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HR 4946




October 12, 2000

Dear P2 Colleagues,

I am writing this letter to share my concerns about HR 4946, the
"National Small Business Regulatory Assistance Act of 2000" which passed
the U.S. House of Representatives recently.

This bill funds a pilot project for developing a service delivery
network of regulatory compliance centers through the existing Small
Business Development Centers.  The Centers will provide confidential
regulatory compliance assistance to small businesses; create a
"partnership" of Federal agencies to increase outreach to small
businesses;  provide a feedback mechanism to Federal agencies for small
business concerns; and refer small businesses to experts and other
providers of regulatory compliance technical assistance. The extent of
regulatory compliance issues to be dealt with in this legislation are
vague.  The bill references the  Small Business Assistance Programs
under the Clean Air Act, but does not specify other regulatory
compliance issues.

The bill indicates that this delivery mechanism will be comprised solely
of the Small Business Development Centers.  As part of the pilot, the
Administrator of the Small Business Development Center program will
identify two centers within each EPA region to participate.  The bill
also establishes the Association of Small Business Development Centers
to serve as a clearinghouse and to coordinate the compliance assistance
system nationally.  This bill does not specify any partnering activities
with existing programs or organizations except as potential referrals.

The last bill  put forth by the Small Business Development Centers to
establish this system, HR 96 (which did not pass), clearly defined
regulatory assistance as environmental regulations, health and safety
regulation, and tax codes.  Whereas the bill that just passed the House
does not specify which regulations are covered by this pilot, the
testimony given by the Association of Small Business Development
Centers  mentions all three of these areas.  The previously proposed
bill also redirected funds  from US EPA, the Department of Labor and the
Internal Revenue Service to support this network.  It is notable that
the funding sources identified in the previous, unpassed bill were funds
that would have gone to states to support their designated and other
programs.

The National Pollution Prevention Roundtable contacted the Association
of Small Business Development Centers to explore the potential to expand
this pilot to include partnerships with the existing small business
assistance providers that serve as the membership of the Roundtable.
The head of the Association of Small Business Development Centers stated
that their organization did not support this bill, yet he provided
testimony to the U.S. House of Representatives clearly stating the
organization's strong and unwavering support of this bill.  This
conflicting information concerns me greatly.

The bill, as written, does not include specific language for
establishment of partnerships with existing compliance assistance and
pollution prevention programs.  The funding source for this pilot is
also unclear.  Establishment of a new system of compliance assistance
providers is wholly irresponsible in that it duplicates services already
provided through state pollution prevention programs, the Small Business
Assistance Programs, the NIST Manufacturing Extension Partnerships, the
OSHA Voluntary Compliance Programs, and other programs.  The fact that
this bill does not include partnerships with existing programs indicates
an intention to establish a separate system to provide assistance
services already provided by state programs.  The existing state
programs have proven their effectiveness for over fifteen years.  This
approach to build a new and duplicative system is an affront to
effective government.

The passage of this bill also poses a real threat to federal funding of
state environmental assistance programs as well as OSHA compliance
assistance programs.  If this bill passes and this pilot is funded, I
believe that legislation will follow along the lines of HR 96, to
permanently put into place a compliance assistance network solely
through the Small Business Development Centers.  I urge our membership
to contact their Congressman and Senators to put an end to this
potentially damaging legislation.

Sincerely,

Patricia Gallagher
Chair
National Pollution Prevention Roundtable