Delegation of director's discretion is needed. Many believe that the delegation could generally be limited to establishing alternatives to nonquantifiable work practice standards, certain types of monitoring requirements, and recordkeeping and reporting requirements. We continue to believe that EPA can and should delegate to state and local agencies some of its authorities provided under the subpart A General Provisions. We recognize EPA's key oversight role and believe that it is an integral part of any delegation of authorities. However, we believe that delegating a reasonable amount of decisionmaking authority to state and local agencies will allow EPA to focus on issues with greater emission reductions impacts.
Partial approval is needed.
We understand that EPA may be working on federal rulemaking on this issue.