ACA Comments to CalRecycle on SB 54 Proposed Regulations
ACA submitted comments to the California Department of Resources Recycling and Recovery (CalRecycle) on the second round of proposed regulations for the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54).
ACA Submits Comments on LEED v5, Second Round
ACA submitted a second round of comments to U.S. Green Building Council (USGBC) on the Leadership in Energy and Environmental Design (LEED) v5. The LEED system is the most widely-recognized and widely-used green building system in the world. Earlier in 2024, USGBC released the first draft version of the LEED v5 rating systems for public comment.
ACA Comments on Maine's draft PFAS bill and Report to Legislature
ACA submitted comments to Vermont’s Department of Environmental Conservation (DEC), which is developing a draft PFAS bill and a report to the legislature. Maine's Act 131, Phase Out of PFAS Added Products, would establish a general prohibition of PFAS added products that will take effect six (6) months after one of the other Northeast states adopts similar legislation, affecting at least 10,000,000 people. ACA underscored the need for the definition of PFAS to be aligned with EPA’s definition under its TSCA Section 8(a)(7) reporting rule, with a structural definition based on compounds with two or more fluorinated carbon atoms.
ACA Comments to California SCAQMD on Rule 1151
ACA submitted detailed comments to California's South Coast Air Quality Management District (SCAQMD) regarding Proposed Amended Rule 1151 – Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations.
ACA, Coalition Support NO IRIS Act of 2024
ACA joined a coalition letter of support to Congressional sponsors of the “No Industrial Restrictions In Secret (NO IRIS) Act of 2024” (S. 3724/H.R. 7284). Increasingly, the Environmental Protection Agency’s Integrated Risk Information System program (IRIS) is being used to justify overly burdensome regulations on critical chemistries essential for everyday products. The NO IRIS Act would protect American manufacturing and ensure regulations are based on sound science.
ACA Comments on Maine’s Reposted Draft Rule for Packaging Stewardship Program
ACA submitted comments to Maine's Department of Environmental Protection on the agency's reposted draft rule: Stewardship Program for Packaging. The department made changes to the draft rules based on the comments received in late 2023 and early 2024 and reposted them to allow for additional public comment. These draft rules provide details for implementing the Stewardship Program for Packaging that aims to reduce the burden on municipalities for managing packaging material.
ACA Comments on Oregon’s Proposed Rulemaking: Plastic Pollution and Recycling Modernization Act
ACA submitted comments to Oregon Department of Environmental Quality regarding the proposed rulemaking for the Plastic Pollution and Recycling Modernization Act. The Act requires producers of packaging, paper products, and food serviceware to support and expand recycling services in Oregon for their products.
ACA Urges Senate Leadership to Include CFATS Reauthorization in NDAA
ACA joined several organizations in a letter to Senate leaders urging the inclusion of language from the Carper-Peters amendment in the National Defense Authorization Act (NDAA) for Fiscal Year 2024 (S. 4638), which reauthorizes the Chemical Facility Anti-Terrorism Standards (CFATS through October 1, 2026, into the substitute NDAA bill that will be filed soon.
ACA Comments on OSHA’s Proposed Emergency Response Standard
ACA's comments focused on Workplace Emergency Response Employers, and generally expressed concern that the covered emergency activities are unnecessarily broad, adressing relatively minor emergency responses.
ACA, Coalition Oppose Extension for Detention and Demurrage Billing Requirements Final Rule
ACA joined more than 60 organizations expressing strong opposition to the petition filed by the Ocean Carrier Equipment Management Association to extend the effective date of the Detention and Demurrage Billing Requirements Final Rule. The coalition letter urged the Federal Maritime Commission to reject the petition.