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Letter Dated 04/25/97 - Environmental Protection Agency

Thomas E. Kelly (MC-2131)
Small Business Advocacy Chair
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460

Subject: Effluent Limitations Guidelines and Standards for the Transportation Equipment Cleaning Point Source Category, 40 CFR Part 442; SBREFA Small Business Advocacy Panel

Dear Mr. Kelly:

I have received your letter dated April 10, 1997 regarding the proposed rulemaking regarding Effluent Limitations Guidelines and Standards for the Transportation Equipment Cleaning Point Source Category, notifying us of the possibility of convening a Small Business Advocacy Review Panel under Section 609(b) of the Regulatory Flexibility Act, as amended by the Small Business Regulatory Enforcement Fairness Act of 1996. We have reviewed the list of suggested small business representatives, and have added two additional parties (see attachment).

We appreciate the advance receipt of some of the materials associated with the rulemaking forwarded by Ms. Gina Matthews, including the fact sheet and regulatory history and a highlight of key data expected to be used in the formation of the rule.

Next Steps

We understand that the agency plans to draft a report containing the views and the recommendations of the small entity representatives, and re-evaluate whether the proposal would have a significant impact on a substantial number of small entities. If not, a Panel would not be required under SBREFA. If a Panel is 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 Section 609(b)(4)), in order to allow sufficient review time by Panel members. We look forward to working with the agency to implement this important new law.


Jere W. Glover
Chief Counsel for Advocacy

cc: Art Fraas, OMB
Gina Matthews, EPA


Jack E. Waggener
Resource Consultants, Inc.
P.O. Box 1848
Brentwood, TH 37024-1848
615-370-6260 ph/ 370-9198 fax

Kathy Clancy
National Oil Recylcers Association
1415 S. 9th Street
St. Charles, IL 60174
630-377-0474 ph/ 377-0593 fax