September 23, 1999

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 Regulatory Flexibility Act, as amended by the
Small 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