The Automotive Service Association (ASA) applauds the United States Environmental Protection Agency (EPA) for excluding collision repair facilities from its proposal to increase required reporting under a revised Air Emissions Reporting Requirements (AERR) regulation. Without this exclusion, ASA believes this rule would inflict considerable economic costs upon many small businesses while providing the government data of negligible value.
The Small Business Advocacy Review (SBAR) panel, convened by the EPA to assist in developing the proposal, selected ASA to serve as a small entity representative (SER). ASA’s appointment as an SER provided the collision repair industry a platform to offer insight for the recommendations of the SBAR panel, which was comprised of the EPA’s Small Business Advocacy chairperson; the director of the EPA’s Air Quality Assessment Division in the Office of Air Quality Planning and Standards; the administrator of the Office of Information and Regulatory Affairs within the Office of Management Budget; and the chief counsel for Advocacy at the Small Business Administration.
In public comments submitted to the EPA following the release of the proposal, ASA stated, “This proposed revision to AERR accounts for the concerns that ASA shared with the EPA. We are encouraged that the EPA appears to have taken our perspective to heart. At the same time, we remain concerned that the 100 employee or less criteria for meeting the small business standard is too restrictive. We also seek clarification as to whether a small entity determination is based on the relevant criteria for an individual collision facility or if it is based on the aggregate of all distinct facilities owned by a common party?”
ASA will continue to monitor and engage the EPA on this regulatory proposal and will keep the collision industry up to date on important developments.
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