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January 18, 2019

Inside EPA Features Comments by Kathleen M. Roberts Regarding Implementation of TSCA Fee Structure

The ACTA Group

On January 18, 2019, Inside EPA spoke with Kathleen M. Roberts, Senior Regulatory Consultant, Bergeson & Campbell, P.C. (B&C®), for the article “EPA’s Fee Rule Takes Effect Without Suit, A First For TSCA Framework.”

Kathleen Roberts, a senior regulatory consultant at the law firm Bergeson & Campbell, suggested that the clarity of the statute regarding fees dissuaded critics from challenging EPA’s final rule. “I believe that there were no challenges because the legislative language is very clear as to how much EPA could collect in TSCA fees. The only question was how the fees would be split between Section 4, 5, and 6 [activities],” Roberts tells Inside EPA.

“Industry stakeholders may not be pleased in paying additional fees, but they knew it was coming,” Roberts adds. “NGOs might want industry to pay more, but the legislation limits what can be collected. Presumably, [environmentalists] do not care how the fees are split among the TSCA sections as long as the funding is provided.”

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