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ASTSWMO Comments on the CCR Notice of Data Availability

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The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has reviewed the December 9, 2011 report titled EPA Must Improve Oversight of State Enforcement (the Report) and is compelled to respond due to what we believe is a misleading assessment of State Hazardous Waste Program oversight of regulated entities within their jurisdictions. ASTSWMO represents the waste management and remediation programs of the 50 States, five Territories and the District of Columbia (States). Our membership includes State waste program experts in the management and regulation of solid and hazardous waste; therefore, our comments will be directed exclusively toward those issues in the Report pertaining to State oversight under Subtitle C of the federal Resource Conservation and Recovery Act (RCRA).