorrectany deficiencies noted by the officials. Code compliance would then be determined at inspection. This amendment vestsaccountability with the developersand adds certainty that translates intoconstructionschedulesandtenantmoves.Moreover,thepredictability filters down into ancillary schedulingforfurniture deliveries and communicationsequipment installations, for example.Of course, thePlanReleasewithConditionswouldnotapplytosubstantially deficient plansortoprojectsinvolvingachangeofuseor change in character of use.

iv.Providing School Bus Operators Choice in Record Retention

In anotherred tape cuttingamendment to its school bus regulations, the Motor VehicleCommission (“MVC”)willallow school busoperatorstousetheirown forms andtechnologytocomplete dailybusinspections,insteadofusing prescribed forms asperpriorregulations.Thisallows theoperatorsflexibility in recordingand storingrequired inspection reports and frees upspaceforthe operator thatwould haveformerly been usedtohousehardcopies.

d.Deploy Technology

Technologyisthe enemy ofbureaucracy,and, recognizing such, Executive Order No. 2directs State agencies toleverage information technologyto improve efficiency and process.

The Christie Administration continues to leverage technologyto transform its regulatoryprocesses and business-to-government interactions. A few examples follow.

i.Electronic Bidding

The Department ofChildren and Families (“DCF”) implemented a process to allowbiddersto submit bidproposals electronically.This saves providers thecostofcopyingandmailingmultiplecopies ofthe samedocument;expedites the process by eliminating the timerequired to ship multiple copiestotheagency;andcreatesefficiencieswhen DCF does not havetodistributethosecopiesto membersof the review team.

ii.RequestingVehicleTagson Demand

MVCintroducedanewprocessforallNewJersey-licensedmotorvehicledealersby whichdealerscanrequestandprint temporary tags on demand.This systemis highlyappreciatedbythedealer community becauseitprovidesthe significant benefitsofgreaterconvenience, accountability, and fraudprevention.

iii.Continued Evolution oftheNewJerseyBusinessPortal

The Division of Revenuewithin Treasury continues to expand the services provided aspartofits Premier BusinessServices(“PBS”),whichcanbeaccessedontheNewJerseyBusiness Portal( BusinessescannowconductaBusinessStanding Check to review their registrationstatus with the State. An individual business is ableto determine if it is still considered “Active”bytheState,ifits annual report filings are up-to-date,andwhetheritscorporatetax payments are current.In fact,the business can access 10

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yearsoftaxreturnsand payment history.As longer-standing PBS features,businessesmayfiletaxreturns,paytaxesandfile annual reports online.

iv.Eliminating PaperworkandIncreasedElectronicInteraction forFarmers

The Department of Agriculture istransforming its once paper-drivenlicensure/registrationandre-licensure/registration procedures to an electronic system. Currently,all license/registration renewals andnew license/registration applications for StoreMilk LicensesandOrganicregistrationsareonline.These systems allow foronline payments to be made andforlicensestobeprintedbytheapplicantimmediately upon completion oftheprocess.

The Department alsolaunchedthe Animal Health Diagnostic Laboratory website gearedtowardveterinarians,aswellas farmers, animalowners, animal organizations,anduniversities.The site providespeople with: theability tosearchfortestsbykeywords, animal species,discipline, and cause of the disease;submissionforms and complete instructions on how tosubmit samples;trainingandeducation information; contact information; and directions to thelaboratory.Theuser-friendly website also includes a mobile site,which provides easyaccesstothe laboratory’s services whileinthe field. Before launch of the website, submittershad to callthelaboratorytogetthis information, which added time to the specimensubmission process.

Such delay could be detrimental to specimen quality resulting in delayeddetection or non-detection of important diseases.

v.Electronic Real Estate License Generation

DOBI’sRealEstateOnlineServiceshasbeenstreamlinedandenhancedthroughtheimplementationofseveralmeasures.Mostnotably,throughtheuseofadynamicprocess,afirm’sbrokerofrecordcannowgeneratethelicensesofthecompany,allbranchoffices,andallaffiliatedindividuallicenseesondemandintheformofPDFdocuments.Alldataandupdatesare real-time.

e.Engage in Continuous Regulatory Process Improvement

Executive Order No. 2 directs departments and agencies tocontinuouslyengageinaself-evaluation of their rules,regulations,andpolicies.A few examples follow.

i.Streamlining Carnival and Amusement Ride Regulations andPolicies

DCA adopted amendments to its Carnival and Amusement Rides Rules for AcceptanceInspections,RecognizedCertifiedMaintenanceTechnicians, Manufacturers TrainingCertifications and Type Certifications. The amendments:eliminate the need to performacceptanceinspections ofinflatablerides(i.e., bounces); expandthe certifications thatwouldbeacceptable for a Recognized Certified Maintenance Technician; eliminate the need formanufacturers to provide training when anew ride issoldinNewJersey;andrequirethatthemanufacturer of a ride provideDCA with serial numbers for ridesthatare manufactured undera

typecertification.Thisadoption eliminates onerous requirements for both DCA and theindustry,and streamlines the approval processfornewrides.

ii.Empowering HighlandsMunicipalities to Approve CertainExemptions

Pursuant to a Memorandumof Understanding (“MOU”) between DEP and the HighlandsCouncil, the authority to approve seven (out of 17) exemptions in the Preservation Area wouldmove fromDEP to municipalities,whereconformance petitions for the Preservation Areahavealready been approved by the Highlands Council.The MOU allows municipalities to maintaintheir conformance commitments andtheneedsof residentswhilealso streamlining theprocessfor landowners to obtain an exemptiondetermination.

iii.Continued Process Improvement FacilitatedbyStakeholderInput

TheDivisionof Consumer Affairs (“ConsumerAffairs”)hasmetregularly with theCoalition of Regulated Professions, a group thattestified before the RTRC at a 2011 publicmeeting, toaddressredtapeinlicensingand permits.Spurred by this on-going dialogue,Consumer Affairs has amended regulations for its occupational boards thatarenolongerrelevant. Significantredtape amendments include:

•StateBoardofSocialWorkExaminers.TheBoardrecognizesnewmethodsforcompleting continuingeducation requirements and with a newly adopted rule, provideslicensees (or their employers)moreflexibilityand cost savings.Limitations on creditsdirectlyrelated to clinicalpractice were removed and the Board will no longerapprovespecificcoursesofinstruction.Itwillinstead defer to accreditationfromnational socialwork organizations. Notably, substantial changes totheruleproposal,inresponsetostakeholdercomments,wereincorporateduponadoption.Thiswouldnothavebeen possiblebeforetheRedTapeReviewCommission legislative members who passedlegislation to amend the Administrative Procedure Act in 2011.

•Board of Examiners of Electrical Contractors andFireAlarm,BurglarAlarmandLocksmith Advisory Committee.The former rule thatrequired a licensee to complete 36continuing education credits ineach triennialeducationperiod for each Committee-issuedlicenseheldwasfoundtobeoverly burdensome.The rule wasamended to reduce thecredit numbers and thespecificsubjectmatter was indicated to assure properlyeducatedprofessionals. Also, the amendmentexpanded the number of continuing educationcreditsforeachlicensethatcouldbe earned through internet, correspondence, self-studyprograms, etc., rather than in-personphysicalattendanceatcertaincourses.

•Home Inspector Licensees. Adopted rule amendments doubled the maximumamount ofdistance learning units, thereby increasing the convenience tohome inspectorsandsavingthemmoney on tuition and transportation costs.

iv.CuttingRedTapeforNon-ProfitOrganizations

The Legalized Games of Chance Control Commission(“LGCCC”),alsopartofConsumer Affairs,adoptedrulesthateased the requirements fornon-profitstohold raffles andbingo games. These suggestions were presentedto the RTRC by the Center for Non-Profits andother non-profit associations and organizations.Due tothese amendments, theburdensandcostson licensed organizations willbe lessened, thereby allowingmoreoftheir limited dollarstobespent on service delivery – not needless administrativecompliance costs.Because anorganizationdoesnotneedalicensetoholda specialdoorprizeraffle, the notificationrequirement to municipalities was removed. If amunicipal clerk forwards an application for amunicipallicensetotheLGCCC and it does not respond within 14calendardays,thelicenseisautomaticallygranted;thistimeframe was shortened from15 business days.Off-premises fifty-fiftyrafflesmaynowbeheldtwice a month, up fromonce a month.The raffle prize limit wasraisedto$1,500from$500andtheinstantraffleticketprice limit wasraisedto$3.00from

$1.00. Also, removing an administrative chore, theLGCCCnolongerrequires organizations tosubmit a certificationthatindicates the number of tickets printed.

f.Eliminate the Unnecessary

In compliance with Executive Order No. 2, manydepartments and agencies amendedrulestorequirethesubmissionof only relevant information, thereby imposing fewer burdens onbusiness and the regulated community. Moreover, departments andagencieshaveinfusedtheirregulationswith more common sense,ensuringthat regulationsaccomplish their intended goals,but do not unnecessarily impose unintended consequences.

i.Modernizing Filings for Cable TelevisionCompanies

The Office of Cable Television (“OCTV”) inBPUeaseditsregulatory requirements toeliminate unnecessary paperwork. StartingwithAnnualReport Forms duein2013,OCTVformsmay now be prepared on a consolidated(i.e.,multi-system) basis. Also, in lieuof filing anaudited financial statement, the operator may file an unaudited financial statement certified bythe operator’s financial officer, attesting tothe truth,completeness, and accuracy of the reports.Moreover,inatrueexampleof commonsense rule-making, filers may indicate by checking a boxthatcertain information hasnot changed fromthe prior year’sfiling, rather than submittingnewforms.Also,theBPU clarified thatitsrules regarding the filing of tariff changesrequireonlythefilingofthespecificsheets that are proposed to be revised,nottheentire, voluminous tariff.