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Non-Rule Environmental Policy: A Case Study of a Foundry Sand Land Disposal NPD

This historical case study of a non-rule policy document (NPD) adopted by the Indiana Department of Environmental Management describes an emerging genre in environmental discourse. The NPD standardizes environmental public policy for land disposal of foundry sand, a solid waste. The collaborative writing process took six months with industry input, and the NPD was presented to two environmental boards. Two contrasts, in process and format, distinguish NPDs from rules. The NPD is an entirely new kind of writing which includes guidance for implementing statutes. The writing process in the case involves government writers and industry representatives, although it does not include other public input such as public hearings. Instead, the staff of the pollution control agency simply presents the NPD to the appropriate environmental policy boards and arranges for its publication. This article adds to the body of knowledge about technical writing in government, specifically environmental policy and non-academic genres.