Letter to EPA: Advocacy Comments on National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills Residual Risk and Technology Review
The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s proposed rule, “National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills Residual Risk and Technology Review.” Advocacy believes that EPA’s proposal makes some very important progress in providing small entities flexibilities that should have been part of previous rulemakings affecting this industry but that more should be done. Advocacy recommends EPA further raise the temperature operating standard, reduce the testing burden by adopting more timely, flexible and effective requirements, and provide greater flexibility in the definition of closed areas of a landfill.
 84 Fed. Reg. 36670 (July 29, 2019), Docket No. EPA-HQ-OAR-2002-0047.