Comment submitted by Redwood Materials

Summary: Redwood Materials opposes the proposed Significant New Use Rules (SNURs) because they create regulatory overlap with existing frameworks (RCRA, CAA, CWA, OSHA), impose technically unfeasible fenceline monitoring requirements, and mandate unnecessary hazardous waste disposal. The company argues that the EPA's economic impact analysis significantly understates the true compliance costs and that the rule contradicts Department of Energy initiatives to expand the domestic battery supply chain.