ASTSWMO ON RANGE RULE

[Lenny Siegel <lsiegel@igc.org>]

From: Lenny Siegel <lsiegel@igc.org>

ASTSWMO CRITICIZES RANGE RULE
ASTSWMO (Association of State and Territorial Solid Waste Management 
Officials), the organization that represents state and territorial 
waste and hazardous waste regulators from throughout the U.S., has sent 
a letter to the Pentagon criticized its proposed Range Rule. While the 
letter was sent on April 12, based upon the February 20, 1996 
"Strawman" draft of that rule, the criticisms still apply to the April 
draft that I recently described on this newsgroup.
The letter is addressed to Deputy Undersecretary of Defense 
(Environmental Security) Sherri Wasserman Goodman, Acting Deputy 
Assistant Secretary of the Army for Environment, Safety, and 
Occupational Health Raymond J. Fatz, and the DOD Range Rule post office box.
Lenny Siegel
 
"Dear Madam or Sir:
 "The purpose of this letter is to respond to the Department of 
Defense (DoD) 'Military Range Rule Strawman - Deliberative Draft' dated 
February 20, 1996. The Association of State and Territorial Solid Waste 
Management Officials (ASTSWMO) is a non-profit trade association which 
represents the collective interests of waste program managers for solid 
waste, hazardous waste, underground storage tanks, and waste 
minimization and recycling programs.
 "Although the concept of a deliberative draft generally is a 
commendable approach, nonetheless I must inform you that the timing and 
assumptions inherent in your deliberative draft raise fundamental 
objections by many state waste managers. State managers believe 
strongly that, while DOD clearly has expertise in the safe use of 
military munitions, States have the expertise and authority to regulate 
solid and hazardous waste. As such, we object strongly to the federal 
effort to preempt State authority to regulate munitions waste and to 
sunset hazardous waste regulatory authority. In order to ensure 
consistent application of solid and hazardous waste requirements, it is 
essential that State authority in this area be recognized. Within that 
framework, States are prepared to work with DoD on the very real 
technical, public health, and environmental issues posed by munitions 
waste on military ranges.
 "As the point of a strawman is to open the formulative process 
to include a broad spectrum of concerned parties, I felt it was 
important to bring such unambiguous opposition to your fundamental 
approach to your attention as soon as possible. ASTSWMO anticipates 
submitting a more detailed response in the future as the process 
matures. Given the predisposition to openness that a strawman draft 
implies, I am hopeful that the DoD will respect State Waste Managers' 
concerns and authorities.
 "Thank you for your attention to these comments.
 "Sincerely
 Mary Jean Yon (Florida)
 President, ASTSWMO"