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
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 Affordable Clean Energy (ACE) rule.
Comments on EPA's Proposed Determination Regarding Good Neighbor Obligations for the 2008 Ozone NAAQS.
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 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."
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 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.
- 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