Thomas E. Kelly (MC-2131)
Small Business Advocacy Chair
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Subject: Metal Products and Machinery Industry Effluent Limitations Guidelines and Standards
Dear Mr. Kelly:
I received your letter on September 7, 1999 regarding Metal Products and Machinery Industry Effluent Limitations Guidelines and Standards, notifying us of the possibility of convening a Small Business Advocacy Review Panel under §609(b) of the RegulatorySmall Business Regulatory Enforcement Fairness Act of 1996.
Having examined the list of suggested small business representatives, we have added several additional parties to the list at this time. We agree to the EPA list and have added several trade association representatives who were actively involved in representing their small business members in the phase I proposal for this rulemaking.
Next Steps
We understand that the agency plans to re-evaluate whether the proposal would have a significant impact on a substantial number of small entities. If the agency finds no such impact, a Panel would not be required under SBREFA. If a Panel were convened, a final Panel report would be prepared.
If a panel is warranted, we ask that EPA provide, in advance of the convening of the Panel, supporting materials and possibly a draft regulatory analysis and/or draft rule (see RFA §609(b)(4)), in order to allow sufficient review time by Panel members. We strongly recommend that the agency hold several prepanel meetings in accordance with the most current EPA SBREFA guidance to assure that adequate and timely information and data is provided to the small entity representatives and the panel representatives.
Sincerely,
Jere W. Glover
Chief Counsel for Advocacy
cc: Art Fraas, OMB
I. Additional Small Entity Representatives
September 22, 1999 (corrected)
Al Collins
National Association of Metal Finishers
202-965-5190
David Isaacs
Electronics Industry Association
(ph) 703-907-7500
Holly Evans
IPC
(ph)202-333-2331
(fax) 333-6605
Jack Waggener
Dames & Moore
320 Southgate Court
Brentwood, TN 37027
(ph)615-370-6260