Letter to EPA on Electronic Industries Association Petition to DOT
On October 26, 2007, the Waste Committee sent a letter to EPA asking for their support in opposing a petition by the Electronic Industries Alliance to the Department of Transportation to preempt some Maine regulatory requirements related to transportation of cathode ray tubes. The letter, which was written in follow up to discussions at the ECOS Annual Meeting, was sent to Susan Bodine, Assistant Administrator of the Office of Solid Waste and Emergency Response. A copy of the letter can be accessed here.
National Brownfields Coalition Brownfields Reauthorization Proposal
In April, in an effort to begin discussion on the issue of reauthorization of Brownfields, the Waste Committee heard a presentation from the National Brownfields Coalition on their proposal for changes during reauthorization. An outline of their proposal and details on some sections of it can be accessed here. After the call the states convened via conference call and email to discuss reactions to the proposal. A set of comments was agreed upon with the Waste Committee. Those comments and a cover letter to the National Brownfields Coalition can be accessed below.
Cover Letter for Comments on Proposal for Reauthorization of Brownfields
Comments on Proposal for Reauthorization of Brownfields
Railroads and Solid Waste Problems in New Jersey
In New Jersey some railroads and solid waste operators who have sought to get designated as railroads have been shielding their solid waste disposal activities from state regulation by claiming preemption under the Interstate Commerce Commission Termination Act (ICCTA), 49 U.S.C. 10101 et seq. These entities have claimed that ICCTA preempts all state health, safety, and environmental regulations which has resulted in continuing fights with the State. New Jersey DEP is looking for support of bills (HR 1248 and S 719) currently before Congress that would clarify that ICCTA does not preempt all state health, safety and environmental regulations. More information from New Jersey on this issue is available at the links below. If you would like to talk to New Jersey DEP about this issue contact Wolf Skacel, Assistant Commissioner of Compliance and Enforcement at Wolfgang.Skacel@dep.state.nj.us. If you are facing similar problems in your state, please let Carolyn Hanson at firstname.lastname@example.org know.
Letter to ECOS from New Jersey DEP on issues with railroads and solid waste
Letter from New Jersey DEP to New York, Susquehanna & Western Railway Corporation
Letter from New Jersey Meadowlands Commission to the New York, Susquehanna & Western Railway Corporation
Photos of solid waste at a railroad facility
Definition of Solid Waste Rule Changes
On February 1, 2007, ECOS and ASTSWMO sent a joint letter to OSWER Assistant Administrator Susan Bodine about the Definition of Solid Waste Rule. The letter addresses two issues related to the rule that have been covered in the press. The first issue is that the revisions be deemed more stringent than the current rule and therefore mandatory for states to adopt.’ The second issue relates to the codification of criteria for defining legitimate recycling. The full letter can be accessed below.
ECOS-ASTSWMO Letter to EPA on Definition of Solid Waste Rule
On March 15, 2007, EPA issued a proposal for changes to the Definition of Solid Waste Rule related to hazardous secondary materials and recycling. This is the proposal that ECOS and ASTSWMO were anticipating when they sent a letter to EPA in February (see below). Comments on this proposal were due by June 25, 2007 and comments on the information collection provisions had to be received by OMB by April 25. The EPA webpage with information about this proposal including Federal Register notice can be accessed below.
EPA Webpage on Revisions to Definition of Solid Waste