Comment submitted by Brian K. Zimmerman, Gorell Windows & Doors

The purpose of the 2008 LRRP was to reduce the lead hazards during renovations. The recent clearance proposals are more in line with lead abatement, not renovations. The additional time and expense that you are proposing will likely make many renovations unnecessarily too expensive for the average consumer. This is unfortunate because the energy efficiency improvements that could be realized would be significant. Your own studies show that the 'white glove test' showed results significantly below the regulation standards. In some of your studies, you found that even though there were elevated results, they were an improvement over the original conditions. The current Please do not over-regulate an industry to the point that you are making energy efficient home improvements unaffordable. It is also too early to be implementing changes to this rule when the effects of the existing LRRP rules have yet to be monitored for some time.