AAMA Responds to EPA's Call for Comment on LRRP Regulations
SCHAUMBURG, IL - The American Architectural Manufacturers Association (AAMA) has responded to the Environmental Protection Agency's (EPA) call for comments on existing regulations. The EPA request was made following the issuance of Executive Order 13563, which seeks to identify regulations that are economically damaging, impede job growth and impact the opportunity to enhance energy efficiency. AAMA provided comments and information regarding the economic impact of the EPA’s 2010 implementation of the Lead: Renovation, Repair and Painting (LRRP) regulations and amendment to the “opt-out” provision.
Rich Walker, AAMA's President and CEO, said, “The AAMA response questions the EPA’s decision to move forward on this rule based on limited and questionable scientific data; the dichotomy of CDC research, which clearly exhibits a rapid and continuous decrease in blood lead levels during the same period of increased pre-LRRP home renovation activity; the continued use of lead test kits that do not meet the EPA, September 1, 2010, required false-positive criteria; and the severe economic burden of increasing the original LRRP cost to $1.3 billion.”
Walker also reports that AAMA questions the EPA’s ability to properly monitor compliance activity on the 7.2 million renovation events it suggests will occur during the first year of implementation and the subsequent 5.4 million events where test kits will exhibit a positive result and LRRP practices are mandated.
Walker stated that, “The removal of the opt-out clause continues to impede the recovery of the residential fenestration industry by passing along significant and, at times, unwarranted renovation costs to homeowners. It is vital that the EPA understands the full impact that these regulations continue to have on the building products industry as well as the construction industry as a whole.”
Rich Walker, AAMA's President and CEO, said, “The AAMA response questions the EPA’s decision to move forward on this rule based on limited and questionable scientific data; the dichotomy of CDC research, which clearly exhibits a rapid and continuous decrease in blood lead levels during the same period of increased pre-LRRP home renovation activity; the continued use of lead test kits that do not meet the EPA, September 1, 2010, required false-positive criteria; and the severe economic burden of increasing the original LRRP cost to $1.3 billion.”
Walker also reports that AAMA questions the EPA’s ability to properly monitor compliance activity on the 7.2 million renovation events it suggests will occur during the first year of implementation and the subsequent 5.4 million events where test kits will exhibit a positive result and LRRP practices are mandated.
Walker stated that, “The removal of the opt-out clause continues to impede the recovery of the residential fenestration industry by passing along significant and, at times, unwarranted renovation costs to homeowners. It is vital that the EPA understands the full impact that these regulations continue to have on the building products industry as well as the construction industry as a whole.”
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