I learned from a source very close that the EPA received more comments on this regulation than any in previous history. The EPA was not able to handle the surge and was forced to call in the contractors to work on the immense number of comments. Just cataloging the comments was a problem beyond the EPA’s capability. the task was tremendous.
The contractors worked three months sorting it all out and were forced to cease work on what they were doing to digest the surge.
I’m surprised they bothered to do anything with the comments other than delete them.