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AL PROTEO

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 

^jji

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Gregg Harper 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Harper: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable John Barrow 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Barrow: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Mathy S'tanislaus 

Assistant Administrator
\1	

S7q

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Leonard Lance 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Lance: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 andNovember 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Marsha W. Blackburn 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congresswoman Blackburn: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
çD S74.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

(a.

	 WASHINGTON, D.C. 20460 

4L PRO1

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Mike Simpson 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Simpson: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18,2008; 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


RecycledlRecyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(iiepa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
çO Sq.

'3'

Ui

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Steven M. Palazzo 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Palazzo: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


RecyclewRecyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory conmTlent periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
S1.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 

PRO1

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Tim Griffin 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Griffin: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postcorisumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Rague1epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
8 ^^V s.ıTED STAT^

^z^SIt^^ ^nr\.

ALp^OTE°

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Rick Crawford 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Crawford: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public coniment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory coniment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder. Raguel@epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 

4L PRO1

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Steve Womack 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Womack: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Rague1(epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Gus Bilirakis 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Bilirakis: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 andNovember 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
S74

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Renee Elimers 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congresswoman Elimers: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on t00% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Lee Terry 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Terry: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586.
^^^ ^^,TED STA^^^

8

^

%

ıpR.TE^

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Mark Amodei 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Amodei: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


RecycleWRecyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mathy tanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Tom Cotton 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Cotton: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epagov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquelepa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
.8E

°

^^^S^Tg,

^^^^°^

^^ALp^oTE^

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Alan Nunnelee 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Nunnelee: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel@epa.gov or (202) 564-9586. 

Mathtanislaus 

Assistant Administrator
\1	

S1q 

isa) 

o1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Tom Latham 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Latham: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http:f/www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has filly considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Mathtanislaus 

Assistant Administrator
S?

'S.. 

• L PAOt'

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND 

EMERGENCY RESPONSE 

The Honorable Bill Cassidy 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Cassidy: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguelepa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
ST

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 

PRO

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Adam Kinzinger 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Kinzinger: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raque1(epa.gov or (202) 564-9586. 

Maanislaus 

Assistant Administrator
^^

^,TEOSTA^

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Mike Pompeo 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Pompeo: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Steve Dames 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Dames: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Robert E. Latta 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Latta: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epagov 


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(iepa.gov or (202) 564-9586. 

Mathy tanislaus 

Assistant Administrator
^^

ED ST ^:^^ATg^

'Zr r

'°

AL PROTEC,

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Billy Long 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Long: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
.s^^E

° ^

TAr ^^2q^

^LPROT^'

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Paul Gosar 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Gosar: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mattanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Jason Chaffetz 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Chaffetz: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http:Ilwww.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa. gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
S?47

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

()

	

WASHINGTON, D.C. 20460 

pRQ1

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Robert Bishop 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Bishop: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Walter B. Jones 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Jones: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oit Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
.S^

EO STAT

^2^

ES'8^

^

NALPROT ES\

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Jeff Duncan 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Duncan: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder. Raquelc2iiepa. gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Mick Mulvaney 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Mulvaney: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquelepa. gov or (202) 564-9586. 

Mathy tanis1aus 

Assistant Administrator
çEO S. (i4) •

L PAO1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable David P. Roe 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Roe: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder. Raguel@epa.gov or (202) 564-9586. 

Mathy anislaus 

Assistant Administrator
S741.

'3	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

• L PRO

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Cory Gardner 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Gardner: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
ST.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 

PRO1

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Cathy McMorris Rodgers 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congresswoman McMorris Rodgers: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mathtanislaus 

Assistant Administrator
S 

s4 

4L PRO1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Brett Guthrie 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Gutbrie: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa. gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
·

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AL PROTEO

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Robert B. Aderholt 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Aderholt: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder. Raguel(2lepa. gov or (202) 564-9586.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Bill Johnson 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Johnson: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://wwwepa.gov 


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Mathtanis1aus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Bill Huizenga 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Huizenga: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epagov


RecycleWRecyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguelcepa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
^,TEDSM^

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^Z^ Z^bp^

^LPROT^°^

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Mo Brooks 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Brooks: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identif' appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable S Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder. Raquelepa.gov or (202) 564-9586. 

Matanis1aus 

Assistant Administrator
WASHINGTON, D.C. 20460

S7q

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Virginia Foxx 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congresswoman Foxx: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Maanis1aus 

Assistant Administrator
c o

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Ira.

	 WASHINGTON, D.C. 20460 

1L PRO1

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Greg Walden 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Walden: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Matanis1aus 

Assistant Administrator
^.,TED STA^^

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'

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Mike D. Rogers 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Rogers: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(äepa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Daniel Webster 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Webster: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http:I/www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguelepa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
^.,TEDSTA^

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^^ALpR.TB

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Adrian Smith 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Smith: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(2iepa.gov or (202) 564-9586.
Z^ ^^ ^^,TED STA^^

^2^^ ^

^^'° ALpRoTE°

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Ann Wagner 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congresswoman Wagner: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa. gov or (202) 564-9586. 

Mathanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Mike J. Rogers 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Rogers: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public conment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguelcepa. gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
S?q. 

L PRO1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Gene Green 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Green: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586. 

Mathtanis1aus 

Assistant Administrator
17

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460 

PRO1

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Steve Southerland 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Southerland: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epagov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquelepa.gov or (202) 564-9586.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Vicky Hartzler 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congresswoman Hartzler: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raguel(epa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
vr^

EOSTA

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AL PRoTEO

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Rodney Davis 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Davis: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Todd Young 

U.S. House of Representatives 

Washington, D.C. 20515 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment nianufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Rague1cepa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Markwayne Mullin 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Mullin: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://wwwepa.gov


RecycleWRecyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list Gf potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa.gov or (202) 564-9586.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Jackie Walorski 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congresswoman Walorski: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquelepa.gov or (202) 564-9586. 

Matanis1aus 

Assistant Administrator
iD S74,

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Todd Rokita 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Rokita: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raque1(epa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Stephen Fincher 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Fincher: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chtonne Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Rague1epa.gov or (202) 564-9586. 

Mathy 'tanis1aus 

Assistant Administrator
^^,TED STA^ ^^Z^^G7

..Vr.^

AL PR0TE

°

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Kevin Cramer 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Cramer: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

vho work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 1OO/ Postconsumer, Process Chlonne Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquelepa. gov or (202) 564-9586. 

Mathanis1aus 

Assistant Administrator
1 D ST. 

pRO10

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Scott Desjarlais 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Desjarlais: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA' s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(epa. gov or (202) 564-9586. 

Matanis1aus 

Assistant Administrator
\-c0

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 

( PRO1

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Martha Roby 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congresswoman Roby: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsurner, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(2epa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
S1.

z

	

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

PAO1

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Diane Black 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congresswoman Black: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquel(liepa.gov or (202) 564-9586. 

Matanis1aus 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Blame Luetkemeyer 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Luetkemeyer: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental Relations, at 

Snyder.Raquelepa.gov or (202) 564-9586. 

Matanislaus 

Assistant Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460

OFFICE OF


SOLID WASTE AND


EMERGENCY RESPONSE 

The Honorable Jim Matheson 

U.S. House of Representatives 

Washington, D.C. 20515 

Dear Congressman Matheson: 

Thank you for your letter of July 24, 2013, regarding the proposed revisions to the U.S. Environmental 

Protection Agency's (EPA) underground storage tank regulations. Knowing that the majority of our 

regulated entities are small businesses, we agree it is important to recognize potential impacts to this 

sector. This was one of the main reasons why, when drafting the proposal, we made a concerted effort to 

propose provisions which would not require costly retrofits to existing underground storage tank (UST) 

systems, yet would help ensure protection of public health and the environment. 

The EPA carefully evaluated the costs associated with the proposal and explained the agency's analysis 

in the regulatory impact assessment (RIA). Our analysis determined that the potential costs of the 

proposal did not reach a level that would require convening a Small Business Advocacy Review Panel. 

Although EPA did not convene a Panel, we sought extensive stakeholder input to help inform our 

rulemaking proposal. 

Prior to the November 2011 proposal, the EPA engaged in a multi-year effort with stakeholders to 

identify appropriate updates and modifications to the UST regulations. Before the EPA started to draft 

regulatory language, the agency reached out to potentially affected parties to ask for their input on what 

changes to make to the UST regulations. Starting in March 2008, the EPA had conference calls, in 

person meetings, and shared emails with stakeholders. The EPA reached out to petroleum marketers and 

other owners and operators of UST systems, equipment manufacturers, vendors and service providers 

who work on the equipment, among others. Specifically, the EPA met with industry representatives of 

Petroleum Marketers Association of America (PMAA), American Petroleum Institute (API), National 

Association of Convenience Stores (NACS), SIGMA, National Association of Truckstop Owners 

(NATSO) and the Petroleum Transportation and Storage Association (PTSA). In addition to meeting 

with these stakeholders, the EPA also met with several individual marketing, equipment and service 

companies. The EPA held a series of in person meetings with these groups to gain their input on 

potential changes to the UST regulations. The feedback included information about field experience 

with UST system equipment, requests not to require extensive retrofits, and general support for a focus 

on operations and maintenance activities. These meetings were held March 17, 2008, April 17, 2008, 

June 18, 2008 and November 18, 2008. 

The EPA documented a list of all of the ideas submitted by stakeholders during these meetings as well 

as through email. In January 2009, the EPA emailed this list of potential changes to the UST regulations 

to all stakeholders, and asked for their comments on the ideas. Based on all of the comments received in 

Internet Address (URL) • http://www.epa.gov


Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
response to the January 2009 email, the EPA narrowed the list of potential changes to the UST 

regulations. In June 2009, the EPA emailed the narrowed list to stakeholders. We invited stakeholders to 

submit their thoughts to us and to let us know if they would like to set up a phone call to discuss any of 

the issues. The EPA met with all industry representatives who asked to do so. Before, during, and since 

the end of the rulemaking comment period, we have held more than 100 meetings with stakeholders. 

From the list that the EPA developed through extensive stakeholder input, we drafted the proposal. 

In addition to meeting with all interested stakeholders, the EPA worked with the Small Business 

Administration's Office of Advocacy (SBA) before the proposal was published as well as during the 

public comment period. Following the EPA's rulemaking process, before publishing the proposal in the 

federal register, all other federal agencies were given an opportunity to review and comment on the 

proposal. SBA was an integral part of this process. In addition, we worked with SBA during the public 

comment period. SBA brought to our attention that many small businesses were confused by the 

proposed changes to wastewater treatment tanks. The EPA and SBA worked together to develop 

explanatory materials on these UST systems to provide the clarity sought by small business. 

In order to ensure that members of the public had an opportunity to comment on the proposal, the EPA 

extended the comment period from 90 to 150 days. The agency takes the comments we receive during 

regulatory comment periods very seriously. After receiving comments, the EPA worked diligently to 

understand industry's cost information comments so that we could thoroughly evaluate our cost analysis. 

The EPA appreciates the detailed response from commenters, and has fully considered the comments 

including the compliance costs submitted by industry representatives. We are currently working to 

determine the appropriate path forward using the comments we received to help inform our decision 

making. Some of the changes to the proposal that the EPA is considering would reduce the costs of the 

final rule. We share your concern about the potential burden on small businesses and are working to 

minimize the costs while we maintain appropriate public health and environmental protection. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may 

contact Raquel Snyder, in s Office of Congressional and Intergovernmental Relations, at 

Snyder.Raqudepa.gov or (202) 564-9586. 

Mathy Stanislaus 

Assistant Administrator