EPA is considering modifying the permit term provision of the Research, Demonstration and Development (RD&D) rule in the Resource Conservation and Recovery Act (RCRA) subtitle D regulations for municipal solid waste landfills. EPA originally promulgated the RD&D rule in 2004. One of the issues that has arisen is the 12 year time limitation on RD&D permits. States that have issued RD&D permits indicate to EPA that this limitation discourages long-term research and shortens the investment period needed to recoup costs, because the lag time from design to operation can be as much as three years. The majority of state stakeholders believe that removing the time limit is appropriate.