Theodore A. McConnell
Chief Counsel
Federal Highway Administration
Department of Transportation
400 Seventh Street, S.W.
Washington, D.C. 20590
Re: Training of Entry-Level Drivers of Commercial Motor Vehicles FHWA Docket No. MC-93-12
Dear Mr. McConnell:
The Office of Advocacy of the U.S. Small Business Administration (SBA) appreciates the opportunity to comment on the Federal Highway Administration's (FHWA) plans to promulgate a rulemaking that would require employers to provide adequate entry-level driving training for commercial motor vehicles. Please place these comments on the public docket.
The Office of Advocacy of the SBA was established by Congress under Public Law No. 94-305 to advocate the views of small business before Federal agencies and Congress. Advocacy is also required by §612 of the Regulatory Flexibility Act (RFA)1 to monitor agency compliance with the RFA. As the FHWA continues to develop the rule, we would appreciate an opportunity to meet with your staff to discuss the agency's effort to develop a regulatory flexibility analysis for this regulation.
As you may know, the Regulatory Flexibility Act was amended by the Small Business Regulatory Enforcement Fairness Act.2 Many federal agencies have renewed their efforts to assure they are in compliance with the spirit and letter of the law which requires an analysis of the regulatory impact on small entities and the development of regulatory alternatives. In fact, the Office of Advocacy led several seminars this summer for over 600 federal agency officials. Because no one from your office attended, I want to make a special effort to extend our assistance.
As you proceed, please contact the Office of Advocacy with any questions you may have about the Regulatory Flexibility Act. Anita Drummond of my staff can be reached at (202) 205-6532 to assist the agency. We look forward to reviewing and commenting on this rulemaking and the accompanying regulatory flexibility analysis.
Sincerely,
Jere W. Glover
Chief Counsel for Advocacy
cc: Honorable Sally Katzen
Office of Information and Regulatory Affairs
Office of Management and Budget
Old Executive Office Building
Washington, DC 20503
Dear Ms. Katzen:
Please find enclosed a copy of comments filed by the Small Business Administration's Office of Advocacy with the Federal Highway Administration (FHWA) dated October 22, 1996. Advocacy is forwarding the letter pursuant to the January 11, 1995, exchange of letters between our respective agencies. Advocacy has reminded the FHWA that the initial regulatory flexibility analysis should be prepared for their anticipated rulemaking that would require employers to provide training of entry-level drivers of commercial motor vehicles. Please forward these comments to the appropriate person on your staff for consideration. Anita Drummond of my staff is available to assist you and your office, and she can be reached at (202) 205-6532. Thank you for your cooperation.
Sincerely, Jere W. Glover Chief Counsel for Advocacy Enclosure
ENDNOTES
1 5 U.S.C. Sections 601-612
2 P.L. 104-121 (Enacted March 29, 1996)