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Financial Responsibility Requirements under CERCLA 108(b) for Facilities in the Hard Rock Mining Industry

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National Association of Manufacturers (NAM) filings
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National Association of Manufacturers (NAM) filed 1 comment on this docket between Jul 17, 2017 and Jul 17, 2017. 77 other organizations filed here. The comment window closed 3304d ago.

What National Association of Manufacturers (NAM) filed (1)

Jul 17, 2017· Comment submitted by Ronald J. Tenpas of the Morgan Lewis Law Firm on behalf of Ross Eisenberg, Vice President, Energy and Resources Policy, National Association of Manufacturers (NAM)· EPA-HQ-SFUND-2015-0781-2721

The National Association of Manufacturers (NAM), the largest manufacturing association in the United States representing manufacturers in every industrial sector and in all 50 states, submits the attached comments in response to the U.S. Environmental Protection Agency's proposed rule: Financial Responsibility Requirements Under CERCLA 108(b) for Classes of Facilities in the Hardrock Mining Industry, 82 Fed. Reg. 3388 (January 11, 2017). Please note that these comments supplement the broader coalition comments submitted by Ronald J. Tenpas of the Morgan Lewis law firm on behalf of the NAM and a coalition of other associations.

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Abstract

EPA is proposing regulations under Section 108(b) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) that will require certain classes within the Hard Rock Mining Industry to establish and maintain evidence of financial responsibility consistent with the degree and duration of risk association with the production, transportation, treatment, storage, or disposal of hazardous substances.

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Co-filers (77)

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