Comment Letters

2021

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
Comments on the MSW Characterization Report Docket ID No. EPA-HQ-RCRA-2011-0178 (11/16/2011) - 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… ... Read More
ASTSWMO Comments on the CCR Notice of Data Availability (11/14/2011) - 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
ASTSWMO Comments on Definition of Solid Waste Notice Proposed Rule (10/20/2011) - The Hazardous Waste Recycling and Program Information Management Task Forces (Task Forces) of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Hazardous Waste Subcommittee, have reviewed the July 22, 2011 Proposed Rule concerning potential revisions to the… ... Read More
The Hazardous Waste and Solid Waste Subcommittees provide input on the RCRA Messaging initiative. (10/15/2011) - The Hazardous Waste and Solid Waste Subcommittees of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciate your invitation to  provide input on the "RCRA Messaging" initiative. In this letter, we offer our perspectives on this initiative… ... Read More
The Hazardous Waste Recycling and Program Information Management Task Forces comment on the Definition of Solid Waste Notice Proposed Rule (76 FR 44094) (10/15/2011) - The Hazardous Waste Recycling and Program Information Management Task Forces (Task Forces) of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Hazardous Waste Subcommittee, have reviewed the July 22, 2011 Proposed Rule concerning potential revisions to the… ... Read More
ASTSWMO Comments on the MSW Characterization Report (9/30/2011) - 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… ... Read More
Comments on the MSW Characterization Report Docket ID No. EPA-HQ-RCRA-2011-0178 (9/17/2011) - 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… ... Read More
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 (8/15/2011) - 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.… ... Read More
ASTSWMO Comments on U.S. EPA’s upcoming proposal for regulations promulgated under §108(b) of CERCLA (5/20/2011) - 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… ... Read More
ASTSWMO Comments on U.S. EPA’s Plan EJ 2014 (4/29/2011) - 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… ... Read More
ASTSWMO Comments on Potential Addition of Vapor Intrusion (VI) Component to Hazard Ranking System (4/15/2011) - ASTSWMO is forwarding the attached comments to U.S. Environmental Protection Agency's Potential Addition of Vapor Intrusion Component to the Hazard Ranking System, Published by the Federal Register on January 31, 2011. ... Read More

2010

Identification of Non-Hazardous Secondary Materials That Are Solid Waste (8/17/2010) - 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… ... Read More
Final Performance Systems Survey, Developed by the Performance Systems Task Force (4/15/2010) - 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… ... Read More

2006

ASTSWMO Comments on its partnership with the Department of Defense (9/8/2006) - 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… ... Read More

2004

ASTSWMO Comments on the Proposed Rule, Revisions to the Definition of Solid Waste (2/27/2004) - 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.… ... Read More