Dear Administrator Wheeler: On behalf of the Association of Battery Recyclers and Battery Council International, we write in support of the Environmental Protection Agency’s notice of proposed rulemaking: Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process, 85 Fed. Reg. 35,612, 35,621 (June 11, 2020).
The Association of Battery Recyclers, Inc. (“ABR”) is a non-profit trade association of companies that are involved in recycling spent lead batteries and other lead-bearing materials. Members of the ABR include companies that own and/or operate battery manufacturers, lead chemical manufacturers, secondary lead smelters, lead fabricators, and consultants and vendors to the lead recycling industry.