The certification is being abused, the 605(b) certification. Agencies are abusing that to try and get out of having to perform small business impact analyses that the RFA requires.
Robert Smith: “The certification is being abused, the 605(b) certification. Agencies are abusing that to try and get out of having to…”
Editor's note · Context
Smith criticizes the misuse of certification to bypass required analyses for small business impacts.
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I am committed to a resolution of this situation that enables the Steens Mountain running camp to continue its historic operations on the mountain.
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Agencies should be forced to consider all costs along with benefits of each rule.
I think there are a couple of steps that I would recommend. First, agencies must be forced to consider the indirect costs of the regulations on small businesses.





