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Advocacy Files Greenhouse Gas Comments

Release Date: 
Wednesday, December 23, 2009 - 5:00am
Release Number: 

WASHINGTON, D.C. – On December 23, 2009, the Office of Advocacy filed comments with the Environmental Protection Agency (EPA) concerning EPA’s ongoing Greenhouse Gas (GHG) rulemakings under the Clean Air Act. Throughout this process Advocacy has worked with small entities and EPA to ensure that small business concerns are addressed.

Advocacy believes that EPA has not satisfied its statutory obligation to fully consider the small entity impacts of these rulemakings. EPA was required under the Regulatory Flexibility Act to convene a Small Business Advocacy Review Panel prior to proposing these rules. These panels have been held since 1996, as a requirement of the Small Business Regulatory Enforcement Fairness Act. Since that time EPA has held 36 panels including 12 on the Clean Air Rules.

Acting Chief Counsel for Advocacy Susan M. Walthall stated that “Advocacy calls on EPA to convene a small business review panel before finalizing their greenhouse gas rules. This will allow the agency to assess small entity impacts and to consider alternative ways to achieve its climate change objectives without unnecessarily burdening small entities.”

Advocacy submitted several recommendations with respect to the GHG regulations under the Clean Air Act. These would take into consideration small business concerns about the rules and help alleviate the impact on small business as posed by these proposed regulations.

For the complete comment letter and fact sheet, visit the Office of Advocacy website at


The Office of Advocacy of the U.S. Small Business Administration (SBA) is an independent voice for small business within the federal government. The presidentially appointed Chief Counsel for Advocacy advances the views, concerns, and interests of small business before Congress, the White House, federal agencies, federal courts, and state policymakers. For more information, call (202) 205-6533.

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