This letter and corresponding document contain ECOS’ comments on U.S. EPA’s draft Fiscal Year (FY) 2018-2019 National Program Manager (NPM) Guidances for the OLEM, OAR, OCSPP, OW, OEI, OITA, OECA, and NEPPS offices.
Policy Documents
Congressional Letters re: ECOS Cooperative Federalism 2.0 Paper
Following the release of its Cooperative Federalism 2.0 paper, ECOS sent these letters and the paper to Congress for consideration as they deliberate the U.S. EPA’s authorizations and appropriations. Letter to the Senate and House Committees on Appropriations Letter to the Senate Environment and Public Works Committee Letter to the House Committees on Transportation &…
ECOS Comments on Enforcing the Regulatory Reform Agenda
This letter contains ECOS’ response to EPA’s request for input on the President’s Executive Order 13777: Enforcing the Regulatory Reform Agenda. The response includes 19 regulatory reform recommendations outlined in three categories.
Resolution 07-8 On the Need to Ensure that Up-to-Date, Protective National Ambient Air Quality Standards and Implementation Rules are Timely Promulgated and Implemented
This resolution urges EPA to ensure that NAAQS reflect current scientific information; urges EPA to set all NAAQS at levels that provide an adequate margin of safety to public health; urges EPA to work with states to identify DIP process improvements; and encourages EPA to better align compliance dates for rules that reduce the same…
Resolution 10-7: Retention of Clean Air Act Waiver of California Emissions Standards and State Adoption of California Standards
In this resolution, ECOS finds that states must be allowed to exercise their discretion to regulate pollutants within their borders and to develop standards as or more stringent than federal regulations and urges Congress to retain and not limit California’s authority to adopt or enforce emissions standards and any state’s ability to adopt California’s standards.…
9-12 Summary of State Responses to SCOTUS Clean Power Plan Stay
This document is a summary of State responses to Clean Power Plan (CPP) Stay (as of 9/12/16). *Alaska, Vermont, and Hawaii, as well as the D.C., are exempt from the CPP.
Partners for Meeting State Research Needs
This document provides brief examples of states using EPA research and resources through the Office of Research and Development to address environmental concerns.
Updated Clean Power Plan (CPP) Implementation Resources for States
This draft chart provides states with a list of organizations with resources relevant to the implementation of the Clean Power Plan.
Comments on Clean Power Plan FIP and Model Trading Rules
This letter provides comments to the U.S. Environmental Protection Agency on Clean Power Plan FIP and Model Trading Rules. In sum, this letter offers broad suggestions that should be addressed by EPA in any final rule. These comments are offered to EPA independent of the question of the legality of the CPP and this proposed rule. Most…
Resolution 00-12: Change to the United States Environmental Protection Agency’s “Once In, Always In” Policy
In this resolution, ECOS calls on EPA to provide an exception to the “Once In, Always In” policy provisions that apply major source requirements after a source reduces and maintains its level of HAP emissions below major source thresholds and equivalent to maximum achievable control technology (MACT) if the reduction is made through the use…
