E­
Mail
FROM:
"
Belton,
Keith
B."
<
Kbelton@
OMB.
eop.
gov>
06/
24/
2004
05:
34
PM
To:
"
Fraas,
Arthur
G."
<
afraas@
OMB.
eop.
gov>,
"
Noe,
Paul
R."
<
pnoe@
OMB.
eop.
gov>,
Bill
Wehrum/
DC/
USEPA/
US@
EPA,
"
O'Donovan,
Kevin
M."
<
Kevin_
O'Donovan@
ovp.
eop.
gov>,
lee.
otis@
hq.
doe.
gov,
David.
R.
Hill@
hq.
doe.
gov,
Indur_
Goklany@
ios.
doi.
gov,
"
Joseffer,
Daryl
L."
<
Daryl_
L._
Joseffer@
OMB.
eop.
gov>,
"
Gayer,
Ted"
<
Ted_
Gayer@
cea.
eop.
gov>,
"
Boyd,
Allison"
<
Allison_
Boyd@
opd.
eop.
gov>,
Chet
Thompson/
DC/
USEPA/
US@
EPA,
Bill
Harnett/
RTP/
USEPA/
US@
EPA,
Jessica
Furey/
DC/
USEPA/
US@
EPA,
"
Belton,
Keith
B."
<
KBelton@
OMB.
eop.
gov>

cc:

Subject:
language
for
ERP
reconsideration
package
FYI:
In
case
you
don't
have
it,
here
is
the
language
suggested
for
the
reconsideration
package.

While
not
discussed
in
the
ERP
final
rule,
we
recently
prepared
information
on
another
regulatory
program
in
the
United
States
­
construction
building
codes.
In
our
investigation,
we
found
that
some
jurisdictions
specify
a
percentage
cost
threshold
for
determining
what
constitutes
a
building
"
improvement,"
and
require
such
improvements
to
comply
with
the
current
code.
A
common
threshold
is
50
percent,
based
on
cost
of
the
improvement
as
compared
to
the
market
value
of
the
pre­
existing
structure.
Additional
information
on
our
investigation
into
building
codes
is
in
our
docket.
See
Docket
OAR­
2002­
0068;
Document
No.
_____.
We
solicit
comment
on
the
accuracy
and
representation
of
this
information
and
whether
it
is
appropriate
to
consider
approaches
used
in
building
code
applicability
when
establishing
criteria
for
RMRR
determinations.
