EMA collaborates closely with member companies and other mining industry associations to craft comments that articulately and clearly express the views of our members to a variety of agencies on a wide range of issues.
Most federal regulations in the United States are promulgated through what is known as “the informal rulemaking process.”
The Administrative Procedure Act of 1946 (APA) established uniform procedures for federal agencies to propose and issue regulations. The APA requires that an agency publish any draft regulation in the Federal Register and solicit comments and recommendations from interested stakeholders during a defined period, usually between 30 and 60 days. The agency then must analyze and consider all comments received, revise the draft regulation as needed, and publish a final regulation at least 30 days before it is scheduled to take effect. Final rules are subject to judicial review and can be challenged through the courts.
Below are copies of comments filed by EMA on behalf of its membership.
(Please note that prior to December 2022, comments were filed under the association’s former name: Industrial Minerals Association – North America.)
The Essential Minerals Association has provided comments to the U.S. EPA in response to its proposed rule relating to the reconsideration of the 2008 Fugitive Emissions rule which would modify how fugitive emissions are considered under certain opermitting requirements of the Clean Air Act.
Environmental Protection Agency
EMA has provided the attached comments on the Environmental Protection Agency’s proposed rule for the regulation of Chrysotile Asbestos under the Toxic Substances Control Act (TSCA).
Department of Interior