Document 7ezO5vr6M2p39OqDrrNZVK9V
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Beck, Nancy [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=168ECB5184AC44DE95A913297F353745-BECK, NANCY] 3/1/2018 11:59:38 PM Spielvogel, Tamra [TSpielvogel@nahb.org] Chai, Amy [achai@nahb.org] RE: Thank You & Follow-up
Many thanks Tamra. We will take a look at all this information and surely circle back if there are questions.
Regards, Nancy
Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP P: 202-564-1273
beck.nancy@epa.gov
From: Spielvogel, Tamra [mailto:TSpielvogel@nahb.org] Sent: Friday, February 23, 2018 3:07 PM To: Beck, Nancy <Beck.Nancy@epa.gov> Cc: Chai, Amy <achai@nahb.org> Subject: Thank You & Follow-up
Dr. Beck,
Thank you for taking the time to meet with us and our colleagues yesterday. We appreciate your time and you attention to our issues raised concerning the RRP program. In follow-up to the discussion we wished to provide you with the information discussed regarding a number of individual items.
Attached you will find a copy of NAHB's comments submitted in July of 2015 at the start of the public stakeholder engagement on the status of lead-paint test kits, in it, NAHB references the language from the 2008 Preamble regarding the Agency's intended course of action should no test kit meeting the regulatory requirements be brought to market in the expected timeframe - "if the improved test kits are not commercially avaiiable by September 2010, ERA wiil initiate rulemaking to extend the effective date of this final rule for 1 year with respect to owner-occupied target housing buiit after 1960." (See the top of page 5 of NAHB's Comments,) As the Agency never acted on this commitment an economic analysis to reflect the proposed action was never completed and no economic analysis of the regulation reflects the lack of a test kit coming to market in year two of the program as anticipated.
Also attached, is a copy of NAHB's comments to HUD in response to the request for comments relating to updating the Federal Strategy to Reduce Childhood Lead Exposure submitted in November 2017.
Finally, attached for your information is a letter received by NAHB from ERA confirming the status of the Agency's commitment of resources to the development of a lead-test kit that meets both performance requirements.
Please iet me know if you have any questions about this material. We look forward to continued opportunities to work with you and the staff at OCSPP on the RRP program moving forward. Again, thank you for your time.
Sierra Club v. EPA 18cv3472 NDCA
Tier 7
ED 002061 00050090-00001
Best, Tamra Spielvogei
national Association
of Homo Boildors
1V1R SPIELVOGEL Senior Program Manager, Environmental Policy
National Association of Home Builders 12.0115th Street, NW j Washington, DC 2.0005 'J C Z X > y C Z j e: tspieivogel@nahb.org w: nahb.org
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Sierra Club v. EPA 18cv3472 NDCA
Tier 7
ED 002061 00050090-00002