Introduction
Business Roundtable commends EPA for committing to improve its process through regulation and seeking public comment through this Advance Notice of Proposed Rulemaking (ANPRM). Business Roundtable shares the agency’s desire to develop more accurate estimates of costs and benefits while clearly and transparently recognizing the limitations, uncertainty and imprecision associated with such analysis.
On November 20, Business Roundtable filed comments in response to EPA’s request for comments regarding whether and to the extent to which any of the best practices recommended in the annual report of the Federal Permitting Improvement Steering Council established by FAST-41 should be applicable to states that have accepted delegated authority to administer permit programs in lieu of EPA.
Business Roundtable supports the Proposed Rule published by the Environmental Protection Agency (the Agency) and the U.S. Army Corps of Engineers on July 27, 20171 to rescind the 2015 Clean Water Rule (the 2015 Rule) and restore the regulatory text defining the term “waters of the United States” as it existed prior to the 2015 Rule. This action is a prudent first step in the process by which the Agency and the U.S. Army Corps of Engineers will reconsider the “waters of the United States” definition.
Business Roundtable commends the Administration for its commitment to creating an investment climate conducive to economic growth and the accelerated creation of high-quality jobs. EPA’s request for comments to inform the deliberations of its Regulatory Reform Task Force is one of a series of important actions by the Administration to implement its regulatory reform agenda.
Businesses commonly find themselves subject to two or more regulatory agencies exercising concurrent jurisdiction over a single issue. This problem is prevalent throughout government, as we document in the attached, which identifies specific examples of problematic agency duplication.
In a letter to the White House, Business Roundtable says the Administration can speed infrastructure permitting by using provisions of an existing law, FAST-41.
Business Roundtable delivered a letter to the White House underscoring the “Top Regulations of Concern” identified by CEOs along with recommendations for minimizing their economic impact.
The Regulatory Accountability Act of 2017 would make the U.S. regulatory system more transparent, accountable and effective.
[We] wanted to share these top-level concerns with you directly in anticipation of our next opportunity to discuss them and other regulations of concern. Building on our recent TPA victory, we look forward to working together to find even more solutions that keep America moving forward.
Business Roundtable CEOs believe that a smarter regulatory system and a modernized federal permitting process will help drive increased business investment, economic growth and job creation.