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.
Through this resolution, ECOS states its believe that each state reserves the right to use or refrain from using guidance as part of its environmental regulatory effort; that EPA should eliminate requiring compliance by states with guidance; urges EPA not to use guidance as a substitute for regulations; and that states object to EPA using…
This resolution encourages the use of SEPs by state and EPA to respond to environmental harm and to invigorate communities.
This resolution seeks support for compliance assistance and innovative compliance approaches from EPA, the regulated community, and academic institutions and encourages study of the effectiveness of these efforts.
In this resolution ECOS encourages EPA to perform program oversight to not extend into individual state regulatory actions; encourages EPA regions to consult with a state prior to taking an enforcement action there; encourages EPA to coordinate with states in settlements; encourages clarification of state and federal roles in enforcement and compliance; states its support for the…
This resolution, among other actions, affirms that state environmental agencies are co-regulators, co-funders, and partners with U.S. EPA; calls on EPA to notify the Governors of all affected states of any citizen suit filed against EPA that alleges a failure of the federal agency to perform its nondiscretionary duties; calls on EPA to provide state environmental…
This letter provides ECOS’ input on EPA’s proposed rule “Non Discrimination in Programs or Activities Receiving Federal Assistance from the Environmental Protection Agency,” which aims to increase transparency and accountability.
This letter reiterates the support of the Environmental Council of the States (ECOS) for the Regional Compliance Training Associations (Associations) and their continued funding.
In this letter, ECOS reiterates its active interest in compliance and enforcement matters. This letter offers general and specific comments on the NEI’s for EPA’s consideration. Among other things, these comments encourage further state and EPA collaboration.
This letter contains the ECOS Planning Committee’s response to EPA’s Office of Civil Rights “FY 2015-2020 External Compliance and Complaints Draft Strategic Plan.” This letter offers a few suggestions for OCR path to initiate improvements while engaging further with states in the process.