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Comments to EPA on Water Quality Trading Proposals
The Environmental Protection Agency (EPA) requested input on policy approaches to promote market-based programs that will improve water quality. We submitted comments suggesting that EPA provides additional clarity, works to avoid undermining key permitting goals, and considers using alternate market-based structures before reissuing its proposals.
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Comments to EPA on TSCA Chemicals Regulation
The Environmental Protection Agency (EPA) is proposing to regulate four chemicals that have serious environmental and health risks. We submitted comments supporting EPA and suggesting ways the agency can strengthen its proposal and, additionally, urging EPA to reexamine its decision not to regulate a fifth chemical.
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Comments to EPA on Coal Combustion Residuals Rule
The Environmental Protection Agency (EPA) recently proposed to significantly weaken requirements for the disposal of coal combustion residuals from coal-fired power plants. We submitted comments focusing on inadequacies in EPA’s assessment of the rule’s costs and benefits.
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Comments to EPA on Changes to New Source Review
We submitted comments to the Environmental Protection Agency (EPA) regarding changes to its New Source Review (NSR) applicability regulations. Our comments focus on EPA’s failure to perform a cost-benefit analysis for the proposed rule.
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Comments to EPA on Rescinding Its “Once In, Always In” Policy
The Environmental Protection Agency (EPA) is proposing to abandon its longstanding “Once In, Always In” policy, in turn allowing “major sources” that reduce emissions below major source thresholds to reclassify as “area sources” subject to less stringent regulation. We submitted comments detailing inadequacies in EPA’s assessment of the rule’s costs and benefits. The agency fails to analyze the rule’s aggregate emissions impacts, conduct its illustrative analyses against an appropriate baseline, account for the possibility of inadequate state enforcement, and monetize the health and environmental effects of emissions changes.
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Comments to EPA on New York’s Clean Air Act Petition
The Environmental Protection Agency (EPA) proposed to deny New York’s Clean Air Act Section 126 Petition seeking reductions in pollution from upwind sources that significantly impede the state’s attainment of ozone pollution standards. We submitted comments explaining how EPA’s justification for the decision is flawed.
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Comments to EPA on Reconsideration of Mercury and Air Toxics Standards
The Environmental Protection Agency (EPA) is proposing to withdraw a prior finding that it is “appropriate and necessary” to regulate power-sector emissions of mercury and other “air toxics” under the Clean Air Act. We submitted comments arguing that EPA has failed to provide a reasoned explanation for this change of course.
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Comments to EPA on Revised Emissions Standards for New Power Plants
The Environmental Protection Agency (EPA) recently proposed a significant weakening of greenhouse gas emissions standards for new coal-fired power plants. We submitted comments focusing on flaws in the proposal and accompanying regulatory impact analysis.
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Comments to EPA on Delay of Landfill Emission Guidelines
In 2016, EPA finalized Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills. Once implemented, the regulation will deliver significant net benefits from reducing pollution that contributes to climate change and other harmful impacts to human health. EPA, however, is proposing to substantially delay the implementation of these protections. We submitted comments that point out how EPA fails to justify the proposed delay and assess its social costs.
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Comments to EPA on Reconsideration of Methane Standards for New Sources
In 2016, EPA finalized a set of performance standards for new, reconstructed, and modified sources of methane and volatile organic compounds (VOCs) in the oil and natural gas sector. A recent proposal, however, aims to weaken the 2016 rule in a variety of ways, with the goal of reducing the regulatory “burden” on industry. We submitted comments that focus on inadequacies in the cost-benefit analysis accompanying the proposed rule.
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