Dear Ms. Cooperstein:
The American Public Gas Association, Association of American Railroads, National Rural Electric Cooperative, U.S. Chamber of Commerce, and The Fertilizer Institute appreciate the opportunity to comment on the U.S. Environmental Protection Agency’s (EPA) proposed rule titled, “EPA Guidance; Administrative Procedures for Issuance and Public Petitions,” hereafter referred to as the “Proposed Rule,” to establish administrative procedures for the issuance of guidance documents that are subject to the requirements of Executive Order 13891.
We applaud EPA’s efforts to formalize a process for creating new guidance and managing existing guidance to promote transparency and openness in the regulatory development and implementation process. Guidance can serve the important purpose of interpreting existing law or clarifying how the agency intends to implement particular legal requirements. Establishing a more transparent and open process for issuing guidance will help provide more predictability for regulated entities when making the investments and decisions necessary to meet regulatory requirements.