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Letters to Agencies

The Regulatory Flexibility Act directs Advocacy to monitor whether proposed federal regulations consider the effects on small businesses. Advocacy files comment letters with federal agencies to alert them to their rules’ small business impacts and to propose alternative approaches to achieving regulatory goals.

Archived Regulatory Comment Letters

Letters to Agencies

Advocacy’s Comments on IRS’s IRA Prevailing Wage and Apprenticeship Initial Guidance

Office of Advocacy Jan 13, 2023

On November 30, 2022, the Internal Revenue Service published a notice of initial guidance (Notice 2022-61) regarding prevailing wage and apprenticeship requirements applicable to certain energy tax incentives found in the Internal Revenue…

Letters to Agencies

Advocacy Recommends that the Federal Railroad Administration Revise and Republish its Regulatory…

Office of Advocacy Dec 22, 2022

On December 21, 2022, the U.S. Small Business Administration Office of Advocacy submitted comments to the Federal Railroad Administration (FRA) on FRA’s Proposed Train Crew Size Safety Requirements Rule. The FRA’s proposed rule would…

Letters to Agencies

Advocacy Comments on EPA’s Initial Regulatory Flexibility Analysis for its Proposed Reporting and…

Office of Advocacy Dec 20, 2022

On December 19, 2022, Advocacy submitted comments on the Environmental Protection Agency’s (EPA) published Initial Regulatory Flexibility Analysis (IRFA) and updated economic analysis. EPA completed a Small Business Advocacy Review…

Letters to Agencies

Advocacy Recommends that the DOL Reassess the Compliance Costs of Independent Contractor Rule for…

Office of Advocacy Dec 13, 2022

On October 13, 2022, the Department of Labor (DOL) proposed a rule that would determine whether a worker is an independent contractor or employee under the Fair Labor Standards Act. The proposed rule would rescind a 2021 final rule which…

Letters to Agencies

Advocacy Recommends that the NLRB Reassess the Compliance Costs of Joint Employer Rule for Small…

Office of Advocacy Nov 29, 2022

On September 7, 2022, the National Labor Relations Board proposed a rule that would expand the joint-employer definition under the National Labor Relations Act. This expansion extends liability to employers that have indirect and reserved…

Letters to Agencies

Advocacy Comments on TTB’s Proposed and Temporary Rules on Refund Procedures for Excise Taxes on…

Office of Advocacy Nov 18, 2022

On September 23, 2022, the Alcohol and Tobacco Tax and Trade Bureau (TTB) published temporary and proposed rules implementing amendments to the Craft Beverage Modernization Act provisions of the Internal Revenue Code (Code). The proposed…

Letters to Agencies

Advocacy Comments on EPA’s Proposed Hazardous Substance Designations for PFOA and PFOS under CERCLA

Office of Advocacy Nov 8, 2022

On September 6, 2022, EPA proposed the designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).…

Letters to Agencies

Advocacy Submits Comment to NMFS on Amendments to the North Atlantic Right Whale Vessel Strike…

Office of Advocacy Nov 1, 2022

On August 1, 2022, the U.S. Department of Commerce’s National Marine Fisheries Service (NMFS) published a proposed rule titled, “Amendments to the North Atlantic Right Whale Vessel Strike Reduction Rule.” The Office of Advocacy of the U.S.…

Letters to Agencies

Advocacy Submits Comments on EPA’s Revisions to Accidental Release Prevention Requirements

Office of Advocacy Oct 31, 2022

The Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA) proposed rule, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act;…

Letters to Agencies

Advocacy Urges FAR Council to Re-Evaluate Compliance Costs for Small Construction Companies in the…

Office of Advocacy Oct 19, 2022

On August 19, 2022, the FAR Council published a proposed regulation that would make it mandatory for agencies to have Project Labor Agreements (PLA) for federal construction contracts valued at $35 million or more. This mandatory PLA would…

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