Comment Letters

2024

ASTSWMO Hazardous Waste Subcommittee Comments re: Listing of Specific PFAS as Hazardous Constituents Proposal (4/9/2024) - The ASTSWMO Hazardous Waste Subcommittee submitted comments to EPA on April 8, 2024 regarding the proposed rule, Listing of Specific PFAS as Hazardous Constituents. ... Read More
ASTSWMO Hazardous Waste Subcommittee Comments re: Proposed Statutory Definition of Hazardous Waste (3/26/2024) - The ASTSWMO Hazardous Waste Subcommittee submitted comments to EPA on March 26, 2024 regarding the proposed rule, Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units. ... Read More
ASTSWMO’s comments regarding the Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities (3/21/2024) - On March 19, 2024, The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) provided comments regarding the U.S. Environmental Protection Agency’s (EPA) Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities. ... Read More
ASTSWMO Hazardous Waste Subcommittee Recommendation for a Charge Question to the EPA e-Manifest Advisory Board (3/19/2024) - The ASTSWMO Hazardous Waste Subcommittee recommended a potential charge question in a comment letter submitted to EPA on March 19, 2024 in response to the February 21, 2024 Federal Register notice, Hazardous Waste Electronic Manifest System (“e-Manifest”) Advisory Board: Request… ... Read More
ASTSWMO CAP Task Force Comments re: Draft Memo Integrating Climate Resilience into Hazardous Waste Permitting (2/6/2024) - The Corrective Action and Permitting (CAP) Task Force within ASTSWMO’s Hazardous Waste Subcommittee provided comments to EPA on January 26, 2024 regarding the draft memo, Integrating Climate Change Adaptation Considerations into Hazardous Waste Permitting. ... Read More
ASTSWMO SMM Task Force Comments re: Draft Strategy for Reducing Food Loss and Waste and Recycling Organics (2/6/2024) - The Sustainable Materials Management (SMM) Task Force within ASTSWMO’s Materials Management Subcommittee submitted comments to EPA on February 1, 2024 regarding the Draft Strategy for Reducing Food Loss and Waste and Recycling Organics. ... Read More

2023

ASTSWMO Hazardous Waste Subcommittee Comments on Proposed RCRA Refrigerants Recycling Standards (12/18/2023) - On December 18, 2023, the ASTSWMO Hazardous Waste Subcommittee submitted comments to EPA regarding proposed alternative standards for certain ignitable spent refrigerants under the Resource Conservation and Recovery Act (RCRA) within the proposed rule, Phasedown of Hydrofluorocarbons: Management of Certain… ... Read More
ASTSWMO Materials Management Subcommittee Comments on CCR Legacy Surface Impoundments NODA (12/11/2023) - On December 11, 2023, the ASTSWMO Materials Management Subcommittee submitted comments to EPA regarding the Notice of Data Availability (NODA) for Coal Combustion Residuals (CCR) Legacy Surface Impoundments and CCR Management Units. ... Read More
ASTSWMO Hazardous Waste Subcommittee Comments re: EPA Used Drum Management and Reconditioning ANRPM (11/27/2023) - The ASTSWMO Hazardous Waste Subcommittee submitted comments to EPA on November 22, 2023 regarding the EPA Used Drum Management and Reconditioning Advance Notice of Proposed Rulemaking (ANPRM). ... Read More
Task Force Comments on EPA Memorandum: Integrating Climate Change Adaptation Considerations into the Resource Conservation and Recovery Act Corrective Action Process (11/16/2023) - On November 16, 2023, the Corrective Action and Permitting (CAP) Task Force within ASTSWMO’s Hazardous Waste Subcommittee provided comments to EPA on the draft memo, Integrating Climate Change Adaptation Considerations into the Resource Conservation and Recovery Act Corrective Action Process. ... Read More
ASTSWMO Materials Management Subcommittee Comments regarding EPA’s Proposed Denial of Alabama’s CCR Permit Program (10/13/2023) - The ASTSWMO Material Management Subcommittee submitted comments to EPA on October 13, 2023 regarding EPA’s proposed denial of Alabama’s State Coal Combustion Residuals (CCR) Permit Program. ... Read More
ASTSWMO Hazardous Waste Subcommittee Comments on EPA Technical Correction Rule (10/13/2023) - The ASTSWMO Hazardous Waste Subcommittee provided comments to EPA on October 10, 2023 regarding EPA Technical Corrections for the Hazardous Waste Generator Improvements Rule, the Hazardous Waste Pharmaceuticals Rule, and the Definition of Solid Waste Rule. ... Read More
2023 ASTSWMO Materials Management Subcommittee Comments on National Strategy to Prevent Plastic Pollution (8/28/2023) - The ASTSWMO Materials Management Subcommittee submitted comments to the U.S. Environmental Protection Agency (EPA) on July 31, 2023 regarding EPA’s Draft National Strategy to Prevent Plastic Pollution. ... Read More
2023 ASTSWMO Task Force Comments Regarding the Proposed Legacy CCR SI Rule (8/15/2023) - The Disposal and Conversion Task Force submitted comments regarding the U.S. Environmental Protection Agency’s (EPA) proposed rule on Legacy Coal Combustion Residuals (CCR) Surface Impoundments and CCR Management Units to EPA on July 17, 2023. ... Read More
ASTSWMO’s comments regarding the U.S. Environmental Protection Agency’s (EPA) Advanced Notice of Proposed Rulemaking (ANPRM) on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances (6/20/2023) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) provides comments regarding the U.S. Environmental Protection Agency’s (EPA) Advanced Notice of Proposed Rulemaking (ANPRM) on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances. ... Read More
ASTSWMO Comments on U.S. EPA’s Proposed PFAS National Priority Drinking Water Regulation (6/20/2023) - ASTSWMO Comments on U.S. EPA’s Proposed PFAS National Priority Drinking Water Regulation; Docket ID No. EPA-HQ-OW-2022-0114 ... Read More
ASTSWMO PSC Comments on EPA’s National Enforcement and Compliance Initiatives for Fiscal Years 2024-2027 (3/23/2023) - The ASTSWMO Program Steering Committee provided comments regarding the U.S. Environmental Protection Agency’s (EPA) National Enforcement and Compliance Initiatives (NECIs) for Fiscal Years 2024-2027. The proposed NECIs were published in the Federal Register on January 12, 2023 (88 FR 2093). ... Read More
2023 Hazardous Waste Subcommittee Comments to the EPA e-Manifest Advisory Board (2/24/2023) - The ASTSWMO Hazardous Waste Subcommittee provided comments on February 21, 2023 to the EPA Hazardous Waste Electronic System (“e-Manifest”) Advisory Board on e-Manifest program priorities and user fees for Fiscal Years 2024 and 2025, the theme of the Advisory Board’s… ... Read More
ACWA, ASDWA, ASTSWMO, ECOS PFAS PBT Reporting Exemption TRI-EPCRA Comments (2/8/2023) - ECOS, ACWA, ASDWA, and ASTSWMO commented on U.S. EPA’s proposed rule on Changes to Reporting Requirements: Per- and Polyfluoroalkyl Substances and to Supplier Notifications for Chemicals of Special Concern; Community Right-to-Know Toxic Chemical Release Reporting. ... Read More

2022

ASTSWMO Comment Letter to EPA’s Proposed Rule to Designate PFOA and PFOS as CERCLA Hazardous Substances (11/4/2022) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments regarding the U.S. Environmental Protection Agency’s (EPA) Proposed Rule, Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as Comprehensive Environmental Response, Compensation,… ... Read More
2022 SWDC Task Force Comments on Proposed CCR Part A Decisions (3/25/2022) - The Solid Waste Disposal and Conversion Task Force provided comments to EPA on March 23, 2022 regarding proposed Coal Combustion Residuals (CCR) Part A decisions. ... Read More
Modernizing Public Notice for RCRA Hazardous Waste Permitting and Other Actions (2/25/2022) - The Corrective Action and Permitting Task Force within the Hazardous Waste Subcommittee provided comments on February 11, 2022 regarding EPA’s Modernizing Public Notice for RCRA Hazardous Waste Permitting and Other Actions. ... Read More

2021

2021 CME Task Force Comments on Draft RCRA Air Emissions Memo (11/19/2021) - The Compliance Monitoring and Enforcement (CME) Task Force within the Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to comment on the draft memorandum, “Applicability of Resource Conservation and Recovery… ... Read More
ASTSWMO COMMENTS on EPA’s Draft FY 2022 – 2026 EPA Strategic Plan (11/18/2021) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) is an association representing the waste management and remediation programs of the 50 States, five Territories and the District of Columbia (States). The ASTSWMO Board of Directors appreciates the… ... Read More
ACWA, ASDWA, ASTSWMO & ECOS Joint Comment Letter to EPA on CWA Effluent Limitations Guidelines and Standards: OCPSF Point Source Category Proposed Rulemaking (5/18/2021) - ASTSWMO joined ACWA, ASDWA and ECOS in submitting a joint comment letter to EPA on its proposed rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards (EPA-HQ-OW-2020-0582) relating to the effluent limitations guidelines, pretreatment standards and new source performance standards… ... Read More
Tanks Subcommittee Comments on US EPA Proposed Rule for E15 Fuel Dispenser Labeling and Compatibility with USTs (4/16/2021) - Comments by the ASTSWMO Tanks Subcommittee regarding US EPA’s Proposed Rule for E15 Fuel Dispenser Labeling and Compatibility with Underground Storage Tanks (86 FR 5094) provided to EPA on April 15, 2021. ... Read More
Sustainable Materials Management Task Force Comments on Recycling Rate Measurement (3/9/2021) - Comments by the ASTSWMO Sustainable Materials Management (SMM) Task Force regarding EPA’s measurement methodology for increasing the national recycling rate to 50% by 2030, provided to EPA on March 8, 2021. ... Read More
ASTSWMO Hazardous Waste Subcommittee comments to EPA’s e-Manifest Advisory Board (2/25/2021) - The ASTSWMO Hazardous Waste Subcommittee provided comments to the EPA Hazardous Waste Electronic System (“e-Manifest”) Advisory Board for the Board’s public meeting on March 2-4, 2021, on the meeting theme, “Looking Ahead: Setting E-Manifest Program Priorities and User Fees for… ... Read More
ASTSWMO CEC Steering Committee Comments to EPA’s Interim PFAS Destruction and Disposal Guidance (2/22/2021) - On February 19, 2021, the ASTSWMO CEC Steering Committee submitted comments to EPA on their Interim PFAS Destruction and Disposal Guidance. Visit Docket EPA-HQ-OLEM-2020-0527 on Regulations.gov to review the interim guidance document and other supporting materials and public comments. ... Read More
ASTSWMO Solid Waste Disposal and Conversion Task Force Comments on ANPRM for CCR Legacy Surface Impoundments (2/11/2021) - The Solid Waste Disposal and Conversion Task Force of ASTSWMO’s Materials Management Subcommittee submitted comments to EPA on February 11, 2021 regarding the Advance Notice of Proposed Rulemaking (ANPRM) for Coal Combustion Residuals (CCR) Legacy Surface Impoundments. ... Read More
ASTSWMO Comments on EPA State Review Framework FY2021 (2/2/2021) - Compliance Monitoring and Enforcement Task Force within the ASTSWMO Hazardous Waste Subcommittee provided feedback regarding the fiscal year performance data that the U.S. Environmental Protection Agency (EPA) proposed to use in conducting State Review Framework (SRF) reviews in FY2021. ... Read More

2020

ASTSWMO Materials Management Subcommittee Comments on 2020 EPA Draft National Recycling Strategy (12/15/2020) - The Materials Management Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on EPA’s Draft National Recycling Strategy and the new U.S. National Recycling Goal to increase the national recycling… ... Read More
2020 SMM Task Force Comments on EPA’s National Recycling Goals (10/2/2020) - Members of the Sustainable Materials Management (SMM) Task Force within the Materials Management Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) have been participants in EPA’s America Recycles Day efforts to create the National Framework… ... Read More
ASTSWMO Comments to Nuclear Regulatory Commission Proposed Interpretative Rule (7/20/2020) - The Materials Management and Hazardous Waste Subcommittees of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciate the opportunity to jointly provide comments on the U.S. Nuclear Regulatory Commission’s (NRC’s) Proposed Interpretive Rule, Transfer of Very Low-Level… ... Read More
ASTSWMO Solid Waste Disposal and Conversion Task Force Comments Proposed to Federal CCR Permit Program (7/16/2020) - The Solid Waste Disposal and Conversion Task Force within the Materials Management Subcommittee of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on the U.S. Environmental Protection Agency (EPA) proposed rule,… ... Read More

2019

Draft Interim Recommendations for Addressing Groundwater Contaminated with PFOA and PFOS (6/12/2019) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on the U.S. Environmental Protection Agency’s (EPA’s) Draft Interim Recommendations for Addressing Groundwater Contaminated with PFOA and PFOS. ASTSWMO is an association representing… ... Read More
ASTSWMO Tanks Subcommittee sends comments to E-15 Waiver (5/30/2019) - The EPA Proposed Rule would modify fuel regulations to allow year-round sales of gasoline blended with up to 15 percent ethanol. ... Read More
State environmental associations respond to EPA’s PFAS Action Plan April 2019 (4/5/2019) - We appreciate the U.S. Environmental Protection Agency’s (EPA’s) development of its Per-and Polyfluoroalkyl Substances (PFAS) Action Plan in response to the feedback EPA received during the May 2018 PFAS National Leadership Summit and other public engagements. The Action Plan demonstrates… ... Read More

2017

ASTSWMO Comments on EPA Strategic Plan (10/31/2017) - 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 2018-2022 EPA Strategic Plan. ASTSWMO is an association representing the waste management and remediation… ... Read More
ASTSWMO Comments on Proposed CERCLA 108(b) Rule (7/10/2017) - On behalf of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), I would like to submit the following comments and concerns on the proposed rule for Financial Responsibility Requirements Under CERCLA §108(b) for Classes of Facilities in… ... Read More

2015

Comments on the Proposed Revision to the RD&D Permits Rule for MSW Landfills (12/16/2015) - ASTSWMO appreciates the opportunity to provide comments on the U.S. Environmental Protection Agency (EPA) proposed rule, Revision to the Research, Development and Demonstration (RD&D) Permits Rule for Municipal Solid Waste Landfills, published in the Federal Register on November 13, 2015… ... Read More

2014

The ASTSWMO letter to the House Armed Services Committtee regarding the FY 2015 budget request for Department of Defense Environmental Restoration Programs. (5/6/2014) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) respectfully requests that the House Armed Services Committee carefully review and reconsider the Fiscal Year (FY) 2015 budget request for the Department of Defense (DOD) Environmental Restoration Programs. ... Read More
ASTSWMO Letter to OMB on e-Manifest (2/6/2014) - The Board of Directors of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) recently adopted the enclosed position paper, "e-Manifest System Development Funding". We wanted to share this position paper with you so that you are aware… ... Read More

2013

LUST Task Force and Tanks Subcommittee Comments on the Draft U.S. EPA “Guidance for Addressing Petroleum Vapor Intrusion at Leaking Underground Storage Tank Sites” (6/17/2013) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Tanks Subcommittee, through the Leaking Underground Storage Tank (LUST) Task Force, is providing the following comments to the April 2013 draft guidance titled, “Guidance for Addressing Petroleum Vapor Intrusion… ... Read More

2012

ASTSWMO Comments on Plan EJ 2014: Considering EJ in EPA’s Permitting Process (8/24/2012) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) is providing the following comments to the U.S. Environmental Protection Agency regarding “EPA Activities to Promote Environmental Justice in the Permit Application Process” (77 FR 38051), published in the… ... Read More
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 (8/2/2012) - Thank you for your response dated December 2, 2011, to the petition for rulemaking (PRM) submitted to the U.S. Nuclear Regulatory Commission (NRC) in December 2009 by the Association of State and Territorial Solid Waste Management Officials (ASTSWMO). We are… ... Read More
ASTSWMO letter to the Senate Appropriations Committee, Subcommittee on Defense regarding FY 2013 Formerly Used Defense Sites Budget Request (5/21/2012) - The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) respectfully requests that the Senate Appropriations Committee, Subcommittee on Defense carefully review and reconsider the FY 2013 Budget Request for the Department of Defense (DOD) program dedicated to restoring… ... Read More
ASTSWMO Comments on U.S. EPA Proposal to Revise UST Regulations (4/11/2012) - ASTSWMO offers the following comments on U.S Environmental Protection Agency's proposed rule-making for the Underground Storage Tank Regulations, published in the Federal Register on November 18, 2011 ... Read More
Identification of Non-Hazardous Secondary Materials That Are Solid Waste (2/16/2012) - The Municipal D Waste Task Force within the Materials Management Subcommittee of the Association of State and Tenitorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments regarding the U.S. Environmental Protection Agency's ("EPA") proposed Commercial and Industrial… ... Read More

2011

ASTSWMO Comments on the December 9, 2011 Report titled “EPA Must Improve Oversight of State Enforcement” (12/15/2011) - 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… ... Read More