ASTSWMO Comments on the MSW Characterization Report

The Municipal Solid Waste (MSW) Recycling Task Force within the Solid Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments in response to the U.S. Environmental Agency’s (EPA) request for input on the MSW Characterization Report and additional measurement issues in the August 2, 2011
Federal Register notice, EPA Seeking Input Materials Measurement; Municipal Solid Waste (MSW), Recycling, and Source Reduction Measurement in the U.S, (76 FR 46290).

Comments on the MSW Characterization Report Docket ID No. EPA-HQ-RCRA-2011-0178

The Municipal Solid Waste (MSW) Recycling Task Force within the Solid Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments in response to the U.S. Environmental Agency’s (EPA) request for input on the MSW Characterization Report and additional measurement issues in the August 2, 2011 Federal Register notice, EPA Seeking Input Materials Measurement; Municipal Solid Waste (MSW), Recycling, and Source Reduction Measurement in the U.S, (76 FR 46290).

The Subcommittee requests a 60-day extension of the comment period for the Environmental Protection Agency’s (EPA) supplemental proposal to revise the definition of solid waste (DSW) rule

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Hazardous Waste Subcommittee respectfully requests a 60-day extension of the comment period for the Environmental Protection Agency’s (EPA) supplemental proposal to revise the definition of solid waste (DSW) rule. The current 60-day comment period is insufficient to allow full analysis and debate among State waste managers, and so we are formally requesting an extension. The extended comment period would end November 29, 2011. EPA has committed to publishing a final rule by December 31, 2012. Therefore, granting a 60-day extension will still allow EPA plenty of time to review comments and publish a final rule.

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

On behalf of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), I would like to thank you for the time you and your staff have invested in considering our concerns on EPA’s upcoming proposal for regulations promulgated under §108(b) of CERCLA. We really appreciate the many updates, meetings, and conference calls where you have provided useful information and listened to our concerns and the concerns of State hardrock mining regulators. We will seek to continue these cooperative efforts as EPA develops the first rule under CERCLA §108(b) to address hardrock mining sites.

ASTSWMO Comments on U.S. EPA’s Plan EJ 2014

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) is providing the following comments to the 10 Dockets referenced above regarding the U.S. Environmental Protection Agency’s (EPA’s) Plan EJ 2014 draft implementation plans. In addition, specifics comments to EPA-HQ-OECA-2011-0293, EPA’s Considering Environmental Justice in Permitting Draft Implementation Plan, are attached to this letter.

Identification of Non-Hazardous Secondary Materials That Are Solid Waste

ASTSWMO appreciates the opportunity to provide comments on the proposed rule, Identification of Non-Hazardous Secondary Materials That Are Solid Waste, published in the Federal Register on June 4, 2010 (75 FR 3 1844). These comments have not been reviewed or adopted by the ASTSWMO Board of Directors. In addition, individual State or Territorial solid waste programs may also provide comments based on their perspectives and experiences. In commenting on this solid waste management proposal — which was proposed concurrently by the U.S. Environmental Protection Agency with the air emission requirements under Clean Air Act (CAA) section 112 for indusfrial, commercial, and institutional boilers and process heaters, as well as air emission requirements under CAA section 129 for commercial and industrial solid waste incineration units – we recognize that our State colleagues who regulate and administer air programs may also provide EPA with their views on issues raised in the proposed rule.

Final Performance Systems Survey, Developed by the Performance Systems Task Force

The Performance Systems Task Force of the Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has engaged in activities to coordinate States’ efforts in identifying opportunities for facility specific flexibility under the RCRA program to be implemented by States that is designed to result in more protective, yet enforceable, environmental management and outcomes. As such, the Task Force has concluded that there exists to “one size fits all” performance system that would satisfy the goal of needed flexibility among the different State programs.

ASTSWMO Comments on its partnership with the Department of Defense

It has come to the attention of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) that questions have been raised about the nature of our association and the work our members do, particularly in relation to the federal government. The purpose of this letter is to clearly state what ASTSWMO is and does and to highlight the successful partnership ASTSWMO and the Department of Defense (DOD) have had over the last ten years.

ASTSWMO Comments on the Proposed Rule, Revisions to the Definition of Solid Waste

The Board of Directors of the Association of State and Territorial Solid Waste Management Officials (herein referred to as “ASTSWMO”) has reviewed the October 28, 2003 proposed rule (68 FR 61558) containing suggested revisions to the definition of solid waste. The ASTSWMO Board is comprised of 14 senior-level State waste program experts representing all geographic and regional areas of the country, and the comments contained herein reflect their collective technical opinions regarding major aspects of the rule proposal. The Board is submitting this letter stating its support of separate comments submitted to the Docket by ASTSWMO’s Hazardous Waste Recycling Task Force (“Task Force”) regarding three areas discussed in the proposal of significant importance to States: notification, legitimacy criteria, and exclusion of on-site recycling. Individual States will also submit comments reflecting their own unique perspectives on the proposed components of the rule.