Novesis Comments on 2011 DSW Proposed Rule

Novesis, on behalf of the South Carolina Chamber of Commerce commented and provided input on the United States Environmental Protection Agency’s 2011 Definition of Solid Waste (DSW) Proposed Rule, published in the Federal Register Volume 76, Number 141 dated Friday, July 22, 2011 (Pages 44094-44154) Docket ID Number EPA-HQ-RCRA-2010-0742.

Our full comments can be found here: Novesis Comments on 2011 DSW Proposed Rule

The 2011 DSW Proposed Rule consists of modifications and revisions to the EPA’s 2008 Definition of Solid Waste, and pre-2008 DSW exclusions contained within the Resource Conservation and Recovery Act (RCRA) Subtitle C regulations. The 2011 DSW Proposed Rule intends to modify previously promulgated and published regulations that were enacted to encourage recycling of hazardous secondary materials.

With the publication of the 2011 DSW Proposed Rule, the EPA has reversed a regulatory course it has followed over the last twenty years that was steadily and consistently providing regulatory relief and encouraging legitimate recycling and reclamation of industrial materials. The 2011 DSW Proposed Rule represents a significant step backwards in sustainability, reclamation, materials recovery, and will encumber companies that wish to create “green jobs” in the recycling industry. Increasing regulatory complexity only penalizes companies who seek to engage in legitimate recycling and reclamation activity. When considering the current economic climate and unemployment rate it seems imprudent to propose legislation that will hamper existing businesses and discourage new business formation that would help both create new jobs and help preserve our natural resources.

Comment submitted by John D. Cain, President, Novesis Inc., Document ID: EPA-HQ-RCRA-2010-0742-0236

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