Anonymous public comment

I oppose these proposed changes to remove the PE certification, even in limited scenarios, of SPCC plans. As I understand it, this rule change would allow a non-engineer to engage in the practice of engineering in violation of nearly all state engineering laws. Additionally, smaller facilities would be less likely to have the expertise on staff to self-regulate. How will they ensure that they are in compliance with the EPA SPCC regulations. Also, many small facilities, if they were not required to use the expertise of a PE, would not be aware of the SPCC requirements, or would not implement engineering controls. And without the threat of regulation, many smaller facilities might be tempted to cut costs and allow their fuel storage facilities to deteriorate. I suggest that the EPA not follow through with the implementation of this rule change.