SPCC Support Letter Request for a Minimum One Year Extension of Implementation Date

With all of the amendments and changes to the SPCC rule, the regulated community is placed in a race against time to comply, assuming the current 2009 implementation dates are not extended. The amendments have significantly altered many elements of the 2002 SPCC rule, which will require fiscal planning and other business related resource allocations. Granted, the amendments have afforded increased clarity to the regulated community. However, the protracted timeline and the uncertainty of the outcome, relative to the final amendments warrant extension of the implementation dates, in our opinion. Therefore, we respectfully request the EPA’s careful consideration in extending the current 2009 implementation dates at least one year.