Dr . Winslow Sargeant is the sixth Chief Counsel for Advocacy...
Regulatory Comment Letters
Regulatory comment letters concerning the Federal Government's compliance with the Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act. (2009 - 2011)
For archived Comment Letters by Year: 2008, 2007, 2006, 2005, 2004, 2003, 2002
For archived Comment Letters by Category: General, Antitrust & Trade, Environmental, Procurement, Safety, Labor, Transportation & Health, Tax Issues, Telecommunication
Leadership
Social Media
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The Office of Advocacy (Advocacy) submits these comments on the Bureau of Land Management’s (BLM) proposed rule Oil and Gas: Well Stimulation, Including Hydraulic Fracturing, on Federal and Indian Lands and the economic analysis therein.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits this comment on the proposed rule on Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z).
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The Office of Advocacy (Advocacy) submits the following comments in response to Internal Revenue Service (IRS) Notice 2012-40.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) respectfully submits these comments to the Offices of Technology and Size Standards of the Small Business Administration (SBA) regarding its proposed Small Business Innovation Size Standard rule that will implement parts of the Small Business Innovation (SBIR) Re-Authorization Act as passed in the 2012 National Defense Authorization Act.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits this comment on Regulation Z; Truth in Lending.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) respectfully submits these comments to the National Oceanic and Atmospheric Administration (NOAA) regarding its proposed sea turtle conservation rule to require the use of turtle excluder devices in the nets of all skimmer trawls, pusher-head trawls, and wing nets rigged for shrimp fishing.
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The U.S. Small Business Administration's (SBA) Office of Advocacy (Advocacy) submits the following comments on the Office of Management and Budget’s (OMB’s) request for information on Federal Participation in the Development and Use of Voluntary Consensus Standards and In Conformity Assessment Activities.
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The U.S. Small Business Administration's (SBA) Office of Advocacy (Advocacy) submits the following comments on the Office of the Federal Register’s (OFR) request for comments on the Petition for Rulemaking on “Incorporation by Reference” and the term “Reasonably Available” that was recently published in the Federal Register.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) respectfully submits these comments to the Federal Communications Commission (FCC) in response to the above-referenced notice of proposed rulemaking regarding mobile device interoperability in the lower 700MHz bands.
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The Small Business Administration Office of Advocacy (Advocacy) would like to offer comments on the Administrative Conference of the United States (ACUS) Review of Regulatory Analysis Requirements and the April 24 draft Recommendations. We believe that this project presents an opportunity to make a stronger statement about the role of regulatory analysis in policymaking and the value of early public engagement.
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The Office of Advocacy (Advocacy) of the U.S. Small Business Administration (SBA) applauds the Department of Justice (DOJ) for publishing a final rule that extends by 60 days the date of compliance with certain requirements in the 2010 Americans with Disabilities Act (ADA) Standards for accessibility of existing swimming pools and spas.
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Comments to express a small business perspective on the Administrative Conference of the United States (ACUS) project on the Paperwork Reduction Act (PRA).
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EPA’s Integrated Risk Information System’s Toxicological Review of Hexavalent Chromium
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Comments on EPA’s Proposed Rule, “National Emission Standards for Hazardous Air Pollutant Emissions: Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks; and Steel Pickling-HCl Process Facilities and Hydrochloric Acid Regeneration Plans.”
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Application of the Fair Labor Standards Act to Domestic Service-Notice of Proposed Rulemaking
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Non-Hazardous Secondary Materials that are Solid Waste
The Office of Advocacy (Advocacy) of the U.S. Small Business Administration submits this request for a review of current acquisition policies and practices regarding the acquisition tool of reverse auctions and the impact of such policies and practices on small businesses.
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The Office of Advocacy (Advocacy) of the U.S. Small Business Administration submits these comments to the Department of Agriculture, Animal and Plant Health Inspection Service (APHIS) on the proposed rule entitled Traceability for Livestock Moving Interstate.
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The U.S. Small Business Administration's (SBA) Office of Advocacy (Advocacy) submits the following comments on the Department of Homeland Security’s (DHS) Proposed Ammonium Nitrate Security Program Rule.
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Comments on the Department of Health and Human Services (HHS), National Toxicology Program‟s (NTP), Report on Carcinogens (RoC) and on the proposed RoC review process.
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The Office of Advocacy (Advocacy) offers the following comment to the Securities and Exchange Commission (SEC) in response to the above-referenced proposed rule.
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The U.S. Small Business Administration Office of Advocacy (Advocacy) submits the following comments regarding the Environmental Protection Agency’s (EPA) recent proposal to revise the final rule, Revisions to the Definition of Solid Waste (DSW), promulgated on October 30, 2008.
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Endangered and Threatened Wildlife and Plants; Designation of Revised Critical Habitat for Southwestern Willow Flycatcher; Proposed Rule.
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The Office of Advocacy (Advocacy) of the U.S. Small Business Administration submits these comments to the Department of Energy, Office of Energy Efficiency and Renewable Energy (DOE) on the proposed rule entitled Energy Conservation Program: Energy Conservation Standards for Direct Heating Equipment.
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The U.S. Small Business Administration (SBA) Office of Advocacy (Advocacy) has received several letters from small business representatives expressing concerns with the Environmental Protection Agency’s (EPA) risk evaluation of hexavalent chromium (Cr(VI)) under the Integrated Risk Information System (IRIS).
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Standard Operating Procedures (SOP) of the Aircraft Certification Service (AIR) Process for the Sequencing of Certification and Validation Projects.
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The U.S. Small Business Administration's (SBA) Office of Advocacy (Advocacy) submits the following comments on the Occupational Safety and Health Administration’s (OSHA) Proposed Occupational Injury and Illness Recording and Reporting Requirements – NAICS Update and Reporting Revisions Rule.
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Proposed Endangered Status for the Chupadera Springsnail (Pyrgulopsis chupaderae) and Proposed Designation of Critical Habitat
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Comments on National Emission Standards for Hazardous Air Pollutants From Coal- and Oil-Fired Electric Utility Steam Generating Units and Standards of Performance for Fossil-Fuel-Fired Electric Utility, Industrial-Commercial-Institutional, and Small Industrial-Commercial-Institutional Steam Generating Units (NSPS: Docket No. EPA-HQ-OAR-2011-0044; NESHAP: Docket No. EPA-HQ-OAR-2009-0234)
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Convening of Small Business Advocacy Review (SBAR) on Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards.
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Preliminary Plan for Retrospective Analysis of Existing Rules; Notice of Availability
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Endangered and Threatened Wildlife and Plants; Revised Critical Habitat for the Riverside Fairy Shrimp; Proposed Rule
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Electronic Fund Transfers; Proposed Rule
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Wage Methodology for the Temporary Non-Agricultural Employment H-2B Program; Amendment of Effective Date
Food Labeling; Nutrition Labeling of Standard Menu Items in Restaurants and Similar Retail Food Establishments (FDA-2011-F-0172)
Guidance Regarding Identification of Waters Protected by the Clean Water Act
Small Business Size Standards: Professional, Scientific and Technical Services
Small Business Advocacy Review Panel (SBAR Panel) Convening of Panel on Greenhouse Gas New Source Performance Standard for Electric Utility Steam Generating Units
Revised Critical Habitat for the Pacific Coast Population of the Western Snowy Plover; Proposed Rule
Temporary Non-Agricultural Employment of H-2B Aliens in the United States; Proposed Rule
Endangered and Threatened Wildlife and Plants; Listing and Designation
of Critical Habitat for the Chiricahua Leopard Frog; Proposed Rule
Antidrug and Alcohol Misuse Prevention Programs for Personnel Engaged in Specified Aviation Activities; Supplemental Regulatory Flexibility Determination
Truth in Lending; Proposed Rule
Registration Requirement for Petitioners Seeking to File H-1B Petitions on Behalf of Aliens Subject to Numerical Limitations
Reply to the notification letter regarding the Small Business Advocacy Review Panel for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Mineral Wool Production Risk and Technology Review (RTR) Amendments
Proposal To Reissue and Modify Nationwide Permits; Notice
Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Nine Bexar County, Texas, Invertebrates; Proposed Rule
- Wage Methodology for the Temporary Non-agricultural Employment H-2B Program; Final Rule
- Reply to the notification letter regarding the Small Business Advocacy Review Panel for the Greenhouse Gas New Source Performance Standard for Electric Utility Steam Generating Units
Safety Management Systems for Part 121 Certificate Holders; Proposed Rule; 75 Fed. Reg. 68224, November 5, 2010
FMCSA’s proposed rule would revise its regulations for hours of service for drivers of property-carrying commercial motor vehicles (CMV) by, among other things, reducing the daily maximum driving limit from 11 hours to ten, reducing the maximum on-duty time within the driving window from 14 hours to 13, requiring the release from duty at the end of the 14-hour driving window, requiring a mandatory break of at least 30 minutes within seven hours of the last off-duty period, and requiring that the current 34-hour restart provision include at least two periods between midnight and 6:00 a.m.
Designation of Critical Habitat for the Sonoma County Distinct Population Segment of the California Tiger Salamander (Ambystoma californiense); 76 Fed. Reg. 2863, January 18, 2011
Letter dated 02/01/11 - Federal Reserve System - Compliance Guide for Regulation Z; Docket No. R-1366, Truth in Lending
On January 31, 2011, Dr. Winslow Sargeant, Chief Counsel for Advocacy, sent a Memorandum to the heads of all Federal agencies advising them of recent changes to the Regulatory Flexibility Act (RFA) and providing guidance on President Obama’s January 18 Executive Order 13563 on regulations and memorandum on the RFA. Writing under auspices of Executive Order 13272, Dr. Sargeant strongly endorsed the principles and policies of Executive Order 13563 and the President’s memorandum and offered Advocacy’s continued assistance to all agencies in their compliance with the RFA.
Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities and Public Accommodations; 75 Fed. Reg. 43460 (July 26, 2010).
Proposed Settlement Agreements for Petroleum Refineries; (75 Fed. Reg. 82,390 (December 30, 2010) and Electric Utility Generating Units (75 Fed. Reg. 82,392 (December 30, 2010)
Notice 2011-6, Implementation of Rules Governing Tax Return Preparers
Final rule on Regulation Z; Docket No R-1366, Truth in Lending
Reply to the notification letter regarding the Small Business Advocacy Review Panel (Panel) for the forthcoming regulatory proposal, “Lead: Renovation Repair and Painting Program for Public and Commercial Buildings.”
Comment Request; Restaurant Menu and Vending Machine Labeling: Recordkeeping and Mandatory Third Party Disclosure Under Section 4205 of the Patient Protection and Affordable Care Act of 2010
Truth in Lending; Proposed Rule
On December 23, 2010, the U.S. Small Business Administration’s Office of Advocacy
(Advocacy) submitted comments on the Board of Governors for the Federal Reserve’s (Board) proposed regulation on Regulation Z; Docket No R-1390 Truth in Lending.
Specified Tax Return Preparers Required to File Individual Income Tax Returns Using Magnetic Media
Parallel Review of Medical Products
Reply to the notification letter regarding a Small Business Advocacy Review Panel for the forthcoming regulatory proposal, “Formaldehyde Emissions from Pressed Wood Products.”
Concerning the forthcoming listing of styrene as a “reasonably anticipated” carcinogen in the National Toxicology Program (NTP) Report on Carcinogens.
Proposed Accounting Standards Update regarding Leases (Topic 840)
Oil and Gas and Sulphur Operations in the Outer Continental Shelf--Increased Safety Measures for Energy Development on the Outer Continental Shelf
Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule
Regulations Implementing the Longshore and Harbor Workers' Compensation Act: Recreational Vessels
Listing Endangered and Threatened Wildlife and Plants: 90-Day Finding on a Petition to List Atlantic Bluefin Tuna as Threatened or Endangered under the Endangered Species Act
Consultation Agreements: Proposed Changes to Consultation Procedures Rule
Proposed Accounting Standards Update regarding Revenue from Contracts with Customers
Wage Methodology for the Temporary Non-Agricultural Employment H-2B Program
Regarding Expanded Form 1099 Filing Requirements
Wireline Competition Bureau Seeks Comment On Business Broadband Marketplace
Test Procedures for Walk-In Coolers and Walk-In Freezers; Proposed Rule
Medicare Program; Home Health Prospective Payment System Rate Update for Calendar Year 2011; Changes in Certification Requirements for Home Health Agencies and Hospices; Proposed Rule
Medicare Program; Home Health Prospective Payment System Rate Update for Calendar Year 2011; Changes in Certification Requirements for Home Health Agencies and Hospices; Proposed Rule
Modifications to the HIPAA Privacy, Security, and Enforcement Rules Under the Health Information Technology for Economic and Clinical Health Act
Program Integrity: Gainful Employment; Proposed Rule
Reply to the notification letter regarding a Small Business Advocacy Review Panel for the forthcoming regulatory proposal, for Stormwater Regulations to Address Discharges from Developed Sites
National Emission Standards for Hazardous Air Pollutants for Major and Area Sources: Industrial, Commercial, and Institutional Boilers
Enhanced Examination Timing Control Initiative
Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems)
Limitations on Subcontracting in Emergency Acquisitions
Identification of Non-Hazardous Secondary Materials That Are Solid Waste
Safety Standard for Bassinets and Cradles
Adoption of the 2010 Draft Report by the Inorganic Arsenic Cancer Review Work Group
Reply to the notification letter regarding regulatory proposal “New Source Performance Standards: Residential Wood Heaters”
Work Reserved for Performance by Federal Government Employees
Commending the Employee Benefits Security Administration (EBSA) for taking into account the concerns of the small business community in its announcement regarding new e-Signature Option for Forms 5500
Petition for Rulemaking to Amend the Commission’s Rules Governing Retransmission Consent
Injurious Wildlife Species; Listing the Boa Constrictor, Four Python Species, and Four Anaconda Species as Injurious Reptiles
Nondisplacement of Qualified Workers Under Service Contracts
Hazard Analysis and Critical Control Point (HAACP) system validation
Women-Owned Small Business Federal Contract Program; Proposed Rule
Effluent Limitations Guidelines and Standards for the Construction and Development Point Source Category
Occupational Injury and Illness Recording and Reporting Requirements
Medicare and Medicaid Programs; Electronic Health Record Incentive Program
Hazardous Materials: Transportation of Lithium Batteries
Endangered and Threatened Wildlife and Plants; Revised Designation of Critical Habitat for Bull Trout in the Coterminous United States
National Broadband Plan
Aircraft Repair Station Security
Small Business Size Regulations; 8(a) Business Development/Small Disadvantaged Business Status Determinations
Continuation of FHA Reform--Strengthening Risk Management Through Responsible FHA-Approved Lenders
Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rules
Improving Implementation of the Paperwork Reduction Act
Truth in Lending; Proposed Rule
Advance notice of proposed rulemaking; Stream Buffer Zone and Related Rules
Regulation of Tobacco Products; Request for Comments
Standards for Living Organisms in Ships' Ballast Water Discharged in U.S. Waters
Lead; Amendment to the Opt-out and Recordkeeping Provisions in the Renovation, Repair, and Painting Program
Exchange Visitor Program--General Provisions
Atlantic Herring Fishery
Magnuson-Stevens Fishery Conservation and Management Act; Regional Fishery Management Councils; Operations
Safety Management System; Advance notice of proposed rulemaking
Recommendations for Tax Reform
Fisheries of the Northeastern United States; Modification to the Gulf of Maine/Georges Bank Herring Midwater Trawl Gear Authorization Letter
Regulation of Fuels and Fuel Additives: Changes to Renewable Fuel Standard Program; Proposed Rule
Definition of Solid Waste Public Meeting
Registration of Mortgage Loan Originators
Payments Under Fixed-Price Architecture and Engineering Contracts
Lease Accounting Standards
Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act
Mandatory Reporting of Greenhouse Gases
Proposed Hazardous Air Pollution Standard for Reciprocating Internal Combustion Engines During Periods of Startup, Shutdown, and Malfunctione
Endangered and Threatened Wildlife and Plants; Revised Designation of Critical Habitat for the California Red-Legged Frog (Rana aurora draytonii)
Tracking Labels for Children's Products Under Section 103 of the Consumer Product Safety Improvement Act
Regulations Under the Genetic Information Nondiscrimination Act of 2008
Reply to the notification letter regarding a Small Business Advocacy Review Panel on the Occupational Safety and Health Administration’s Preliminary Draft Standard for Occupational Exposure to Diacetyl and Food Flavorings Containing Diacetyl
Oil Pollution Prevention; Non-Transportation Related Onshore Facilities; Spill Prevention, Control, and Countermeasure Rule; delay of effective date
Recovery and Reinvestment Act of 2009 Broadband Initiatives. Advocacy comments on the test for whether an applicant is a socially and economically disadvantaged small business of concern as defined under Section 8(a) of the Small Business Act
Recovery and Reinvestment Act of 2009 Broadband Initiatives. The FCC should consider the important role that small businesses play in creating a competitive, innovative telecommunications market that serves the public interest by providing more choice and lower prices
Rural Broadband Strategy
Medicare, Medicaid, and Clinical Laboratory Improvement Amendments of 1988 (CLIA) Program; Cytology Proficiency Testing (PT)
Large Aircraft Security Program, Other Aircraft Operator Security Program, and Airport Operator Security Program
Effluent Limitations Guidelines and Standards for the Construction and Development Point Source Category; Proposed Rule
Protection of Stratospheric Ozone: Ban on the Sale or Distribution of Pre-Charged Appliances and Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export
Early Warning Reporting Regulations
Handling of Animals; Contingency Plans
Reply to the notification letter regarding a Small Business Advocacy Review Panel for the proposed combined rulemaking on Industrial, Commercial, and Institutional Boilers.
Cranes and Derricks in Construction; Proposed Rule
Reply notification letter regarding Effluent Elimination Guidelines and Standards for the Construction and Development Point Source Category; Small Entity Representative Recommendations
Memorandum to John Spotila, Administrator, Office of Information and Regulatory Affairs, Office of Management and Budget, providing comments during Executive Order 12866 Interagency Review of Draft Final Rule Regarding Class V Underground Injection Control Wells (Safe Drinking Water Regulation).
Letter to Carol M. Browner, Administrator, EPA, regarding the Report of the Small Business Advocacy Review Panel for EPA's proposed rule for Federal Implementation Plans for Regional Reductions of Nitrogen Oxides.
Letter to Carol Browner, Administrator, EPA, regarding the Report of the Small Business Advocacy Review Panel convened for EPA's rulemaking Responding to Petitions Under Section 126 of the Clean Air Act.
Preliminary comments on EPA's proposed effluent guidelines for the transportation equipment cleaning industry
Letter to Thomas E. Kelly, Small Business Advocacy Chair, EPA, regarding implementation plans to reduce the Regional Transport of Ozone in the Eastern United States; Findings of Significant Contribution and Rulemaking on Seciton 126 Petitions.
Letter to Thomas E. Kelly, EPA, in response to notification letter regarding: National Primary Drinking Water Regulations: Ground Water Rule.; Small Business Regulatory Enforcement Fairness Act (SBREFA) small business advocacy review panel.
Letter to Thomas E. Kelly, EPA, in response to notification letter regarding: National Primary Drinking Water Regulations: Ground Water Rule. ; Small Business Regulatory Enforcement Fairness Act (SBREFA) small business advocacy review panel.
Letter to Thomas E. Kelly, EPA, replying to Small Business Regulatory Enforcement Act notification letter requesting small entity representatives for proposed rulemaking regarding Class V Underground Injection Wells under the Safe Water Drinking, 40 CFR Parts 144 and 146.
Thank you for superior implementation of Small Business Regulatory Enforcement Act panel process in recent proposal regarding effluent limitations (water pollution rule) affecting the industrial laundries industry; 40 CFR Part 441
Report of the Small Business Advocacy Review Panel convened on "Effluent Limitations Guidelines and Standards for the Transportation Equipment Cleaning Industry.
Letter to Carol M. Browner, Administrator, EPA, regarding the Report of the Small Business Advocacy Review Panel for EPA's proposed rule for Effluent Limitations Guidelines and Standards for the Centralized Waste Treatment Industry.
Regarding the report of the small business advocacy review panel convened for the EPA's proposed rulemaking, Effluent Limitations Guidelines and Pretreatment Standards for the Industrial Laundries Point Source Category
Regarding the Report of the Small Business Advocacy Review Panel for EPA's proposed rulemaking to revise the NPDES regulations under Clean Water Act Section 402(p)(6).
Letter to Thomas E. Kelly, Small Business Advocacy Chair, EPA, regarding Effluent Limitations Guidelines and Standards for the Centralized Waste Treatment Point Source Category, 40 CFR Part 437; Small Business Advocacy Panel
Regarding effluent limitations guidelines and standards for the transportation equipment cleaning point source category
Letter to Thomas E. Kelly, EPA, regarding effluent limitations guidelines and standards for the industrial laundries point source category, 40 CFR Part 441; SBREFA Small Business Advocacy Review Panel