March 3, 2000

The Honorable Carol M. Browner
Administrator
United States Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, D.C.  20460


Dear Ms. Browner:

     Enclosed for your consideration is the Report of the Small
Business Advocacy Review Panel (SBAR Panel or the Panel) convened
for the planned proposed rulemaking on Effluent Limitations
Guidelines and Standards for the Metal Products and Machinery
Industry that the Environmental Protection Agency (EPA or the
Agency) is currently developing.

     On December 7, 1999, EPA's Small Business Advocacy
Chairperson convened this Panel under section 609(b) of the
Regulatory Flexibility Act (RFA) as amended by the Small Business
Regulatory Enforcement Fairness Act of 1996 (SBREFA).  In
addition to the Chair, Panel consisted of the Director of the
Engineering and Analysis Division of the Office of Science and
Technology within EPA's Office of Water, the Chief Counsel for
Advocacy of the Small Business Administration, and the Deputy
Administrator of the Office of Information and Regulatory Affairs
within the Office of Management and Budget.

     The Report includes a discussion of the options under
consideration for the proposed regulation under development, a
description of the Panel's outreach to small entity
representatives, a summary of small entity comments received by
the Panel, and the Panel's findings and discussion.  These are
also summarized in an executive summary of the full panel report.
     
Sincerely,
Thomas E. Kelly, Chair
Small Business Advocacy
U.S. Environmental Protection Agency

John T. Spotila, Administrator
Office of Information and Regulatory Affairs
U.S. Office of Management and Budget

Jere W. Glover, Chief Counsel
Office of Advocacy
U.S. Small Business Administration

Sheila E. Frace, Director
Engineering and Analysis Division
Office of Water
U.S. Environmental Protection Agency