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Regulatory Comment Letters
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The U.S. Small Business Administration’s (SBA) Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA) proposed rule, “Financial Responsibility Requirements for the Hardrock Mining Industry.” The proposed rule would impose costly requirements on hardrock mines owned by small firms, without evidence that a problem exists warranting intervention. The proposal requires mines to acquire financial assurance coverage (i.e. insurance) to cover potential liabilities for releases of hazardous substances from a mine. However, these small mines are already highly regulated by robust state and Federal programs. New Federal standards risk damaging these programs which have, in recent years, effectively addressed the same issues at modern small mines. Further, EPA missed the opportunity to receive important feedback from small businesses through the Small Business Regulatory Enforcement Fairness Act (SBREFA) panel process and did not consider less costly regulatory alternatives as required by the Regulatory Flexibility Act (RFA).
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The U.S. Small Business Administration’s (SBA) Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA) proposed rule, “TSCA Reporting and Recordkeeping Requirements; Standards for Small Manufacturers and Processors.” Advocacy agrees that revisions to the current size standard definitions under the TSCA 8(a) reporting requirements are warranted. However, Advocacy believes that EPA has proposed this determination without fully examining all factors relevant to setting an appropriate small business size standard. Advocacy recommends EPA consider a significantly broader set of factors in its development of size standards under TSCA and recommends that EPA engage in a robust consultation with affected small entities. Advocacy further suggests that EPA should convene a Small Business Advocacy Review panel under 5 U.S.C. 609(b) to help address this challenging issue.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) respectfully submits the following comments in response to the State Department’s proposed rule, “Intercountry Adoptions.” Advocacy is concerned that the State Department did not consider and include all of the potential costs in the Regulatory Flexibility Act (RFA) section of the rule, and therefore, the certification was improper under the RFA. Advocacy commends the State Department for requesting comment on the cost of compliance with the Country-Specific Authorization provision. However, Advocacy has heard from small adoption agencies concerned about the ambiguity of the proposed rule and the uncertainty of how the rule will be applied. Advocacy recommends the State Department either re-propose the rule when more information can be provided, or submit a supplemental notice of proposed rulemaking with a proper RFA analysis.
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The Office of Advocacy (Advocacy) offers the following comment to the Internal Revenue Service (IRS) in response to the above-referenced proposed rules issued on August 4, 2016. The proposed rules relate to the valuation of interests in a closely-held partnership or corporation for estate, gift, and generation-skipping transfer tax purposes. Because the IRS certified that the proposed rules will not have a significant economic impact on a substantial number of small entities, and because the statement in support of the certification lacks a factual basis, Advocacy recommends that the IRS publish for public comment either a supplemental Regulatory Flexibility Act (RFA) assessment with a valid factual basis or an Initial Regulatory Flexibility Analysis (IRFA). Advocacy also encourages the IRS to extend the comment period for the proposed regulations by 60 days.
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The Office of Advocacy (Advocacy) of the U.S. Small Business Administration respectfully submits this comment letter to the United States Citizenship and Immigration Service (USCIS) of the Department of Homeland Security (DHS) for the International Entrepreneur Rule. Advocacy applauds USCIS for undertaking this initiative that would allow international entrepreneurs to utilize the parole program to stay temporarily in the United States to grow their start-up businesses and create U.S. jobs.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits these comments on the proposed rule on the Consumer Financial Protection Bureau (CFPB or the Bureau) Payday, Vehicle Title, and Certain High-Cost Installment Loans. Advocacy is concerned that the economic impact of the proposed rule on small entities and consumers may be greater than what is indicated in the CFPB’s Regulatory Flexibility Act (RFA) analysis. Advocacy encourages the CFPB to reevaluate the economic impact in RFA section of the proposed rule and consider less burdensome alternatives for small entities.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Animal & Plant Health Inspection Service’s (APHIS) proposed rule, “Horse Protection; Licensing of Designated Qualified Persons and Other Amendments.” Advocacy urges APHIS to extend the public comment period for an additional 60 days to allow small businesses and their representatives to fully and meaningfully participate in this important rulemaking.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Department of Energy’s (DOE) June 17, 2016 notice of proposed rulemaking on “Energy Conservation Standards for Manufactured Housing.” After conducting outreach with small business stakeholders, Advocacy has concerns that DOE's proposal will have a disproportionate impact on small manufacturers of manufactured homes. Advocacy recommends that DOE present and analyze significant alternatives, and adopt a regulatory alternative to the proposed standard that will minimize the economic impact to small manufacturers.
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The Office of Advocacy respectfully requests that Secretary Pritzker designate a Commerce representative to participate in any future Interagency Working Group (IWG) and provide this individual’s contact information to Advocacy as soon as possible. The Trade Facilitation and Trade Enforcement Act (TFTEA) requires that the IWG includes a representative from the U.S. Department of Commerce (Commerce) in addition to representatives from the Office of U.S. Trade Representative (USTR) and the U.S. Department of Agriculture (USDA).
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The Office of Advocacy respectfully requests that Secretary Vilsack designate a USDA representative to participate in any future Interagency Working Group (IWG) and provide this individual’s contact information to Advocacy as soon as possible. The Trade Facilitation and Trade Enforcement Act (TFTEA) requires that the IWG includes a representative from the U.S. Department of Agriculture (USDA) in addition to representatives from the Office of U.S. Trade Representative (USTR) and the U.S. Department of Commerce (Commerce).
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The Office of Advocacy respectfully requests that Ambassador Froman designate a USTR representative to participate in any future Interagency Working Group (IWG) and provide this individual’s contact information to Advocacy as soon as possible. The Trade Facilitation and Trade Enforcement Act (TFTEA) requires that the IWG includes a representative from the Office of U.S. Trade Representative (USTR) in addition to representatives from the U.S. Department of Agriculture (USDA) and the U.S. Department of Commerce (Commerce).
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) respectfully submits this ex parte letter to the Federal Communications Commission (FCC) regarding the above- referenced proceeding. After conducting outreach with small business stakeholders and reviewing the comments filed with the FCC on their behalf, our office has concerns that the FCC’s proposed rules will be disproportionately and significantly burdensome for small Broadband Internet Access Service (BIAS) providers. Given the impact of the proposed rules on small BIAS providers, Advocacy recommends that the FCC adopt measures to mitigate the disproportionate impact of compliance on small BIAS providers.
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The Office of Advocacy (Advocacy) offers the following comment to the Internal Revenue Service (IRS) in response to the above-referenced proposed rules issued on April 18, 2016. The proposed regulations would update the IRS requirements related to the Highway Revenue Act of 1982. Because the IRS certified that the collection of information in the proposed regulations will not have a significant economic impact on a substantial number of small entities, and because the statement in support of the certification lacks a factual basis, Advocacy recommends that the IRS publish for public comment either a supplemental Regulatory Flexibility Act (RFA) assessment with a valid factual basis or an Initial Regulatory Flexibility Analysis (IRFA). Advocacy also encourages the IRS to extend the comment period for the proposed regulations by 60 days.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) respectfully submits this ex parte letter to the Federal Communications Commission (FCC) regarding the above- referenced proceeding. After conducting outreach with small business stakeholders and reviewing the comments filed with the FCC on their behalf, our office has concerns that the FCC’s proposed rules will be disproportionately and significantly burdensome for small multi-channel video programming distributors (MVPDs). Given the impact of the proposed rules on small MVPDs, and the fact that the FCC can achieve its regulatory goals without their compliance, we believe the FCC should exempt small MVPDs when it finalizes its new rules under Section 629 of the Communications Act.
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The U.S. Small Business Administration's (SBA) Office of Advocacy (Advocacy) submits the following comments on the Federal Motor Carrier Safety Administration’s (FMCSA’s) Proposed Carrier Safety Fitness Determination (SFD) Rule. FMCSA’s proposed rule would implement a new statistical measuring program designed to determine which motor carriers are “fit” to operate in interstate commerce and which ones are not. There are some 503,000 small business motor carriers (493,000 property and 10,000 passenger) representing nearly ninety-nine percent of the motor carrier industry. Advocacy recommends that FMSCA fully assess the validity of its proposed SFD methodology and whether it will have a disproportionate impact on small carriers, consider significant alternatives to the proposed rule, and await the conclusion of a Congressionally-mandated study by the National Research Council of the National Academies of Science (NAS) before finalizing a new rule.
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The U.S. Small Business Administration's Office of Advocacy (Advocacy) submits the following comments in response to the Food and Nutrition Services' (FNS) proposed rule, "Enhancing Retailers Standards in the Supplemental Nutrition Assistance Program (SNAP)."Advocacy was contacted by small convenience store operators and their food suppliers who believe the rule will have a significant economic impact on their businesses. This letter is meant to bring those small business concerns to the attention of the FNS. Also, Advocacy recommends that as it finalizes this rule, FNS improve its regulatory flexibility impact analysis and consider reasonable regulatory alternatives that will minimize the impact of the rule on affected small businesses.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA) proposed rule, “Accident Release Prevention Requirements: Risk Management Programs under the Clean Air Act.” Accident prevention and safety precautions are a priority for small business facilities that use and distribute hazardous chemicals to protect both the public and their employees. Small businesses, however, are concerned that the rule will impose unnecessary burdens on them and that alternatives exist that will reduce the economic impact of the rule on small entities while still accomplishing the agency’s objective. Advocacy urges EPA to carefully address the small business concerns and to provide flexibility to reduce the impact of the proposed rule on the small businesses.
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The Office of Advocacy (Advocacy) thanks the Internal Revenue Service (IRS) and the Department of Treasury (Treasury) for the above-referenced announcement, issued on April 14, 2016, that withdraws certain provisions of proposed regulations published on January 29, 2016, relating to nondiscrimination requirements applicable to qualified retirement plans. The IRS and Treasury are withdrawing the provisions of the proposed regulations that would have added a "reasonable business" classification requirement for a nondiscrimination test.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits these comments on the proposed rule on Magnuson-Stevens Fishery Conservation and Management Act; Seafood Import Monitoring Program. Advocacy is concerned that the economic impact the proposal may have on small entities has not been fully analyzed. Advocacy encourages the National Marine Fisheries Service (NMFS), National Oceanic and Atmospheric Administration (NOAA) to reevaluate the costs in the Regulatory Flexibility Act (RFA) section of the proposed rule, analyze the full economic impact that this rulemaking may have on small entities, and consider less burdensome alternatives for small entities.
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The Office of Advocacy (Advocacy) of the U.S. Small Business Administration respectfully submits this comment letter to the Department of Labor (DOL) for the proposed rule, Establishing Paid Sick Leave for Federal Contractors.
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The Office of Advocacy submits these comments to the Fish and Wildlife Service’s (the Service) proposed rule entitled Injurious Wildlife Species: Listing Salamanders Due to Risk of Salamander Chytrid Fungus (the Interim Rule). Advocacy is concerned that the Interim Rule will impose a significant economic impact on a substantial number of small businesses, an economic burden on small business, and suggests that the alternative of prohibiting the importation of salamanders yet allowing the interstate transport within the continental U.S. would reduce that burden and support the Service’s goal of preventing the spread of chytrid fungus.
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The Office of Advocacy (Advocacy) of the U.S. Small Business Administration respectfully requests that the Department of Labor (DOL) extend by 30 days the comment period for this proposed rule, which requires certain parties that contract with the Federal Government to provide their employees with up to 7 days of paid sick leave, including paid leave allowing for family care. The proposed rule implements Executive Order 13706, signed by President Barack Obama on September 7, 2015. The Executive Order directs the Secretary of Labor (Secretary) to issue regulations by September 30, 2016.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Department of Defense’s interim final rule, “Defense Federal Acquisition Regulation Supplement: Network Penetration Reporting and Contracting for Cloud Services (DFARS Case 2013-D018).' Advocacy believes DOD has underestimated the substantial number of small businesses affected by this rulemaking and the significant economic impact of compliance. Advocacy recommends that DOD include small businesses serving as prime contractors and as subcontractors in their estimation of the number of impacted small entities. Advocacy also recommends that DOD consider alternatives, such as collaborating with universities or other organizations to provide low-cost cybersecurity services to small businesses, or providing a one-time subsidy to small businesses to help cover the cost of initial consultations with third-party vendors.
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The United States Department of Veterans Affairs (VA) is proposing to amend its current regulations governing the Veteran-Owned Small Business Verification Program. This program has been under review by the U.S. Government Accountability Office (GAO) and the VA’s Office of Inspector General. Numerous congressional hearings have also been held regarding the implementation of the verification program.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to Environmental Protection Agency’s (EPA’s) October 23, 2015, notice of proposed rulemaking, “Federal Plan Requirements for Greenhouse Gas (GHG) Emissions From Electric Utility Generating Units Constructed on or Before January 8, 2014; Model Trading Rules; Amendments to Framework Regulations.” Advocacy believes that EPA’s Initial Regulatory Flexibility Analysis (IRFA) and other related analyses do not provide small entities sufficient information to understand the likely economic impacts or evaluate reasonable regulatory alternatives. Advocacy strongly recommends that, for each state that does not submit an acceptable state implementation plan for the Clean Power Plan, EPA re-propose a federal plan and develop a supplemental IRFA for each one.
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The Office of Advocacy at the U.S. Small Business Administration (Advocacy) respectfully submits the following comments on the Environmental Protection Agency’s (EPA) proposed changes to the existing regulations for the certification of applicators of restricted use pesticides (RUPs). Small businesses are concerned that the rule will impose unnecessary and unjustified burdens on them and that alternatives exist that would reduce the economic impact of the rule on small entities while still accomplishing the agency’s objectives.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Department of Energy’s (DOE) August 19, 2015, notice of proposed rulemaking on “Energy Conservation Standards for Refrigerated Bottled or Canned Beverage Vending Machines.” Small manufacturers are concerned that DOE's proposal for beverage vending machines (BVM) are neither technologically nor economically feasible within the three year period prescribed by DOE. Advocacy recommends that DOE either adopt a lower Trial Standard Level (TSL) or use its discretion to adopt a regulatory alternative to the proposed standard that is achievable for small manufacturers.
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The Office of Advocacy (Advocacy) offers the following comments to the Department of Defense (DOD) in response to the above-referenced rulemaking issued on September 21, 2015. The proposed rule would require contractors, both large and small, who are not the original manufacturer to have a risk-based system to trace electronic parts from the original manufacturer to product acceptance by the Government. If such traceability is not feasible for a particular part, the contractor system must provide for the consideration of an alternative part or utilization of tests and inspections in order to avoid counterfeit electronic parts. The rule also requires the contractor to notify the contracting officer if the part cannot be obtained from a trusted supplier. If such cannot be obtained from a trusted supplier and after notification to the contracting officer, the contractor is responsible for inspection, testing, and authentication, in accordance with existing applicable industry standards. This rule will also apply to commercial contractors. In general, the Government has made a determination that Commercially Off the Shelf Items (COTS) are not bound by the same acquisition regulations as other items unless there is a determination that it is in the best interest of the Government for federal acquisition regulations to apply. DOD has determined that COTS items will be covered by this regulation. Finally the contractor assumes responsibility for the authenticity of parts provided by suppliers.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to Environmental Protection Agency’s (EPA’s) August 27, 2015, notices of rulemaking on air emission standards for Municipal Solid Waste (MSW) Landfills under section 111 of the Clean Air Act. These notices are (1) a supplemental proposed rule for its July 17, 2014, proposal to revise the New Source Performance Standards (NSPS) for MSW Landfills under section 111(b), and (2) a notice of proposed rulemaking (NPRM) on Emission Guidelines for existing MSW Landfills under section 111(d).
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The Office of Advocacy submits these comments to the Fish and Wildlife Service’s (the Service) proposed rule entitled “Endangered and Threatened Wildlife and Plants; Revision of the Section 4(d) Rule for the African Elephant."
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The Office of Advocacy (Advocacy) respectfully submits these comments to the Federal Communications Commission (FCC) regarding the small business exemption from enhanced transparency requirements adopted in the 2015 Open Internet Order. Advocacy commends the FCC for acknowledging the disproportionate compliance burden that small broadband providers face under the rules, and encourages the FCC to continue to exempt small businesses from the requirements. Advocacy also encourages the FCC to use existing Small Business Administration (SBA) size-standards to determine the appropriate small business threshold for the exemption.
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The Office of Advocacy of the U.S. Small Business Administration respectfully submits these comments to the Department of Labor (DOL) for this proposed rule, which amends the regulations under the Fair Labor Standards Act (FLSA) governing the “white collar” exemption from overtime pay for executive, administrative and professional employees. The proposed rule implements a 2014 Presidential Memorandum that directed DOL to update and modernize these overtime regulations. Advocacy held a number of small business listening sessions and roundtables across the country, and this letter will outline small business comments, concerns and recommendations regarding this proposal.
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The Office of Advocacy (Advocacy) offers the following comments to the Federal Acquisition Council (FAR) in response to the above-referenced rulemaking issued on May 28, 2015. The proposed rule would require agencies to review a contractor’s prior three-year history of compliance with fourteen Federal labor laws or any equivalent state laws in determining contractor responsibility. To accomplish this review, the proposed rule would impose new and significant reporting and recordkeeping requirements on prime and subcontractors. The proposed rule would also impose new paycheck and complaint dispute transparency requirements on contractors and subcontractors. This provision is designed to ensure workers are given the necessary information each pay period so that they can verify the accuracy of what they are paid. The proposed rule would require an offeror, for any solicitation estimated to exceed $500,000, to represent whether it has had any administrative merits determinations, arbitral awards or decisions, or civil judgments rendered against it within the preceding three years for violations of the fourteen specific Federal labor laws or equivalent state laws.
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The Office of Advocacy (Advocacy) offers the following comments to the Department of Labor (DOL) in response to the above-referenced guidance document issued on May 28, 2015. The Executive Order directs DOL to develop guidance to assist federal agencies in implementing the Order’s requirements. In accordance with this direction, the proposed guidance defines administrative merits determinations, civil judgment and arbitral award or decisions and provides guidance on what information related to these determinations must be reported by contractors and subcontractors. The document provides guidance to the Contracting Officers (CO) and to Labor Compliance Advisors (LCA) as to how to assess reported labor law violations. In addition the guidance document ensures that DOL will work with LCAs agencies to minimize the information that contractors have to provide.
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The Office of Advocacy of the U.S. Small Business Administration respectfully requests that the Department of Labor (DOL) extend by 90 days the comment period for this proposed rule, which amends the regulations under the Fair Labor Standards Act (FLSA) governing the “white collar” exemption from overtime pay for executive, administrative and professional employees. The rule implements a March 2014 Presidential Memorandum directing DOL to modernize and streamline existing overtime regulations. In the proposed rule, DOL would change the salary threshold for employees who are eligible to receive overtime pay, from $23,660 to $50,440. This salary threshold will also be updated every year in the Federal Register.
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The Office of Advocacy at the U.S. Small Business Administration (Advocacy) respectfully submits the following comments on the Environmental Protection Agency’s (EPA) reporting and recordkeeping requirements for certain chemical substances when they are manufactured or processed at the nanoscale. Small businesses are concerned that the rule will impose unnecessary and unjustified burdens on them and that alternatives exist that will reduce the economic impact of the rule on small entities while still accomplishing the agency’s objective.
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On July 17, 2015, the Office of Advocacy submitted a comment letter to the Employee Benefits Security Administration (EBSA) in response to the agency’s April 14, 2015 proposed rule, Definition of the Term "Fiduciary"; Conflict of Interest Rule--Retirement Investment Advice. The proposed rule would expand the definition of “fiduciary” of an employee benefit plan by providing investment advice to a plan, its participants, or beneficiaries. The proposal would extend the fiduciary standard of care to all advisers of workplace retirement plans and IRAs. The proposed rule would require these advisers to disclose any potential conflicts of interests and the proposal would again prohibit advisers from engaging in certain transactions.
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The Office of Advocacy, U.S. Small Business Administration (“Advocacy”) respectfully submits this ex parte letter to the Federal Communications Commission (FCC) regarding the above-referenced Notice of Proposed Rulemaking in the Emerging Wireline Networks and Services proceeding. Advocacy encourages the Commission to adopt policies governing network transitions that will ensure the ability of small competitive carriers to meet the demand that small businesses have for competitive choices in wireline service.
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The Office of Advocacy, U.S. Small Business Administration (“Advocacy”) respectfully submits this ex parte letter regarding a meeting attended by Assistant Chief Counsel Jamie Saloom and Director for Interagency Affairs Charles Maresca with the following FCC staff on June 11, 2015: Bill Lake, Media Bureau Chief; Joyce Bernstein and Shaun Maher, staff attorneys in the Media Bureau’s Video Division; David Konczal from the Office of General Counsel; and Thomas Reed, Director of the Office of Communications Business Opportunities. During the meeting Advocacy staff forwarded the concerns of small Low-Power Television licensees with regard to the upcoming broadcaster incentive auction.
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The Office of Advocacy, U.S. Small Business Administration (“Advocacy”) respectfully submits this ex parte filing regarding a number of proposed changes to the Federal Communications Commission’s Part 1 competitive bidding rules. On June 4, 2015, Assistant Chief Counsel for Advocacy Jamie Saloom met with the following staff in the FCC’s Wireless Telecommunications Bureau: Gary Michaels, Sue McNeil, Margaret Wiener, and Leslie Barnes. During the meeting Advocacy discussed ways in which the FCC can amend its rules to improve its auction policies to encourage greater competition and small business entry and growth in the wireless marketplace.
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The Office of Advocacy (Advocacy) of the U.S. Small Business Administration (SBA) submits the following comments to the Department of Labor (DOL) regarding its proposed rule, which amends regulations under the H-2A program to codify procedures for hiring temporary agricultural foreign workers for job opportunities in sheepherding, goat herding and the production of livestock on the open range.
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On December 18, 2014, the United States Food and Drug Administration (FDA) published a proposed rule titled: Electronic Distribution of Prescribing Information for Human Prescription Drugs, Including Biological Products. The Office of Advocacy (Advocacy) urges the FDA to improve its small business impact analysis as required under the RFA and to entertain additional regulatory alternatives designed to lessen the economic impacts of this regulation on small entities.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Department of Energy’s (DOE’s) February 9, 2015, notice of proposed rulemaking on “Energy Conservation Standards for Hearth Products.” Many small manufacturers have concerns about DOE’s proposal for hearth products, and Advocacy recommends that DOE more clearly determine small business impacts in its Initial Regulatory Flexibility Act Analysis (IRFA), and use its discretion to adopt a regulatory alternative to the proposed standard that is achievable for small manufacturers.
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On April 30, 2015, EPA convened a Small Business Advocacy Review (SBAR) panel on its upcoming rulemaking, “Federal Plan Requirements for Greenhouse Gas Emissions from Electric Utility Generating Units Constructed on or Before January 8, 2014.” The Office of Advocacy (Advocacy) believes that EPA has not prepared sufficient materials to convene this panel. EPA has not provided the other panel members with information on the potential impacts of this rule and has not provided Small Entity Representatives (SERs) with the necessary information upon which to discuss alternatives and provide recommendations to EPA, as required by the Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA). Due to this lack of information, any panel conducted under these circumstances is unlikely to succeed at identifying reasonable regulatory alternatives for small businesses.
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The U.S. Small Business Administration's (SBA) Office of Advocacy (Advocacy) submits the following comments on the General Services Administration (GSA) proposed rule on Transactional Data Reporting. The rule would amend GSA’s regulations to create a transactional data reporting clause. The proposed rule would require contractors to report prices paid for products and services delivered during the performance of a federal contract. The proposed rule would create an online reporting system for contractors to report such pricing data. The requirement would apply immediately to GSA’s government-wide non Federal Supply Schedules (FSS) vehicles, where transactional data is not already collected through other methods. For FSS vehicles, the reporting clause would be introduced in phases, beginning with a pilot for selected products and commoditized services. The proposed rule is to create a Common Acquisition Platform (CAP), an online marketplace to identify best-in-class contracts issued by GSA or other agencies.
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The U.S. Small Business Administration's (SBA) Office of Advocacy (Advocacy) submits the following comments on the Federal Aviation Administration’s (FAA’s) Proposed Operation and Certification of Small Unmanned Aircraft Systems (Small UAS) Rule. FAA’s proposed Small UAS rule would amend FAA’s regulations to allow the operation of small UAS (less than 55 lbs.) for non-hobby and non-recreation uses in the National Airspace System (NAS). The proposed rule would specifically address the operation of small UAS, the testing and certification of operators, UAS registration, and the display of registration markings. While the proposed rule would reduce barriers for small UAS use for commercial, private, and research purposes, it also includes significant operational restrictions that are a concern for small business. The proposed rule would not require airworthiness certification for small UAS covered by the proposed rule. The proposed rule also considers whether FAA should adopt a special category of micro-UAS (less than 4.4 lbs.) and would prohibit model aircraft from endangering the safety of the NAS.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA’s) January 22, 2015, notice of proposed rulemaking on “Revisions to the National Oil and Hazardous Substances Pollution Contingency Plan; Subpart J Product Schedule Listing Requirements.”This rule would revise the testing requirements for listing products that may be used to mitigate the effects of oil spills covered by the National Contingency Plan (NCP). Advocacy has concerns about the impact this rule will have on small businesses and believes that EPA lacks a factual basis upon which to certify that this rule would not have a significant economic effect on a substantial number of small entities. In particular, Advocacy is concerned that EPA has underestimated the number of small businesses that will be adversely affected by new testing requirements and underestimated the other costs that will be imposed on small businesses, such as research and development, lost intellectual property, and lost sales due to removal from the NCP schedule. Advocacy recommends EPA re-propose this rule after conducting an Initial Regulatory Flexibility Analysis and considering small business flexibilities to minimize the impact on small businesses consistent with the NCP and EPA’s mission.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Department of Energy’s (DOE’s) February 4, 2015, notice of proposed rulemaking on “Energy Conservation Standards for Commercial Warm Air Furnaces.” One small manufacturer has concerns about DOE’s proposal for gas-fired commercial warm air furnaces, and Advocacy recommends that DOE use its discretion to adopt a regulatory alternative to the proposed standard that is achievable for this small manufacturer.
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The Office of Advocacy (Advocacy) offers the following comment to the Internal Revenue Service (IRS) in response to the above-referenced revenue procedure issued on February 13, 2015. Rev. Proc. 2015-20 provides guidance on accounting requirements, commonly referred to as the “repair regulations,” related to the acquisition, production, or improvement of tangible property. The repair regulations direct when businesses must capitalize purchases of property and when businesses are permitted to deduct expenses in the year the businesses incur the expenditure. The IRS issued Rev. Proc. 2015-20 with the intent to make it easier for business owners to comply with the repair regulations. The revenue procedure also requested comment on whether the $500 safe harbor threshold contained in the repair regulations should be raised. Advocacy commends the IRS for simplifying compliance with the repair regulations. However, based on feedback from small businesses, Advocacy strongly encourages the IRS to increase the $500 safe harbor threshold.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA’s) December 18, 2014, notice of proposed rulemaking on “National Emission Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Clay Product Manufacturing.”
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits these comments on the proposed rule on Limitations on Terms of Consumer Credit Extended to Service Members and Dependents. Advocacy is concerned that the proposal may impose an undue burden on small entities. Advocacy encourages the Department of Defense (DoD) to reevaluate the certification in the Regulatory Flexibility Act (RFA) section of the proposed rule and to prepare an initial regulatory flexibility analysis (IRFA), if warranted. Advocacy further encourages DoD to consider less burdensome alternatives for small entities.
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The Office of Advocacy (Advocacy) of the U.S. Small Business Administration (SBA) submits the following comments to the Department of Justice (the Department) regarding this proposed rule, which would require movie theaters to exhibit 100 percent of showings with closed captioning and audio description whenever movies are produced with this capacity unless to do so would result in an undue burden or fundamental alteration. This rule, which amends regulations implementing Title III of the Americans with Disabilities Act (ADA), would require movie theaters to purchase hardware and a number of individual accessibility devices.
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On behalf of the Office of Advocacy, I am writing to bring to your attention the concerns of small manufacturers regarding the Department of Energy’s (DOE) Appliance and Equipment Standards program. Advocacy supports the Department’s efforts to fulfill the mandate of the Energy Policy Conservation Act (EPCA) to reduce national energy consumption through the development of energy efficiency standards; however, Advocacy has concerns about the cumulative and disproportionate impact that DOE’s standards may be having on small manufacturers. DOE has recently proposed and adopted several energy efficiency regulations that will have significant economic impacts on small business manufacturers, according to DOE’s own analyses. Most recently, small manufacturers have expressed concerns regarding DOE’s proposed efficiency standards for automatic commercial ice makers. Advocacy recommends that DOE use its discretion to adopt an alternative to the proposed standard that is achievable for small manufacturers. Additionally, Advocacy recommends that DOE give similar consideration to small manufacturers in all future energy efficiency rulemakings.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to Environmental Protection Agency’s (EPA’s) June 30, 2014, notices of proposed rulemaking on “Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards.” Small refiners have concerns about EPA’s proposal for fenceline monitoring, and Advocacy believes that EPA should adopt regulatory alternatives to reduce the burden of this requirement on small entities.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits these comments on the proposed rule on Home Mortgage Disclosure (Regulation C). Advocacy is concerned that the rule as proposed imposes an undue burden on small businesses, and encourages the Consumer Financial Protection Bureau (CFPB) to consider less burdensome alternatives as suggested by small entities in the home mortgage industry.
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On July 23, 2014, the Consumer Product Safety Commission (CPSC) published a proposed rule titled: Safety Standard for Sling Carriers. I am writing with regard to the above-captioned rule. The Office of Advocacy believes the CPSC should revisit its analysis of the small business impacts of this regulation, be more transparent about the data and assumptions underlying the projected costs and benefits, and consider additional alternatives that would minimize the impacts of rule on small businesses while still allowing the Commission to achieve its regulatory goals.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits these comments regarding the proposed rule to the U.S. Army Corps of Engineers (the Corps) and the Environmental Protection Agency (EPA, and together, “the agencies”). Advocacy believes that EPA and the Corps have improperly certified the proposed rule under the Regulatory Flexibility Act (RFA) because it would have direct, significant effects on small businesses. Advocacy recommends that the agencies withdraw the rule and that the EPA conduct a Small Business Advocacy Review panel before proceeding any further with this rulemaking.
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The Office of Advocacy (Advocacy) respectfully submits this ex parte letter to encourage the Federal Communications Commission (FCC) to reach out to small businesses as it works through the above referenced dockets, and to encourage the FCC to utilize the Regulatory Flexibility Act (RFA) as a tool for analyzing the small business impacts of its decision making.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to Environmental Protection Agency’s (EPA’s) July 17, 2014, notices of rulemaking on air emission standards for Municipal Solid Waste (MSW) Landfills under section 111 of the Clean Air Act. These notices are (1) a proposed rule to revise the New Source Performance Standards (NSPS) for MSW Landfills under section 111(b), and (2) an advance notice of proposed rulemaking (ANPRM) on Emission Guidelines for existing MSW Landfills under section 111(d).
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The Office of Advocacy at the U.S. Small Business Administration (Advocacy) respectfully submits the following comments on the Environmental Protection Agency’s (EPA) rulemakings on Agricultural Worker Protection Standard Revisions for pesticides.
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On July 31, 2014, the Office of Advocacy’s Chief Counsel, Dr. Winslow Sargeant, sent a letter to the Food and Drug Administration’s (FDA) Commissioner, Dr. Margaret Hamburg, suggesting improvements in the agency’s Regulatory Flexibility Act analyses.
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The Office of Advocacy (Advocacy) of the U.S. Small Business Administration (SBA) is pleased to submit these comments to the Wage and Hour Division of the U.S. Department of Labor (DOL) regarding its proposed rule, Establishing a Minimum Wage for Federal Contractors.Printer Friendly Version Fact Sheet
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The Office of Advocacy at the U.S. Small Business Administration (Advocacy) respectfully submits these comments to the Department of the Interior, U.S. Fish and Wildlife Service (FWS) regarding its proposal to list five species of snakes as injurious reptiles under the Lacey Act.
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The Office of Advocacy (Advocacy) offers the following comment to the Department of Labor (DOL) to respectfully request that the department extend the comment period for the proposed rule, Establishing a Minimum Wage for Federal Contractors. This rule, which implements Executive Order 13658, increases the hourly minimum wage for federal contractors, subcontractors and their workers to $10.10 per hour, beginning January 1, 2015.
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The Office of Advocacy (Advocacy) offers the following comment to the Food and Drug Administration (FDA) in response to the above-referenced proposed rule issued on April 24, 2014. The FDA issued the proposed rule to implement provisions of the Family Smoking Prevention and Tobacco Control Act of 2009 (Tobacco Control Act). Since the passage of the Tobacco Control Act, small businesses that manufacture or market tobacco products have been in contact with Advocacy in anticipation of this rulemaking.
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The Office of Advocacy (Advocacy) offers the following comment to the Food and Drug Administration (FDA) in response to the above-referenced proposed rule issued on April 24, 2014. The FDA issued the proposed rule to implement provisions of the Family Smoking Prevention and Tobacco Control Act of 2009 (Tobacco Control Act). Since the passage of the Tobacco Control Act, small businesses that manufacture or market tobacco products have been in contact with Advocacy in anticipation of this rulemaking.
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The Office of Advocacy of the U.S. Small Business Administration respectfully requests that the U.S. Army Corps of Engineers and the Environmental Protection Agency (together the “Agencies”) extend the comment period for the proposed rule Definition of Waters of the United States Under the Clean Water Act.
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The Office of Advocacy of the U.S. Small Business Administration respectfully requests that the National Oceanic and Atmospheric Administration (NOAA) and the U.S. Fish and Wildlife Service (FWS) extend the public comment period for its proposed rule Definition of Destruction or Adverse Modification of Critical Habitat.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to Environmental Protection Agency’s (EPA’s) April 8, 2014 notice reopening the comment period on its rulemakings on Formaldehyde Emissions Standards for Composite Wood Products. These comments supplement Advocacy’s submission to the docket dated August 21, 2013.
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I am writing you for two reasons. First, I want to commend certain Food and Drug Administration (FDA) employees for the important contributions made by them during small business roundtables hosted by impacted industries designed to disseminate information and to answer questions on the Food Safety Modernization Act rules. Secondly, I want to inform you of some small business concerns with the above-captioned rule. It is my hope that the FDA will consider the affected industries’ comments and take them into consideration as the agency finalizes the proposed rule.
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On behalf of the U.S. Small Business Administration Office of Advocacy, I am writing to urge the Federal Communications Commission to move forward and strengthen protections for small multichannel video programming distributors (MVPDs) under the Cable Television Consumer Protection and Competition Act of 1992 (Cable Act) by finalizing certain revisions to the Commission’s Program Access Rules. In light of increasing vertical integration between cable programmers and distributors, including the anticipated acquisition of Time Warner Cable by Comcast/NBCU, small MVPDs have asked Advocacy to raise their concerns regarding the FCC’s program access rules and support reasonable revisions that would better protect small MVPDs from discriminatory pricing in cable programming. Printer Friendly Version Fact Sheet
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The U.S. Small Business Administration's Office of Advocacy (Advocacy) submits the following comments on the Occupational Safety and Health Administration’s (OSHA’s) Proposed Occupational Exposure to Respirable Crystalline Silica Rule. OSHA’s proposed rule would establish a new permissible exposure limit (PEL) and action level for respirable crystalline silica and impose a host of ancillary requirements, such as exposure assessments, medical monitoring, engineering and work practice controls, personal protective equipment, respiratory protection (when engineering and work practice controls are insufficient to meet the PEL), training, and recordkeeping. A more detailed discussion of the proposed rule is provided below.
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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 issued on October 23, 2013. The SEC issued the proposed rule to implement Title III of the JOBS Act, which established the foundation for a regulatory structure for startups and small businesses to raise capital through securities offerings using the Internet through crowdfunding. On December 16, 2013 and January 15, 2014, Advocacy hosted small business roundtables to receive feedback from small business representatives about the proposed rule. Advocacy also hosted several conference calls to hear input from small business. Based upon this feedback from small business stakeholders, Advocacy is concerned that the Initial Regulatory Flexibility Analysis (IRFA) contained in the proposed rule lacks essential information required under the Regulatory Flexibility Act (RFA). Specifically, the IRFA does not adequately describe the costs of the proposed rule on small entities, and the IRFA does not set forth significant alternatives which accomplish the stated SEC objectives and which minimize the significant economic impact of the proposal on small entities. For this reason, Advocacy recommends that the SEC republish for public comment a Supplemental IRFA before proceeding with this rulemaking. Advocacy also believes that the SEC should take into consideration small business representatives’ suggested alternatives to minimize the proposed rule’s potential impact.
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The U.S. Small Business Administration Office of Advocacy (Advocacy) respectfully submits the following comments to the Department of Energy (DOE) regarding its proposed energy efficiency standards for walk-in coolers and freezers. Advocacy has heard persistent concerns from small manufacturers of walk-in panels regarding the costs of the proposed standard. Advocacy believes the proposed rule would impose a significantly disproportionate burden on small businesses within the walk-in industry. To mitigate that impact to small entities while also achieving significant energy savings, Advocacy recommends that DOE adopt an alternative standard.
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On February 12, 2013, President Obama signed Executive Order 13636, “Improving Critical Infrastructure Cybersecurity.” This Executive Order placed primary responsibility on NIST to develop a cybersecurity framework. We have heard from our small business stakeholders, and we would like to share with you their comments and concerns regarding the preliminary cybersecurity framework. The comments fall into four areas: cost, compliance, education and enforcement.
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The Office of Advocacy (Advocacy) submits these comments on the U.S. Fish and Wildlife Service’s (FWS or the Service) proposed rule, Revised Designation of Critical Habitat for the Contiguous U.S. Distinct Population Segment of the Canada Lynx (Lynx Proposed Rule). Advocacy is concerned that FWS has improperly certified the proposed rule. Advocacy believes FWS should publish an Initial Regulatory Flexibility Analysis (IRFA).
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On behalf of the U.S. Small Business Administration Office of Advocacy, I am writing to express concerns regarding AT&T’s proposed special access tariff revisions, filed November 25, 2013, which would eliminate the availability of certain discounted long-term special access contracts with the carrier. Advocacy is greatly concerned that the changes will result in significant downstream cost increases for small business customers, including both small competitive local exchange carriers as well as end users. Additionally, Advocacy has persistent concerns regarding state of competition in the special access market, and its effect on small business customers.
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The Office of Advocacy (“Advocacy”) submits these comments on the U.S. Fish and Wildlife Service’s (“FWS”) proposed rule, Endangered and Threatened Wildlife and Plants; Proposed Endangered Status for Gunnison Sage-Grouse and Proposed Critical Habitat for Gunnison Sage-Grouse. Advocacy is concerned that FWS has improperly certified the proposed rule. Advocacy believes FWS should publish an Initial Regulatory Flexibility Analysis (“IRFA”).
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Congratulations on your recent confirmation as Chairman of the Federal Communications Commission. I would like to extend my best wishes as you assume leadership of an agency that is vitally important to our nation’s small businesses. Many of the issues the FCC will be confronting over the coming months are at the heart of the Small Business Administration Office of Advocacy’s mission to ensure that federal regulation preserves the ability of small businesses to compete and innovate in today’s economy.
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The U.S. Small Business Administration's Office of Advocacy (Advocacy) recommends that the Occupational Safety and Health Administration (OSHA) consider extending the public comment period and other deadlines for its proposed Occupational Exposure to Respirable Crystalline Silica (silica) rule by an additional 90 days to allow small businesses and their representatives adequate time to evaluate and assess the impact of this important rulemaking.
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The U.S. Small Business Administration's Office of Advocacy (Advocacy) submits the following comments on the Environmental Protection Agency’s (EPA’s) notice of proposed consent decree under the Clean Air Act published on August 20, 2013. In this notice, EPA invites public comment on a proposed consent decree that would require rulemaking under sections 112(d)(6) (technology review) and 112(f)(2) (residual risk review) to revise the National Emission Standards for Hazardous Air Pollutants (NESHAP) for petroleum refineries. Advocacy is concerned that the timeline for rulemaking required by this consent decree does not provide sufficient time for EPA to fully comply with the Regulatory Flexibility Act (RFA), including, if necessary, the requirement to re-initiate a Small Business Advocacy Review (SBAR) Panel in support of the proposed rulemaking, if EPA is unable to certify that the rulemaking would not have a significant economic impact on a substantial number of small entities.
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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 issued on July 24, 2013. The SEC issued the proposed rule with the intent of enhancing its ability to evaluate and enforce market practices associated with general solicitation and general advertising. Small business owners, entrepreneurs who have participated in small business startups, and investors in small business have all been in contact with Advocacy to discuss the proposed rule. Based upon this input from small business representatives, Advocacy is concerned that the Initial Regulatory Flexibility Analysis (IRFA) contained in the proposed rule lacks essential information required under the Regulatory Flexibility Act (RFA). For this reason, Advocacy recommends that the SEC republish for public comment a Supplemental IRFA before proceeding with this rulemaking. -
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Advocacy is concerned that the Centers for Medicare and Medicaid Services (CMS) has certified that the rule will not have a significant economic impact on a substantial number of small entities without providing a factual basis for the certification as is required by the Regulatory Flexibility Act. Advocacy is also concerned about the methodologies and assumptions underlying CMS’ economic analysis and possible alternative approaches. For these reasons set out below, Advocacy believes that CMS should improve its small entity impact analysis as it drafts the Final Regulatory Flexibility Analysis to be contained in the final rule. -
The Office of Advocacy (Advocacy) respectfully submits the following comments on the above-referenced proposed rule. For reasons set out below, Advocacy believes that CMS should improve its small entity impact analysis as it drafts the Final Regulatory Flexibility Analysis to be contained in the final rule. Advocacy also believes CMS should take into consideration industry’s suggested alternatives, in order to minimize the rule’s impact on small dialysis providers.
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On August 21, 2013, the Office of Advocacy submitted comments on the Environmental Protection Agency's (EPA) rulemaking on Formaldehyde Emissions Standards for Composite Wood Products and Third-Party Certification Framework for the Formaldehyde Standards for Composite Wood Products. -
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On August 15, 2013, the Office of Advocacy filed a notice of ex parte meeting with the Federal Communications Commission (FCC) detailing an August 13th meeting attended by Assistant Chief Counsel Jamie Saloom and FCC staff regarding the FCC’s proposed rules implementing sections 204 and 105 of the Twenty-First Century Communications and Video Accessibility Act (CVAA). In the meeting, Advocacy forwarded the concerns of small multi-channel video programming distributors (MVPDs) regarding the potential for the proposal to place a disproportionate impact on small MVPDs. Advocacy recommended that the FCC adopt regulatory alternatives, including a delayed compliance schedule for small MVPDs and an exemption for MVPDs with fewer than 20,000 subscribers. Additionally, Advocacy recommended that the FCC provide further analysis of the economic impact of the proposal on small MVPDs in its final rule. For further information please contact Jamie Saloom at 202/205-6890. -
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On July 29, 2013, the Office of Advocacy (Advocacy) filed public comments with the Department of the Interior (Interior) in response to the Notice entitled National Environmental Policy Act: Implementing Procedures; Addition to Categorical Exclusions for U.S. Fish and Wildlife Service.
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The Office of Advocacy (Advocacy) submits these comments on the U.S. Fish and Wildlife Service’s (FWS) proposed rule Proposed Designation of Critical Habitat for the New Mexico Jumping Mouse.Advocacy is providing the following comments to assist FWS in its compliance with its Regulatory Flexibility Act (RFA) obligations, the February 2012 Presidential Memorandum, and Executive Order 13563.
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The Office of Advocacy (Advocacy) filed a comment letter with the U.S. Department of Homeland Security (DHS) and the U.S. Department of Labor (DOL) regarding its interim final rule entitled, Wage Methodology for Temporary Non-Agricultural Employment-H-2B Program, Part 2.
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The U.S. Small Business Administration's (SBA) Office of Advocacy (Advocacy) submits the following reply comments on the Federal Communication’s Commission (FCC’s) Proposed Aviation Communications Rules.
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The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments on the Environmental Protection Agency’s (EPA) Draft Toxic Substances Control Act (TSCA) Workplan Chemical Risk Assessments (Risk Assessment) of Methylene Chloride (DCM), N-Methylpyrrolidone (NMP) and Trichloroethylene (TCE).
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On February 27, 2013, Bruce Lundegren and Jamie Saloom of the U.S. Small Business Administration’s Office of Advocacy (Advocacy) met with Jeffery Tobias, James Shaffer, and Scot Stone of the Federal Communications Commission to discuss the FCC’s recently proposed rules in the above-referenced docket.
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The Office of Advocacy (Advocacy) offers the following comment in response to the above-referenced notice of proposed rulemaking (NPRM) published by the Internal Revenue Service (IRS) on December 28, 2012.
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The Office of Advocacy (Advocacy) submits these comments on the National Oceanic and Atmospheric Administration’s (NOAA) and the U.S. Fish and Wildlife Service’s (FWS) proposed rule Revisions to the Regulations for Impact Analyses of Critical Habitat.
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The U.S. Small Business Administration's Office of Advocacy (Advocacy) submits the following comments on the Environmental Protection Agency (EPA) notice of proposed consent decree under the Clean Air Act, published on December 7, 2012. In this notice, EPA invites public comment on a consent decree that would require rulemaking under section 112(d) of the Clean Air Act to establish a National Emission Standard for Hazardous Air Pollutants (NESHAP) for brick and structural clay products manufacturing facilities and clay ceramics manufacturing facilities. Advocacy is concerned that the timeline for rulemaking required by this consent decree does not provide sufficient time for EPA to fully comply with the Regulatory Flexibility Act (RFA), including the requirement to conduct a Small Business Advocacy Review (SBAR) panel in support of a notice of proposed rulemaking.
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The Small Business Administration (SBA), Office of Advocacy (Advocacy) appreciates the opportunity to submit comments to the National Toxicology Program (NTP) Board of Scientific Counselors (BSC) in advance of their December 11, 2012 meeting.
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The Office of Advocacy (Advocacy) submits these comments on the U.S. Fish and Wildlife Service’s (FWS) proposed rule 12-Month Finding for the Lemmon Fleabane; Endangered Status for the Acuntildea Cactus and the Fickeisen Plains Cactus and Designation of Critical Habitat.
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The U.S. Small Business Administration's (SBA) Office of Advocacy (Advocacy) submits the following comments on the Federal Aviation Administration’s (FAA’s) Proposed Repair Stations Rule.
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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 (“RESPA” or Regulation X) and the Truth in Lending Act (“TILA” or Regulation Z).
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Advocacy respectfully submits these comments to the U.S. Patent and Trademark Office
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits this comment on the proposed rules on Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Minimum Regulatory Capital Ratios, Capital Adequacy, and Transition Provisions; Regulatory Capital Rules: Standardized Approach for Risk-weighted Assets; Market Discipline and Disclosure Requirements; and Regulatory Capital Rules: Advanced Approaches Risk-based Capital Rules; Market Risk Capital Rule.
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The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits this comment on the proposed rules on 2012 Truth in Lending Act (Regulation Z) Loan Originator Compensation.
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The Office of Advocacy (Advocacy) submits these comments on the Federal Acquisition Councils (FAR) proposed rule “Small Business Set Asides for Research and Development Contracts.”
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The Office of Advocacy of the U.S.. Small Business Administration (Advocacy) submits this comment on the proposed rules on 2012 Real Estate Settlement Procedures Act (Regulation X) Mortgage Servicing Proposal and 2012 Truth in Lending Act (Regulation Z) Mortgage Servicing Proposal.
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The Office of Advocacy of the U.S. Small Business Administration respectfully requests that the U.S. Patent and Trademark Office (USPTO) extend the public comment period for its proposed rules and examination guidelines implementing the First-Inventor-to-File (FITF) provisions of the Leahy-Smith America Invents Act (AIA).
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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 update the Steam Electric Power Plant Effluent Limitations Guidelines (ELG) by imposing technology-based standards to control wastewater under the Clean Water Act (CWA).
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Small Business Innovative Research
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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 (Advocacy) submits these comments on the U.S. Fish and Wildlife Service’s (FWS) proposed rule and economic analysis on the Revised Critical Habitat for the Northern Spotted Owl.
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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
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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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Endangered and Threatened Wildlife and Plants; Revised Critical Habitat for the Riverside Fairy Shrimp; Proposed Rule
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Preliminary Plan for Retrospective Analysis of Existing Rules; Notice of Availability
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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
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Food Labeling; Nutrition Labeling of Standard Menu Items in Restaurants and Similar Retail Food Establishments (FDA-2011-F-0172)
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Guidance Regarding Identification of Waters Protected by the Clean Water Act
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Small Business Size Standards: Professional, Scientific and Technical Services
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Small Business Advocacy Review Panel (SBAR Panel) Convening of Panel on Greenhouse Gas New Source Performance Standard for Electric Utility Steam Generating Units
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Revised Critical Habitat for the Pacific Coast Population of the Western Snowy Plover; Proposed Rule
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Temporary Non-Agricultural Employment of H-2B Aliens in the United States; Proposed Rule
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Endangered and Threatened Wildlife and Plants; Listing and Designation
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Antidrug and Alcohol Misuse Prevention Programs for Personnel Engaged in Specified Aviation Activities; Supplemental Regulatory Flexibility Determination
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Truth in Lending; Proposed Rule
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Registration Requirement for Petitioners Seeking to File H-1B Petitions on Behalf of Aliens Subject to Numerical Limitations
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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
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Proposal To Reissue and Modify Nationwide Permits; Notice
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Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Nine Bexar County, Texas, Invertebrates; Proposed Rule
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- Wage Methodology for the Temporary Non-agricultural Employment H-2B Program; Final Rule
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- 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
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Safety Management Systems for Part 121 Certificate Holders; Proposed Rule; 75 Fed. Reg. 68224, November 5, 2010
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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.
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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
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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.
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Letter dated 02/01/11 - Federal Reserve System - Compliance Guide for Regulation Z; Docket No. R-1366, Truth in Lending
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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).
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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)
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Notice 2011-6, Implementation of Rules Governing Tax Return Preparers
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Final rule on Regulation Z; Docket No R-1366, Truth in Lending
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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.”
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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
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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. -
Truth in Lending; Proposed Rule
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Specified Tax Return Preparers Required to File Individual Income Tax Returns Using Magnetic Media
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Parallel Review of Medical Products
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Reply to the notification letter regarding a Small Business Advocacy Review Panel for the forthcoming regulatory proposal, “Formaldehyde Emissions from Pressed Wood Products.”
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Concerning the forthcoming listing of styrene as a “reasonably anticipated” carcinogen in the National Toxicology Program (NTP) Report on Carcinogens.
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Proposed Accounting Standards Update regarding Leases (Topic 840)
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Oil and Gas and Sulphur Operations in the Outer Continental Shelf--Increased Safety Measures for Energy Development on the Outer Continental Shelf
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Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule
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Regulations Implementing the Longshore and Harbor Workers' Compensation Act: Recreational Vessels
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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
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Consultation Agreements: Proposed Changes to Consultation Procedures Rule
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Proposed Accounting Standards Update regarding Revenue from Contracts with Customers
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Wage Methodology for the Temporary Non-Agricultural Employment H-2B Program
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Regarding Expanded Form 1099 Filing Requirements
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Wireline Competition Bureau Seeks Comment On Business Broadband Marketplace
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Test Procedures for Walk-In Coolers and Walk-In Freezers; Proposed Rule
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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
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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
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Modifications to the HIPAA Privacy, Security, and Enforcement Rules Under the Health Information Technology for Economic and Clinical Health Act
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Program Integrity: Gainful Employment; Proposed Rule
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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
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National Emission Standards for Hazardous Air Pollutants for Major and Area Sources: Industrial, Commercial, and Institutional Boilers
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Enhanced Examination Timing Control Initiative
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Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems)
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Limitations on Subcontracting in Emergency Acquisitions
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Identification of Non-Hazardous Secondary Materials That Are Solid Waste
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Safety Standard for Bassinets and Cradles
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Adoption of the 2010 Draft Report by the Inorganic Arsenic Cancer Review Work Group
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Reply to the notification letter regarding regulatory proposal “New Source Performance Standards: Residential Wood Heaters”
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Work Reserved for Performance by Federal Government Employees
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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
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Petition for Rulemaking to Amend the Commission’s Rules Governing Retransmission Consent
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Injurious Wildlife Species; Listing the Boa Constrictor, Four Python Species, and Four Anaconda Species as Injurious Reptiles
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Nondisplacement of Qualified Workers Under Service Contracts
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Hazard Analysis and Critical Control Point (HAACP) system validation
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Women-Owned Small Business Federal Contract Program; Proposed Rule
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Effluent Limitations Guidelines and Standards for the Construction and Development Point Source Category
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Occupational Injury and Illness Recording and Reporting Requirements
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Medicare and Medicaid Programs; Electronic Health Record Incentive Program
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Hazardous Materials: Transportation of Lithium Batteries
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Endangered and Threatened Wildlife and Plants; Revised Designation of Critical Habitat for Bull Trout in the Coterminous United States
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National Broadband Plan
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Aircraft Repair Station Security
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Small Business Size Regulations; 8(a) Business Development/Small Disadvantaged Business Status Determinations
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Continuation of FHA Reform--Strengthening Risk Management Through Responsible FHA-Approved Lenders
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Truth in Lending; Proposed Rule
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Improving Implementation of the Paperwork Reduction Act
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Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rules
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Letter dated 12/16/09 - Department of Interior, Office of Surface Mining Reclamation and Enforcement
Advance notice of proposed rulemaking; Stream Buffer Zone and Related Rules
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Regulation of Tobacco Products; Request for Comments
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Standards for Living Organisms in Ships' Ballast Water Discharged in U.S. Waters
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Lead; Amendment to the Opt-out and Recordkeeping Provisions in the Renovation, Repair, and Painting Program
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Exchange Visitor Program--General Provisions
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Atlantic Herring Fishery
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Magnuson-Stevens Fishery Conservation and Management Act; Regional Fishery Management Councils; Operations
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Safety Management System; Advance notice of proposed rulemaking
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Recommendations for Tax Reform
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Fisheries of the Northeastern United States; Modification to the Gulf of Maine/Georges Bank Herring Midwater Trawl Gear Authorization Letter
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Regulation of Fuels and Fuel Additives: Changes to Renewable Fuel Standard Program; Proposed Rule
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Definition of Solid Waste Public Meeting
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Registration of Mortgage Loan Originators
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Payments Under Fixed-Price Architecture and Engineering Contracts
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Lease Accounting Standards
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Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act
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Mandatory Reporting of Greenhouse Gases
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Proposed Hazardous Air Pollution Standard for Reciprocating Internal Combustion Engines During Periods of Startup, Shutdown, and Malfunctione
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Endangered and Threatened Wildlife and Plants; Revised Designation of Critical Habitat for the California Red-Legged Frog (Rana aurora draytonii)
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Tracking Labels for Children's Products Under Section 103 of the Consumer Product Safety Improvement Act
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Regulations Under the Genetic Information Nondiscrimination Act of 2008
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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
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Oil Pollution Prevention; Non-Transportation Related Onshore Facilities; Spill Prevention, Control, and Countermeasure Rule; delay of effective date
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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
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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
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Rural Broadband Strategy
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Medicare, Medicaid, and Clinical Laboratory Improvement Amendments of 1988 (CLIA) Program; Cytology Proficiency Testing (PT)
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Large Aircraft Security Program, Other Aircraft Operator Security Program, and Airport Operator Security Program
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Effluent Limitations Guidelines and Standards for the Construction and Development Point Source Category; Proposed Rule
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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
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Letter dated 02/03/09 - Department of Transportation, National Highway Traffic Safety Administration
Early Warning Reporting Regulations
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Handling of Animals; Contingency Plans
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Reply to the notification letter regarding a Small Business Advocacy Review Panel for the proposed combined rulemaking on Industrial, Commercial, and Institutional Boilers.
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Cranes and Derricks in Construction; Proposed Rule
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Reply notification letter regarding Effluent Elimination Guidelines and Standards for the Construction and Development Point Source Category; Small Entity Representative Recommendations
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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).
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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.
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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.
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Preliminary comments on EPA's proposed effluent guidelines for the transportation equipment cleaning industry
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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.
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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.
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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.
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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.
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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
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Report of the Small Business Advocacy Review Panel convened on "Effluent Limitations Guidelines and Standards for the Transportation Equipment Cleaning Industry.
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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.
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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
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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).
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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
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Regarding effluent limitations guidelines and standards for the transportation equipment cleaning point source category
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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
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