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 the recordkeeping and reporting requirements that would be imposed under the proposed rule pursuant to the Paperwork Reduction Act. EPA concluded that it has “carefully tailored the proposed reporting and recordkeeping requirements so they will permit the Agency to achieve statutory objectives without imposing an undue burden on those entities that choose to be involved in covered activities.”