March 2, 2007

BY ELECTRONIC MAIL
The Honorable Ben Grumbles 
Assistant Administrator, Office of Water 
c/o Water Docket
Environmental Protection Agency
Mailcode 2822T
1200 Pennsylvania Ave., N.W.
Washington, D.C.   20460

Re:  Docket ID No. EPA-HQ-OW-2006-0765, Request for Extension of Public 
Comment Period on the Proposal, “NPDES Permit Fee Incentive for Clean Water 
Act Section 106 Grants; Allotment Formula” 72 Fed. Reg. 293 (Jan. 4, 2007).

Dear Assistant Administrator Grumbles:

The Office of Advocacy of the U.S. Small Business Administration (Advocacy) 
respectfully requests that the U.S. Environmental Protection Agency (EPA) extend the 
public comment period on the above referenced proposed rule for an additional 60 days.  
Advocacy believes that this extension is necessary in order to allow small businesses and 
small communities to advise EPA fully on the likely impacts of the proposal.  
Representatives of small businesses and small communities have contacted Advocacy 
and expressed their concerns about the proposal, the short time frame for comment on the 
proposal, and their uncertainty about the economic implications of the proposal.  

In the absence of any formal analysis of the proposal’s economic impacts on small 
businesses and small communities, EPA would be well served to allow these small 
entities to have a better grasp of how the allotment changes would affect them so that 
they can comment accordingly.  Because this proposal would appear to have the potential 
to significantly affect the water permit fees paid by small businesses and small 
communities, EPA should want to gather more, rather than less, detailed information 
from affected sources.
      
The Office of Advocacy was established pursuant to Pub. L. 94-305 to represent the 
views of small business before Federal agencies and Congress.  Advocacy is an 
independent office within the U.S. Small Business Administration (SBA), so the views 
expressed by Advocacy do not necessarily reflect the views of the SBA or the 
Administration.

We stand ready to assist EPA in its careful consideration of how this proposal will impact 
small entities.  Please do not hesitate to call me or Keith Holman (keith.holman@sba.gov 
or (202) 205-6936) if  we can be of further assistance.


      Sincerely,



      Thomas M. Sullivan
      Chief Counsel for Advocacy  


cc:Steven D. Aitken 
Acting Administrator, Office of Information and Regulatory Affairs 
Office of Management and Budget