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Major Clark, Assistant Chief Counsel for the Office of Advocacy testified before United States House of Representatives Committee on Small Business, Subcommittee on Contracting and Workforce and, and the United States House of Representatives Committee on Veterans' Affairs, Subcommittee on Oversight and Investigations.
Major L. Clark, III.
Assistant Chief Counsel for Advocacy
The U.S. Small Business Administration's Office of Advocacy (Advocacy) submits the following comments on the Environmental Protection Agency (EPA) notice of proposed consent decree under the Clean Air Act, published on December 7, 2012. In this notice, EPA invites public comment on a consent decree that would require rulemaking under section 112(d) of the Clean Air Act to establish a National Emission Standard for Hazardous Air Pollutants (NESHAP) for brick and structural clay products manufacturing facilities and clay ceramics manufacturing facilities. Advocacy is concerned that the timeline for rulemaking required by this consent decree does not provide sufficient time for EPA to fully comply with the Regulatory Flexibility Act (RFA), including the requirement to conduct a Small Business Advocacy Review (SBAR) panel in support of a notice of proposed rulemaking.
Advocacy Report Explores Why a Firm Hires Its First Employee
Report gives three top policy directions to increase employment.
On behalf of the U.S. Small Business Administration Office of Advocacy, I am writing to express concerns regarding AT&T’s proposed special access tariff revisions, filed November 25, 2013, which would eliminate the availability of certain discounted long-term special access contracts with the carrier. Advocacy is greatly concerned that the changes will result in significant downstream cost increases for small business customers, including both small competitive local exchange carriers as well as end users. Additionally, Advocacy has persistent concerns regarding state of competition in the special access market, and its effect on small business customers.
Crossing the Employer Threshold: Determinants of Firms Hiring Their First Employee, a report by Robert W. Fairlie, analyzes the factors that lead new businesses without employees to hire their first employee; this is a significant aspect of small business job creation.
The Office of Advocacy (“Advocacy”) submits these comments on the U.S. Fish and Wildlife Service’s (“FWS”) proposed rule, Endangered and Threatened Wildlife and Plants; Proposed Endangered Status for Gunnison Sage-Grouse and Proposed Critical Habitat for Gunnison Sage-Grouse. Advocacy is concerned that FWS has improperly certified the proposed rule. Advocacy believes FWS should publish an Initial Regulatory Flexibility Analysis (“IRFA”).
Congratulations on your recent confirmation as Chairman of the Federal Communications Commission. I would like to extend my best wishes as you assume leadership of an agency that is vitally important to our nation’s small businesses. Many of the issues the FCC will be confronting over the coming months are at the heart of the Small Business Administration Office of Advocacy’s mission to ensure that federal regulation preserves the ability of small businesses to compete and innovate in today’s economy.
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Two Sides to Internet Sales Tax
Report gives objective analysis for small businesses and policymakers.
The October-November issue of “The Small Business Advocate” features new data on veteran business owners that shows interesting demographic changes.
Advocacy report estimates the utilization of the largest federal tax expenditure provisions by small and large businesses in 2013.
As the popularity of online shopping has grown, states have seen their sales tax revenues drop. The Supreme Court has ruled that states cannot require a company to collect sales tax on transactions with their residents when the company has no physical presence in the state. Federal legislation has been introduced over the past several years to authorize online sales tax collection. With small business owners on both sides of the issue, the Office of Advocacy recognized the need for objective research for small businesses and policymakers. This report analyzes the number of firms that will be affected by the small seller exemption (SSE) if current legislation passes and how much e-commerce is likely to be affected.
On November 8, 2013, the Occupational Safety and Health Administration (OSHA) published its proposed Improve Tracking of Workplace Injuries and Illnesses rule in the Federal Register. OSHA’s proposed rule would amend its recordkeeping regulations to add requirements for the electronic submission of injury and illness information employers are already required to keep under OSHA’s regulations for recording and reporting occupational injuries and illnesses.
On November 8, 2013, the Occupational Safety and Health Administration (OSHA) published its proposed Improve Tracking of Workplace Injuries and Illnesses rule in the Federal Register. OSHA&rs
On November 6, 2013, the United States International Trade Commission (USITC) announced the new date for the Washington, DC public hearing postponed because of the federal government shutdown. The hearing is scheduled for November 20, 2013 at 9:30 a.m. The USITC is seeking information for a report that will identify trade-related barriers that U.S. small and medium-sized enterprises (SMEs) perceive as disproportionately (compared to large firms) affecting their exports to the European Union (EU).
On November 6, 2013, the United States International Trade Commission (USITC) announced the new date for the Was
The National Institute of Standards and Technology (NIST) seeks comments on a preliminary version of the Cybersecurity Framework (“preliminary Framework”). NIST is developing the Framework as directed by Executive Order 13636, “Improving Critical Infrastructure Cybersecurity.” The Framework will consist of standards, methodologies, procedures and processes that align policy, business, and technological approaches to address cyber risks.
The National Institute of Standards and Technology (NIST) seeks comments on a preliminary version of the Cybersecurity Framework (“preliminary Framework”).
For Release: April 18, 2013 Con
The Quarterly Employment Bulletin assesses small business job trends using the latest release of government data.
Tax expenditures are provisions in the tax law designed to benefit specific groups of taxpayers. They are similar to spending programs but generally do not involve direct federal outlays. Rather, they work through the income tax system, taking the form of special credits, exemptions, deductions, exclusions, and preferential rates. This study estimates the utilization of federal tax expenditure provisions by small and large businesses in 2013.
On October 25, 2013, the Occupational Safety and Health Administration (OSHA) announced it was extending the comment period and other deadlines for its proposed Occupational Exposure to Crystalline Silica (Silica) rule, published in the Federal Register on September 13, 2013. The proposed rule would amend OSHA’s existing silica standard by reducing the permissible exposure limit to 50 micrograms of respirable crystalline silica per cubic meter of air (50 mg/m3), calculated as an 8-hour time-weighted average. The proposed rule also includes ancillary provisions for employee protection, such as preferred methods for controlling exposure, respiratory protection, medical surveillance, hazard communication, and recordkeeping. OSHA is proposing two separate regulatory texts — one for general industry and maritime, and the other for construction.
On October 25, 2013, the Occupational Safety and Health Administration (OSHA) announced it was extending the comment period and other deadlines for its proposed Occupational Exposure to Crystalline
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