2009/05/20-Comment from Kevin Leuer Requesting Extension of Comment Period

The comment period is insufficient to properly review, analyze and determine the impact of the proposed changes. The format of the REP Manual does not support and expeditious review because the changes are not highlighted or clearly identified. The 366 pages of material are very detailed and contain significant changes that will have a direct impact on the preparedness program. The impact of requiring HSEEP and NIMS is huge and will take several weeks to identify the impact and the cost for compliance with the new requirements. The proposed changes will have a significant impact on State, County and Local governments and more time is needed to consider the impacts of these changes. Many of the changes that are included in these documents have not been discussed with State or Local jurisdictions and have far reaching consequences. Without having any discussion about the changes in advance and seeing them for the first time it’s a lot to digest and get a handle on in such a short period of time, and therefore. I am requesting that the comment period be extended to 180 days.