From: Inge, Carolyn
Location:
DCRoomARN3500/OPEI
Importance:
Normal
Subject: Meeting with NAHB re: Renovation, Repair and Painting Program and Stormwater Issues
Start Date/Time: Wed 5/10/2017 7:30:00 PM
End Date/Time:
Wed 5/10/2017 8:00:00 PM
Stormwater Issues - NAHB Brief!
3df
Hi, Would you set this up from Samantha's calendar Please? Thank you.
Directions: Please use the William Jefferson Clinton North Entrance located on your right as you exit the Federal Triangle Metro Station. Please arrive 20 minutes prior to the meeting with photo IDs to clear Security.
EPA Contact: For an escort from Security to the meeting call (202) 564-4332; for all other matters call Robin Kime (202)564-6587.
4 Attendees: Tamra Spielvogel, Amy Chai, Eva Birk and Tom Ward
Request: A follow-up conversation to discuss the RRP program. I'm emailing in follow up to your conversation with Michael Mittelholzer at the NAHB meeting with Administrator Pruitt last week. I know several issues were discussed for additional follow up during the meeting with the Administrator including the Renovation, Repair and Painting (RRP) Program and stormwater issues which my colleague Eva will be following up with you on in a subsequent message.
Attached is the material you and Michael discussed to provide additional detail regarding NAHB's concerns regarding implementation and evaluation of the RRP program. Specifically I have provided copies of NAHB's comments related to the Section 610 review as well as those NAHB submitted during both public comment periods EPA opened during the review of issues related to the lack of an approved lead test kit. Also, for your information I am including copies of two petitions NAHB has filed with EPA on the RRP program. The most recent was in regards to the changes made to the refresher training course requirements which was denied by the agency in December 2016. The EPA response is also enclosed. I have enclosed the 2010 petition
17cv01906 Sierra Club v. EPA
ED_001523_00005604-00001
because while the other documents discuss the issues we have with the economic analysis of the rule, it was most comprehensively addressed in this petition on the test kit.
Finally, I was also told you are interested in the report where EPA's cost benefit estimates were called into question. The report was issued by the EPA Office of the Inspector General. The following link will take you to the OIG page for the report where you can access their findings, the report, as well as the responses exchanged between OIG and EPA on the report.
I would note that one of the commitments made by the EPA to the OIG was to collect better data but they made the commitment to do so in the context of a separate rulemaking (the development of an RRP rule for Public & Commercial Buildings) and that survey is currently underway. NAHB individually and as part of an industry coalition has called into question the efficacy of this effort. While the data may be useful to the residential program collecting it in the context of the Public & Commercial Buildings rule has never seemed appropriate or truly illustrative given a range of other differences between the two rules. Furthermore, the data is being collected prior to establishing a hazard for Public & Commercial Buildings.
Contact:
TAMRA SPIELVOGEL Program Manager, Environmental Policy
National Association of Home Builders
1201 15th Street, NW | Washington, DC 20005
d: 202.266.8327 e:
w:
z
17cv01906 Sierra Club v. EPA
ED_001523_00005604-00002