Environmental Management Institute, Inc.

Regulatory flexibility 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 vpreamble. 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 proposed rules with respect to its responsibilities under Regulatory Flexibility Act. EMI is concerned with two specific aspects of EPA’s analysis:

1. Consistency with Relevant Federal Rules; and
2.Consistency with Small Business Advocacy Review Panel’s Comments.

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