June 27, 2003
                                
Mr. Robert E. Burt
Small Business Advocacy Chair
Occupational Safety and Health Administration
U. S. Department of Labor
200 Constitution Ave., NW
Washington, D.C. 20210

Subject: Electric Power Generation, Transmission and
Distribution; SBREFA Small Business Advocacy Panel

Dear Mr. Burt:

     In a letter dated April 1, 2003, you provided the Office of
Advocacy with official notice of the potential need to convene a
small business advocacy review panel for the above-captioned rule
under 609(b) of the Regulatory Flexibility Act, as amended by
the Small Business Regulatory Enforcement Fairness Act of 1996
(SBREFA).  The panel is now nearing completion.

     My office has worked closely with you and the panel members
representing the Occupational Safety and Health Administration
(OSHA) and the Office of Management and Budget's Office of
Information and Regulatory Affairs.  Although Advocacy responded
informally to your letter, we inadvertently failed to reply to in
writing.  As a matter of completing the record of the panel, I am
submitting this written response to document Advocacy's response
to your letter.

     As you know, Advocacy reviewed the list of small entity
representatives (SERs) suggested by OSHA and we suggested the
following additions: Mr. Charlie Tauzin of EP Breaux, Mr. Jeff
Kelly of Enterprise Electric, Mr. Dave McElvain of Hartts
Electric, Mr. Chuck Woodings of Anderson & Wood Construction Co.,
Mr. Clayton Spoon of Kohler Construction, and Ms. Sandy Grubb and
Mr. Bob McVeigh of Southeast Power Corp.  It is my understanding
that OSHA reviewed the potential SERs to ensure that only
regulated small entities were included, and the work went forward
with a panel of SERs capable of working with OSHA, the Office of
Management and Budget's Office of Information and Regulatory
Affairs, and the Office of Advocacy to address the issues that
are important to small businesses.

     In advance of convening of panel, you provided supporting
materials and a draft regulatory analysis and draft rule (see RFA
609(b)(4)), which were provided to the panel members for their
review. I understand that OSHA held several pre-panel meetings in
accordance with the most current OSHA SBREFA guidance to assure
that adequate and timely information and data were provided to
the small entity representatives and the panel representatives.

     Thank you for your continued support and advocacy for small
business issues. Please contact Charles Maresca of my staff at
(202) 205-6978 if you have any questions.
  
Sincerely,


Thomas M. Sullivan
Chief Counsel for Advocacy


  cc:  Dr. John D. Graham
     Administrator, Office of Information and Regulatory Affairs

     Mr. John Henshaw
     Assistant Secretary of Labor for Occupational Safety and
Health