September 14, 2016

EPA Betas New Platform for Submitting Public Comment

We know you’ve all read the proposed e-manifest fee rule from cover to cover. And outside of the hefty proposed fee schedule, you may have noticed that EPA is trying something new. There are 3 ways to submit comments on the proposal: 1) postal/snail mail, 2) regulations.gov, and 3) EPA’s pilot comment platform. The third approach is new, and the proposed e-manifest rule is the first to use this optional new comment format. To use it, simply go to the website, select the rule you want to review, and submit your comments.

As you work your way through the rule, you will notice that to the right of each section, there is a link labeled “Write a comment about.” Select the link next to the text on which you want to comment, and a box will appear for you to type in your thoughts; beneath the box is a button giving you the ability to upload documents with information supporting your comment. When you are finished evaluating the rule, you can 1) review all of your comments; 2) select whether you are submitting comments on behalf of an organization, government agency, or yourself as an individual; and 3) submit your comments. This new approach is quite slick and shows EPA exactly what part of the proposed rule you are commenting on. If you want to try it out, hurry—the comment period for the e-manifest fee proposal ends September 26!

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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.