With a network of state chapters and a national office in Washington, D.C., the National Solid Wastes Management Association (NSWMA) is very engaged in local, state and federal legislative advocacy. NSWMA also regularly comments on regulatory matters that affect our industry’s operations.
Such regulations often seem dauntingly technical in nature, especially when the parts of them that affect the solid waste industry may involve only a few lines in documents that are hundreds of pages long. Still, state and federal regulators increasingly are proposing and finalizing regulations that can have sweeping impacts on our industry, so it’s vital to the private-sector solid waste industry and the manufacturers that support it that NSWMA and its sister organization, the Waste Equipment Technology Association (WASTEC), be vigilant and successful in helping shape these policies.
At the federal level, these proposed regulatory changes during the last year have involved efforts to reduce to reduce greenhouse gas (GHG) emissions, improve employee and commercial truck safety, and make trucks more fuel-efficient. In recent months, NSWMA has worked closely with government officials to offer comments regarding their efforts in these areas, especially regarding efforts to regulate greenhouse gas emissions and improve truck safety standards.
NSWMA represents a hauling industry with a fleet of more than 130,000 trucks. All of these trucks are regulated at the federal and state level as commercial motor vehicles (CMV). Yet our trucks are a unique type of CMV. They are far heavier than other trucks when empty, have a short wheelbase and tend to travel relatively short distances. Yet they are subject to the same regulations as long-haul trucks that routinely transport goods across the country. As a result, NSWMA staff has to remind federal regulators of our unique attributes and ensure that our trucks are treated fairly.
Recent examples of specific regulatory efforts have included:
• NSWMA submitted comments to the U.S. Environmental Protection Agency (EPA) on how greenhouse gas emissions from biogenic sources should be treated under Prevention of Significant Deterioration (PSD) and the Title V Greenhouse Gas Tailoring Rule. NSWMA argued that the GHG produced from biomass should not be regulated in the same manner as anthropogenic GHG (i.e., fossil fuel use) under this rule.
• NSWMA offered comments on two of EPA’s proposed amendments to rules requiring the mandatory reporting of GHG. NSWMA argued that the proposed rules substantially changed the requirements for municipal solid waste landfills, imposing significant new data collection requirements mid-reporting year. NSWMA believed that EPA should not retroactively impose these requirements for reports that are to be submitted in 2010 and should, in some cases, provide an opportunity for formal public comment.
• NSWMA recently submitted comments regarding the U.S. Occupational Safety & Health Administration’s (OSHA) blood-borne pathogens standard. NSWMA stated that the current standard was a necessary part of protecting healthcare workers and should be updated to consider changes in health settings such as medical treatment in non-traditional facilities.
Furthermore, NSWMA and WASTEC are currently drafting comments on a regulation proposed by EPA and the National Highway Transportation Safety Administration to increase fuel efficiency and lower GHG emissions for medium and heavy-duty trucks that will ultimately impact the cost of the truck.
NSWMA and WASTEC members are invited to participate in the review and development of regulatory comments. These are great opportunities for members to communicate why they believe some regulations are unnecessary, why proposed rules should be reconsidered and how regulatory goals can be achieved with less cost.
If your company is an NSWMA or WASTEC member, and you would like to participate in such regulatory efforts, reach out to NSWMA staff today. If your company does not currently belong to NSWMA or WASTEC, these programs are additional reasons to join. For more information about NSWMA and WASTEC membership, visit www.environmentalistseveryday.org/membership.
Caija Owens is the program manager for the Waste Equipment and Technology Association. Reach her at (202) 364-3750.