Subject:		Late Comments Included in the Docket
From:  		Jim Belke, Office of Emergency Management, U.S. EPA
To:		Docket EPA-HQ-OEM-2015-0725
Date:		November 19, 2019

Various parties have submitted communications to the above-referenced docket after August 23, 2018, the close of the comment period for the RMP Amendments Reconsideration proposed rule, either by direct submission to the docket or by submission to various agency officials.  These submissions include an April 18, 2019 letter from Lawrence P. Halprin discussing constitutional concerns about the requirement to conduct public meetings after accidents (EPA-HQ-OEM-2015-0725-1992) ("Halprin Letter"); a letter dated May 3, 2019, from Richard Moore on behalf of the National Environmental Justice Advisory Council asking that EPA halt work on revising the 2017 RMP Amendments (EPA-HQ-OEM-2015-0725-1993) ("Moore Letter"); a July 5, 2019 email from Stephanie Herron of the Environmental Justice Health Alliance for Chemical Policy Reform providing a list of meeting attendees and a link to a video (EPA-HQ-OEM-2015-0725-1995) ("Herron Email"); an August 20, 2019 letter from the Attorneys General for New York, Pennsylvania, and several other states discussing chemical accidents and reports about accidents since the close of comments on the RMP Amendments Reconsideration (EPA-HQ-OEM-2015-0725-1998) ("AG August Letter"); and an October 28, 2019 supplement to the Attorneys General letter forwarding an October 16, 2019 "Factual Update" report of the Chemical Safety Board on a chemical accident at the Philadelphia Energy Solutions refinery (to be docketed) ("AG October Letter").  This note clarifies that, while EPA has included each of these documents in the its docket for the RMP Amendments Reconsideration, by doing so the Agency is not concluding that any of these documents are of "central relevance" to the reconsideration proceeding, as that term is used in CAA 307(d)(4)(B)(i).  The communications are included as "late comments" outside the comment period. 
