"Lee, Amanda I." <Amanda_I._Lee@omb.eop.gov> 
11/27/2007 07:37 PM	To
	Aaron Levy/DC/USEPA/US@EPA
	cc
	Ross Brennan/DC/USEPA/US@EPA, Paul Balserak/DC/USEPA/US@EPA, Richard 
Keigwin/DC/USEPA/US@EPA, Diane McConkey/DC/USEPA/US@EPA, "MacNeil, John 
S." <John_S._MacNeil@omb.eop.gov>, "Belefski, Mary L." 
<Mary_L._Belefski@ceq.eop.gov>
	bcc
	
	Subject
	Comments on the 2008 CUE MeBr FRM
	
	


Hi Aaron,
 
Here are some OMB comments.  I'm still working on other editorial comments.
 
1.  Given that the Parties have not adopted a concept of SCF, what is the 
basis for adopting in this FRM?  What are the consequences of this 
adoption?
 
2.  What is the basis for not adopting a 1-year SCF in response to 
comments?  Also, the preamble talks about the proposed SCF being 6 month 
cushion and 4 month cushion.  Which one is it?
 
3.  What isn't OECA involved with the alleged under-reporting of MeBr 
use?  Why is EPA/Air requiring more reporting to deal with enforcement 
matter?
 
4.  Even if the newly proposed reporting requirement is considered a sound 
policy, the basis for the 90 hour burden is not very convincing.  We would 
think the firms would be spending more than 0.5 hour familiarizing 
themselves with the new requirements, especially for smaller firms.  Also, 
what is the basis for the data compilation burden?  How many transactions 
does EPA expect the firms to go through to come up with the list of 
distributors?  Is there a form attached to this reporting?  
 
If this FRM is serving the purpose of a 60-day notice, then the agency 
will need to do another 30-day notice.
 
5.  The preamble makes references to technical analysis associated with 
SCF.  Other than the TSD, has the agency conducted another analysis?  If 
so, please provide.  Also, the preamble discussion on this issue appears 
to be largely unresponsive to the comments.
 
6.  The agency cite some commenters and not others.  Please be consistent.
 
 
I have not received comments from USDA, CEQ or USTR yet.
 
Thanks,
 
Amanda
 
 