Comments

APPA filed comments with EPA on the proposed rule for Postponement of Certain Compliance Dates for ELG Guidelines and Standards for Stream Electric Generation Point Sources (7-6-17)

APPA  filed comments in accordance with Executive Order (EO)13777, “Enforcing the Regulatory Reform Agenda" (5-12-17)

APPA filed comments with EPA on the proposed rule, the Clean Energy Incentive Program Design Details (11-1-16)

APPA filed comments with EPA on the Coal Combustion Residuals Extension Final Rule and Proposed Rule (8/22/16)

Comments of the American Public Power Association on the Environmental Protection Agency’s (EPA) Proposed Federal Plan Requirements and Model Trading Rules to Implement EPA’s Section 111(d) Rule (1-21-16)

APPA and NRECA joint webinar on RCRA Citizen Suite Enforcement and the CCR Rule: PowerPoint slides and audio (10/30/15)

APPA's Sue Kelly Testifies on Reliability at FERC's Technical Conference on the EPA Clean Power Plan (2/19/15)

APPA letter to EPA on ENERGY STAR distribution transformers draft specification framework (2/27/15)

APPA files comments with EPA on proposed carbon dioxide regulations for existing power plants under Section 111(d) of the Clean Air Act (12/1/14)

APPA files comments with EPA on proposed carbon dioxide regulations for modified and reconstructed power plants under Section 111(b) of the Clean Air Act (10/16/14)

APPA files amicus brief in Catskill Mountains Chapter of Trout Unlimited v. EPA (9/18/14)

APPA files intervenors brief in RICE litigation (4/1/14)

APPA submits comments for proposed NAAQS rule (8/30/12)

APPA's timeline for upcoming EPA regulations. (7/24/12)

APPA submits comments on EPA's proposed NSPS GHG Rule (6/25/12)

APPA Submits Comments with Appendices on EPA's Listening Session on Greenhouse Gas Standards for Fossil Fuel Fired Power Plants and Petroleum Refineries - Session 1: Electric Power Industry Representatives on Feb. 4, 2011 (March 18, 2011) 

EPA Press Release on Proposed Mercury MACT Rule (March 16, 2011) 

Press Release from EPA on 15 years of Acid Rain Reductions (December 20, 2010)

Write-up on the CO2/Clean Air Act issues in first iteration of Kerry-Lieberman bill "Discussion draft version" (May 7, 2010)

EPA's Final Decision to Continue Applying the Agency’s Existing Interpretation of a Regulation That Determines the Scope of Pollutants Subject to the Federal Prevention of Significant Deterioration (PSD) Program under the Clean Air Act (03/29/2010) 

APPA Paper Summarizing the August 2009 EIA Analysis of the Waxman-Markey Climate Change Bill (September 2009)

APPA's EPA Endangerment Comments (6/23/09)

EPA Requests that the Department of Justice Withdraw the Petition for Writ of Certiorari in EPA v. State of New Jersey (No. 08-512) concerning EPA's intention to develop emission standards for utility units under section 112 of the Clean Air Act. (01-29-2009)

APPA and the American Water Works Association File Joint Comments on Federal Requirements Under the Underground Injection Control (UIC) Program for Carbon Dioxide Geosequestration Wells, Proposed Rule, (Docket ID No. EPA-HQ-OW-2008-0390 73 Fed. Reg. 43492 July 25, 2008) (12/24/2008)

APPA Submits Comments on Federal Requirements Under the Underground Injection Control (UIC) Program for Carbon Dioxide Geologic Sequestration Wells (Docket No. EPA-HQ-OW-2008-0390 73 Fed. Reg. 43492 July 25, 2008) (12/19/2008)

APPA Submits Comments in Regulating Greenhouse Gases under the Clean Air Act: Advanced Notice of Proposed Rulemaking (Docket No. EPA-HQ-OAR-2008-0318 73 Fed. Reg. 44354 July 30, 2008) (11/26/2008)

APPA Submits Comments to NERC on Reliability Impacts of Climate Change. (07/16/2008)

APPA Submits Comments to the Environmental Protection Agency on the March 28, 2008 Draft National Water Program Strategy as a Proposed Response to Climate Change. (06/10/2008)

APPA Paper Summarizing the April 2008 EIA Analysis of the Lieberman-Warner Climate Change Bill (May 2008)
See additional legislative materials at APPA's legislative climate page.

EIA Energy Market and Economic Impacts of S. 2191, the Lieberman-Warner Climate Security Act of 2007 (April 2008)

APPA Paper Summarizing the March 2008 EPA Analysis of the Lieberman-Warner Climate Change Bill (April 2008)

EPA Analysis of the Lieberman/Warner Climate Change Legislation (March 2008)

APPA Analysis of Lieberman-Warner Bill (01/10/2008)
Utility members, download APPA's analysis of S. 2191. The Workbook (Excel) contains several spreadsheets that are described in the Description and Analysis (Word).

EIA Analysis of Bingaman-Specter & House Climate Hearing (January 2008)

EPA March 2007 Memo in 316b Implementation

Congressional Letter Sent to EPA Administrator Johnson Calling for the Withdrawal of the NPDES User Fee Rule (03/05/2007)
The letter is signed by Durbin, Isakson, Warner, Kyl, Smith, Wyden, Clinton, Salazar and Inhofe.

Final Comments of the CAPUM Coalition against New Permitting Fees (03/05/2007)

APPA Comments to EPA Regarding Proposed Changes to the NPDES Permit Program and the Grant Program in the Proposed Rule (03/05/2007)

Office of Advocacy NPDES Permit Fees (03/02/2007)

Joint Local Government/Industry Letter to Tom Sullivan at the Small Business Administration Office of Advocacy regarding NPDES Permit Fees (12/20/2006)

Letter from Senators Inhofe and Clinton to help on the NPDES User Fee Issue (Dec. 2006) 

APPA Pfiesteria Memorandum (11/15/2006)

APPA Comments for EPA-HQ-OAR-2005-0132 submitted October 23, 2006 (11/02/2006) 

APPA Supreme Court NSR Amicus Brief (09/15/2006)

CO2 Control and Sequestration: A Recent Exercise with Public Perception, Presentation by Theresa Pugh, Director, Environmental Services, American Public Power Association, Addressed To Utility Air Regulatory Group 2006 Control Technology Committee Meeting (Powerpoint, posted 03/30/2006)

Contacts

Carolyn Slaughter, Director of Environmental Policy, 202/467-2943

Delia Patterson, APPA Acting Senior Vice President of Advocacy and Communications & General Counsel, 202/467-2993