There are multiple reasons for concluding that the procedure used is fair under these circumstances. First, because school begins in August, there is not sufficient time to adopt a rule through non-emergency means before the start of the 2019-20 school year. Second, the agency has received multiple requests from school districts to clarify and define the criteria for content area experts so that districts can use the funds for remaining recruitment efforts. Additionally, the emergency rule allows districts to distribute not only recruitment awards to new teachers, but since recruitment awards must be made before recognition awards, this rule will allow school districts the opportunity to distribute recognition funding to K-12 instructional personnel. Further, the agency is of the opinion that the procedure is fair because the rule itself relies in part upon criteria established in an existing rule that has already been adopted through the full rulemaking process. Moreover, the emergency rule was published on the Department’s website in an effort to reach interested persons. Finally, the agency intends to proceed with the normal rulemaking process as soon as possible in order to seek input from interested persons for any subsequent awards.