This letter outlines ECOS’ Comments submitted under Federal Docket EPA-HQ-OPPT-2017-0421 (82 FR 49564) on reporting requirements for the TSCA Mercury Inventory. ECOS urges EPA to adopt mercury reporting requirements for the TSCA Mercury Inventory that will ensure fulfillment of the statutory requirements under TSCA’s 2016 amendment, the Frank R. Lautenberg Chemical Safety for the 21st Century Act.
This letter details potential consequences for environmental quality if the Vessel Incidental Discharge Act (S. 1129) were enacted. The letter was co-signed by ECOS and three other nonprofit associations representing state environmental regulatory agencies: the Association of Clean Water Administrators (ACWA), the Association of State Wetland Managers (ASWM), and and the Association of Fish and Wildlife…
This comment letter, submitted on December 11, 2017, outlines ECOS’ recommendations to U.S. EPA on the chemical data reporting (CDR) requirements for the inorganic byproduct chemical substances negotiated rulemaking process and on the associated Federal Advisory Committee. ECOS also submitted an appendix to the comments, here, which discusses options considered by the negotiated rulemaking committee…
This document outlines ECOS’ comments on recommended best practices for environmental reviews and authorizations for infrastructure projects, in accordance with Section 41006 of the Fixing America’s Surface Transportation Act (FAST-41) and feedback on whether any of the best practices are generally applicable on a delegation or authorization-wide basis to permitting under FAST-41.
This document reflects ECOS’ and the states’ comments on EPA’s draft FY2018-2022 Strategic Plan.
A joint letter sent this week by ECOS, the Association of Clean Water Administrators (ACWA), and the Association of State Wetland Managers (ASWM) notes the associations’ concern over provisions of H.R. 3043, Hydropower Policy Modernization Act of 2017.
This formal comment letter to U.S. EPA Administrator Pruitt offers ECOS’ input on “Step 1” of redefining of waters of the U.S. following the February 28, 2017, Presidential Executive Order on “Restoring the Rule of Law, Federalism, and Economic Growth by Reviewing the ‘Waters of the United States’ Rule.’”
This letter from ECOS’ newly elected President Todd Parfitt, Director of the Wyoming Department of Environmental Quality, outlines his priorities for the 2017-2018 year.
On September 5th, ECOS submitted a letter to U.S. EPA Chief Financial Officer David Bloom detailing their suggestions for the Agency’s Fiscal Year (FY) 2019 budget priorities. EPA is developing its FY19 budget proposal over the coming months, with a draft due to the White House Office of Management and Budget (OMB) September 11. Traditionally OMB…
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.