Position Papers

Recent Position Papers

Cathode Ray Tubes (CRT) Management Position Paper (April 2017)

ASTSWMO 128(a) Position Paper (May 2017)

ASTSWMO Position Paper on Performance-Based Contracting at Federal Facilities (March 2017)

ASTSWMO Position Paper on Federal Regulation of Coal Combustion Residuals (October 2016)

ASTSWMO Position on Advanced Geophysical Classification for Munitions Response (January 2017)

ASTSWMO Position Paper on RCRA Subtitle C Hazardous Waste Program Information and RCRAInfo Database Operation and Maintenance (October 2016)

ASTSWMO Policy Position on UST Open Bermed Containment Systems (July 2016)

ASTSWMO Position Paper on Coal Combustion Residuals (CCR) (July 2014)

ASTSWMO Position Paper on Site Assessment Funding (May 2014)

ASTSWMO Position Paper on 128(a) Funding (May 2014)

ASTSWMO Position Paper on e-Manifest Funding (October 2013)

ASTSWMO Policy Position Paper on Federal Facilities (October 2013)

ASTSWMO Position Paper on Subtitle D Post-Closure (July 2013)

ASTSWMO Position Paper: A New Regulatory Approach to Pharmaceutical Waste Management

ASTSWMO Request for Extension of the Comment Period of the Proposed Rule Hazardous and Solid Waste Management Systems; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals from Electric Utilities (Docket ID # EPA HQ-RCRA-2009-0640) (August 2010)

ASTSWMO Position Paper on the Importance of Community Involvement

ASTSWMO comments on EPA’s proposed regulatory schemes for managing Coal Combustion By-products, including results of the February 2009 survey of State programs and a collection of State comments (April 2009)

ASTSWMO Position Paper on RCRA Subtitle C Hazardous Waste Program Information and RCRAInfo Database Operation and Maintenance (April 2009)

Community Involvement at Federal Facilities Position Paper (April 2008)

Formerly Used Defense Sites (FUDS) Position Paper (July 2007)

Department of Defense and State Memorandum of Agreement (DSMOA) Position Paper (April 2007)

Base Realignment and Closure (BRAC) Position Paper (April 2006)


Position Papers (Prior to 2006)

Formerly Utilized Site Remedial Action Program (FUSRAP) Position Paper (Revised October 2005)

ASTSWMO endorses the charter developed by the Munitions Response Committee (March 2002)

Meaningful Public Participation in Environmental Cleanups (January 1998)

On ASTSWMO's Federal Facilities Environmental Restoration Dialogue Committee's final report on "Improving Federal Facility Cleanup" (April 1996)

Comment Letters

The comments on this page were made on behalf of the entire Association. For program-specific comment letters, please visit the program's publications page.

ASTSWMO Comments on EPA Strategic Plan (October 2017)

ASTSWMO Comments on Proposed CERCLA 108(b) Rule (July 2017)

The ASTSWMO letter to the House Armed Services Committtee regarding the FY 2015 budget request for Department of Defense Environmental Restoration Programs.

ASTSWMO Letter to OMB on e-Manifest (February 2014)
» Referenced e-Manifest Position Paper

ASTSWMO Comments on Plan EJ 2014: Considering EJ in EPA’s Permitting Process, Docket ID No., EPA-HQ-OAR-2012-0452 (August 2012)

ASTSWMO letter to U.S. Nuclear Regulatory Commission in response to the Commission’s denial of ASTSWMO’s 2009 petition for rulemaking on tritium exit signs (August 2012)

ASTSWMO letter to the Senate Appropriations Committee, Subcommittee on Defense regarding FY 2013 Formerly Used Defense Sites Budget Request (May 2012)

ASTSWMO Comments on U.S. EPA Proposal to Revise UST Regulations (Docket ID No. EPA–HQ–UST–2011–0301) (April 2012)

ASTSWMO Comments on the December 9, 2011 Report titled “EPA Must Improve Oversight of State Enforcement” (December 2011)
» EPA’s Office of Inspector General responds to ASTSWMO's Comments

ASTSWMO Comments on the CCR Notice of Data Availability (November 2011)

ASTSWMO Comments on Definition of Solid Waste Notice Proposed Rule (October 2011)

ASTSWMO Comments on the MSW Characterization Report (September 2011)

ASTSWMO Comments on U.S. EPA's upcoming proposal for regulations promulgated under §108(b) of CERCLA (May 2011)

ASTSWMO Comments on U.S. EPA's Plan EJ 2014 (April 2011)

ASTSWMO Comments on Potential Addition of Vapor Intrusion (VI) Component to Hazard Ranking System (April 2011)

ASTSWMO Comments on its partnership with the Department of Defense (September 2006)

ASTSWMO Comments on the Proposed Rule, Revisions to the Definition of Solid Waste (68 FR 61558) (February 2004)


Press Releases

ASTSWMO Press Releases



More information about testimonies coming soon!


The ASTSWMO Newsletter is distributed to members via email and posted to this page once every quarter. To receive the newsletter by email, please contact Timothy Gannon, ASTSWMO Information Technology Specialist, at (202) 640-1065 or timothyg@astswmo.org.

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