Environmental Management Institute, Inc.

National technology transfer and advancement act

The Environmental Management Institute (EMI) respectfully submits these comments to the U.S. Environmental Protection Agency regarding its proposed renovation, repair and painting rule posted in docket no EPA-HQ-OPPT-2005-0049.

EPA has crafted a strong, proposed rule. It has adequately explained the proposed rule in the preamble.  And it has published a detailed economic analysis that sufficiently explains its decisions. While EMI believes that changes are needed to make the rule more effective and more protective, it recognizes the challenge EPA faced as it negotiated the complex maze of ten often conflicting statutory and executive orders that must be complied with in order to propose the rule.

In these comments, EMI addresses EPA’s analysis of its responsibilities pursuant to Section 12(d) of the National Technology Transfer and Advancement Act of 1995 (‘‘NTTAA’’).1 NTTAA “directs EPA to use voluntary consensus standards in its regulatory activities unless to do so would be inconsistent with applicable law or otherwise impractical. Voluntary consensus standards are technical standards (e.g.,materials specifications, test methods, sampling procedures, and business practices) that are developed or adopted by voluntary consensus standards bodies. The NTTAA directs EPA to provide Congress, through OMB, explanations when the Agency decides not to use available and applicable voluntary consensus standards.”

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