Environment Regulatory Filings
Comments to CEQ on their proposed rule to "Update the Regulations Implementing the Procedural Provisions of the National Environmental Policy Act (NEPA)."
Comments to EPA on their Advanced Noticed of Proposed Rulemaking on Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process.
Comments to EPA on Financial Responsibility Requirements Under CERCLA Section 108(b) for Facilities in the Electric Power Generation, Transmission, and Distribution Industry.
Air
Comments on EPA's proposed Mercury Air Toxic Standards (MATS) Supplemental Finding Reconsideration and Risk and Technology Review (RTR).
Comments on EPA's Review of Standards for Greenhouse Gas Emissions from Electric Utility Generating Units
Comments on EPA's proposed Affordable Clean Energy (ACE) rule.
A summary of the final Affordable Clean Energy (ACE) rule.
A letter to EPA and the National Highway Traffic Safety Administration on the CAFE standards for light-duty vehicles.
Comments on EPA's Prevention of Significant Deterioration (PSD) and Nonattainment New Source Review (NNSR): Project Emissions Accounting.
Comments on EPA's proposed rule on Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act.
Water
Comments on EPA Region 10 Draft NPDES Permits for Hydroelectric Facilities.
Comments on the Revised Definition of Waters of the United States (WOTUS).
Comments to EPA on the postponement of certain compliance dates for effluent limitation guidelines and standards for steam electric generating point sources.
Comments to EPA on the Clean Water Act's coverage of "discharges of pollutants" via a direct hydrologic connection to surface waters.
Comments to the EPA and the Army Corps of Engineers on the proposal to repeal the 2015 Rule and recodify the regulatory text defining "waters of the United States."
Waste
Comments on EPA's proposed rule on Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals (CCRs) from Electric Utilities; Enhancing Public Access to Information; Reconsideration of Beneficial Use Criteria and Piles.
Comments on EPA's proposed CCR Part B Rule: Alternative Demonstration for Unlined Surface Impoundments; Implementation of Closure.
PCB approval by EPA to dispose of non-liquid remediation wastes with as found PCB concentrations of less than 50 parts per million in non-TSCA approved landfill facilities.
- Whitepaper on Risk-Based Disposal for PCB Remediation Waste Less than 50 ppm
- PCB Risk Based Disposal Approval Questions and Answers Document
- EPA Memo Clarifying Notification and Sampling Requirements under the Approval
PCB Webinars
- Webinar slides on PCB use, storage, and marking
- Webinar slides on PCB cleanup and disposal, part 1
- Webinar slides on PCB cleanup and disposal, part 2
- Webinar slides on PCB reporting and recordkeeping
- Webinar slides on natural gas pipelines use and abandonment/disposal