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Letter to Thomas E. Kelly, EPA
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 Industrial Laundries Point Source Category, 40 CFR Part 441; SBREFA Small Business Advocacy Panel
Dear Mr. Kelly:
I have received your letter dated March 3, 1997 regarding the proposed rulemaking regarding Effluent Limitations Guidelines and Standards for the Industrial Laundries 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 agree with your selection. We also would like to add Douglas Greenhaus of the National Automotive Dealers Association to the list of representatives (see attached).
We appreciate the advance receipt of some of the materials associated with the rulemaking forwarded by Ms. Susan Burris, including the fact sheet and regulatory history and a highlight of key data expected to be used in the formation of the rule.
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
Susan Burris, EPA
National Automotive Dealers Association
8400 Westpark Drive
McLean, Virginia 22102