Environment

Environment Filings and Resources

Environment Regulatory Filings

Comments to EPA on their Advanced Noticed of Proposed Rulemaking on Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process.

Air

A letter to EPA and the National Highway Traffic Safety Administration on the CAFE standards for light-duty vehicles.

Comments on EPA's proposed rule to repeal the carbon pollution emission guidelines for existing stationary sources: electric utility generating units.

Comments on EPA’s advance notice of proposed rulemaking which seeks input on the development of emission guidelines to limit greenhouse gas emissions from existing electric generating units.

Comments to EPA in accordance with Executive Order “Enforcing the Regulatory Reform Agenda” on regulatory burdens imposed on utilities by the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, and Toxic Substance Control Act.
 
Comments on the EPA’s proposed Clean Energy Incentive Program design with suggested modifications to expand the eligibility of renewable energy and energy efficiency investments under state and federal plans.

Comments on EPA’s proposed rule to establish a significant emissions rate for greenhouse gas emissions under the Prevention of Significant Deterioration program.

Comments on EPA’s Cross-State Air Pollution Rule Update targeting nitrogen oxide emissions from electric generating units. 

Water

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."

Comments to the Army Corps of Engineers on ways to improve and streamline Nationwide Permit submissions under the Clean Water Act. 

Waste

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 EPA on hazardous and solid waste management system and disposal of coal combustion residuals from electric utilities.

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.

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