The Honorable Ron Johnson
Chairman, Homeland Security and Government Affairs Committee
Washington, DC 20510
Dear Mr. Chairman;
The National Roofing Contractors Association (NRCA) strongly supports regulatory reform legislation the committee will
consider on October 7, 2015. This package of reforms will reduce the burden of excessive regulations on job creators
and the U.S. economy. NRCA commends you for your leadership on this important issue and remains committed to working
with Congress on a bipartisan basis to achieve true regulatory reform.
Established in 1886, NRCA is one of the nation's oldest trade associations and the voice of professional roofing
contractors worldwide. NRCA has approximately 3,500 members in all 50 states who are typically small, privately held
companies, with the average member employing 45 people and attaining sales of about $4.5 million per year.
Roofing contractors continue to face an unprecedented array of regulations issued by federal agencies, with even more
regulations expected in the coming years. In 2011, the U.S. Small Business Administration estimated the total cost of
compliance with all federal regulations nationally was $1.75 trillion, with the greatest burden falling on small
businesses. The cumulative burden of often counter-productive regulations is highly disruptive to entrepreneurs seeking
to start and grow a business. Firms of all sizes consistently cite growing regulatory burdens and the uncertainty this
causes is a major obstacle to hiring.
NRCA supports the following bipartisan regulatory reform initiatives and urges members of the committee to approve
these measures and send them to the full Senate for consideration.
Regulatory Improvement Act of 2015 (S. 708). This legislation takes the approach of the successful Base Realignment and
Closure (BRAC) Commissions by establishing a bipartisan, blue-ribbon commission of regulatory experts with the task of
developing recommendations for elimination, consolidation, or repeal of regulations. The commission will have the
ability to take testimony, consult with industry and agency experts, and solicit public comments in preparing a
proposal to Congress, which will then vote on the recommendations as package.
Independent Agency Regulatory Analysis Act of 2015 (S. 1607). NRCA is aware that independent federal agencies
including the SEC, the CFTC, the NLRB, and othersexercise vast power over major sectors of our economy, yet are
exempt from some regulatory requirements, including cost-benefit analysis of major rules (those with annual impacts of
$100 million or more). These agencies are also exempt from review by the Office of Information and Regulatory Affairs
(OIRA), which provides a valuable check on the quality of agency rulemakings. This bill would close that gap by
authorizing the president to bring independent agencies into the same analysis and review process of the other
Principled Rulemaking Act of 2015 (S. 1818). This legislation codifies a series of good government and rulemaking
principles that have largely been in effect for over 20 years, across administrations of both parties. In short, it
ensures that agencies promulgate rules based on necessity, using best available information, and provide opportunity
for meaningful public input in the regulatory development process.
Early Participation in Regulations Act of 2015 (S. 1820). This legislation requires that, for major rules, federal
agencies must employ an Advanced Notice of Proposed Rulemaking, which engages the public and stakeholders earlier in
the process of developing the regulation. This will ensure there is more opportunity for active and meaningful public
input in the earliest stages of development of major regulations.
Smarter Regs Act of 2015 (S. 1817). This legislation builds an automatic lookback requirement into the rulemaking
process for all major rules. Under this requirement, federal agencies, working with OIRA guidance, will need to create
a plan to reassess the rule's effectiveness, cost, and achievement of its purpose within 10 years of going into
NRCA believes this series of reforms will provide more opportunities for public input and more effective cost/benefit
analysis during the development of regulations. Ultimately, enactment of this legislation will help ensure that
regulations are not burdensome on employersour nation's job creatorswhile also still achieving public policy
goals. These reforms are needed now more than ever to provide businesses with the certainty they need to create jobs
and get our economy back on track.
NRCA urges members of the committee to approve these regulatory reforms expeditiously. Thank you for your consideration
of NRCA's views on this crucial issue. If you have questions or need more information please contact Duane Musser or
Drew Felz at (202) 546-7584.
Tecta American Southeast LLC