This link is to the Concise Explanatory Statement requirements in the WAC process. In 2008 ( I think ) the Legislature altered requirements that agencies utilized ( they would cherry pick & ignore citizen input ) so they have to respond to each subject. They can group things up from different sources ( citizens ) but must respond to each issue placed into comment on the record.

http://apps.leg.wa.gov/rcw/default.aspx?cite=34.05.325
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Dazed and confused.............the fog is closing in