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
ECOS Green Report: Streamlining Permitting – An Inventory of State Environmental Agency Online Tools and Resources
This ECOS Green Report presents an inventory of the innovative state permitting processes, documenting resources, tools, and efforts as they appear on the websites of state environmental agencies.
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 11-1: Objection to U.S. EPA Imposition of Interim Guidance, Interim Rules, Draft Policy, and Reinterpretation Policy
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…
Resolution 17-3: On the Value of Supplemental Environmental Projects
This resolution encourages the use of SEPs by state and EPA to respond to environmental harm and to invigorate communities.
Resolution 17-2: On the Value of Diverse and Innovative Approaches to Advance Compliance with Environmental Requirements
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.
Resolution 98-9: U.S. EPA Enforcement in Delegated States
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…
Resolution 13-2 The Need for Reform and State Participation in EPA’s Consent Decrees which Settle Citizen Suits
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…
Comments on proposed EPA Title VI Non-Discrimination Rulemaking
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.
Letter on Environmental Enforcement Training for States
This letter reiterates the support of the Environmental Council of the States (ECOS) for the Regional Compliance Training Associations (Associations) and their continued funding.
