Doesn't the June 18 memorandum extend an unfair advantage to members of the regulated community who have delayed compliance with the certification and training requirements and punish those who have complied with the rule?
EPA does not believe that allowing more time for firms to become certified and renovators to become trained extends an unfair advantage. To the contrary, firms that are already certified can benefit by continuing to advertise that they are certified and may continue to use EPA's program logo during this interim period. The Agency also recognizes the challenges some are facing in obtaining training in a timely fashion and is providing additional time to individual renovators to enroll in and take the required training courses before the Agency actively enforces the individual renovator requirements. EPA is committed to encouraging additional training opportunities in every state to meet this demand for classes.