The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) and its members from the 50 States, 5 Territories and the District of Columbia (States), routinely work with our partners at the EPA to identify opportunities for improvements to the Superfund Program. In recent months, EPA contacted ASTSWMO for help collecting input from States on how to improve the federal site assessment program. The ASTSWMO Site Assessment Focus Group noticed several trends when compiling responses from States and this issues letter identifies those trends.
The ASTSWMO Materials Management Subcommittee submitted comments to the docket on June 29, 2026 regarding the EPA proposed rule, Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy CCR/CCRMU Amendments, that was published in the Federal Register on April 13, 2026.
The ASTSWMO Materials Management Subcommittee submitted comments to the docket on June 30, 2026 in support of the EPA proposal, Virginia: Approval of State Coal Combustion Residuals Permit Program, that was published in the Federal Register on May 4, 2026.
ASTSWMO and the CEC Steering Committee support EPA’s ongoing efforts to develop guidance regarding the destruction and disposal of PFAS and PFAS-containing materials. This remains an area of active research and rapidly evolving understanding. EPA’s continued commitment to updating this guidance to reflect emerging science, technological advances, and implementation experience is appreciated. The transition to an annual update cycle demonstrates EPA’s commitment and recognition of the importance of providing timely information to States and other stakeholders responsible for managing PFAS-containing materials.
The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Board of Directors appreciates the opportunity to provide the enclosed comments on the Draft FY 2026-2030 EPA Strategic Plan.
The ASTSWMO Board of Directors is encouraged with EPA’s draft Strategic Plan (SP) to accelerate cleanup of contaminated sites and promote recycling. However, when read alongside the President’s proposed FY27 Budget, this language could suggest shifting greater responsibility for delegated land programs to States without sufficient federal funding. That outcome would be highly problematic and could undermine EPA’s goal of revitalizing land and preventing contamination.
The ASTSWMO Hazardous Waste Subcommittee submitted comments to EPA on May 4, 2026 regarding the proposed Paper Manifest Sunset Rule; Modification of the Hazardous Waste Manifest Regulations.
The ASTSWMO Materials Management Subcommittee submitted comments to EPA on November 3, 2025 supporting EPA’s proposed approval of Wyoming’s coal combustion residuals (CCR) permit program.
The ASTSWMO Hazardous Waste Subcommittee provided comments on September 16, 2025 to the EPA e-Manifest Advisory Board for the Advisory Board’s September 2025 virtual public meeting on the theme, “Accelerating the Future: Phasing out Paper Manifests to Unlock the Full Potential of e-Manifest.”
The ASTSWMO Materials Management Subcommittee submitted comments to EPA on July 15, 2025 supporting EPA’s proposed approval of North Dakota’s coal combustion residuals (CCR) permit program.
The ASTSWMO Hazardous Waste Subcommittee provided comments to the EPA e-Manifest Advisory Board on September 10, 2024 regarding EPA’s proposed program priorities for FY 2026/2027.
