Office of Advocacy Letterhead

    Via Electronic Mail

    September 1, 2010

    Mr. Alexander Cristofaro (MC-1804A)
    Small Business Advocacy Chair
    U.S. Environmental Protection Agency
    1200 Pennsylvania Ave., N.W.
    Washington, DC 20460

    Subject: SBAR Panel for Stormwater Regulations to Address Discharges from Developed Sites

    Dear Mr. Cristofaro:

    The Office of Advocacy (Advocacy) has received electronically your August 17, 2010 formal notification regarding the Small Business Advocacy Review Panel (Panel) for the forthcoming regulatory proposal, “Stormwater Regulations to Address Discharges from Developed Sites.” Advocacy generally concurs with the revised list of Small Entity Representatives (SERs) that EPA provided this morning. We agree with EPA’s plan to have approximately 30 small entity representatives, with roughly half representing industry and builders/developers, and one half representing local governments. We have some specific suggestions for additional representatives in both sectors, supplied in Attachment A. In particular, EPA appears to be short of representatives in the industrial sector.

    We look forward on working with EPA on planning the next steps, including the appropriate time when the formal panel should be convened. We will be reviewing the general outline of regulatory alternatives that EPA provided earlier today.

    We look forward to working with you through this process.

    Sincerely,

    /s/

    Winslow Sargeant, Ph.D.
    Acting Chief Counsel for Advocacy

    cc: The Honorable Cass R. Sunstein, Administrator
    Office of Information and Regulatory Affairs
    Office of Management and Budget

    Attachment A

    Builder/Developers

    Leah Pilconis, Associated General Contractors

    Industry
    David Wagger, Institute of Scrap Recycling Industries, Inc.
    Jeffrey Longsworth, Federal Storm Water Association

    Local Government

    Dave Ulrich, Great Lakes and St. Lawrence City Initiative, Illinois|
    Randy Neprash, Minnesota Cities Storm Water Coalition
    Ken Carper, WK Dickson And Company, North Carolina
    Eric Larson, City of Georgetown, Kentucky
    Richard Sustich, Village of Lake Zurich, Illinois
    Randy Stambaugh, Kentucky Stormwater Association
    Normand Goulet, Northern Virginia Regional Commission (also Chesapeake Bay)
    Laurie Hawkes, Georgia Association of Water Professionals Stormwater Committee
    Jim Eckrich, City of Crestwood, Missouri
    Champ Adcock, City of Meridian, Mississippi
    Ryan Cummins, City of Brunswick, Ohio (also NACWA nominee)
    Sam Amerson, City of Stuart, Florida