In June 2017, ECOS published “Cooperative Federalism 2.0: Achieving and Maintaining a Clean Environment and Protecting Public Health.” Among other things, that document describes ways in which EPA could improve environmental outcomes and maximize efficiency by modifying its approach to overseeing state implementation of delegated federal environmental programs. The following more detailed statement expands on…
Policy Documents
ECOS Statement on U.S. EPA PFAS Leadership Summit
This ECOS letter to U.S. EPA outlines questions states intend to raise at the agency’s National Leadership Summit to address Per- and Polyfluoroalkyl Substances (PFAS). Of upmost importance is the collective states’ view that the federal government should take a leadership role in protecting public health, informing citizens, and supporting state action to address these…
Letter to U.S. EPA on Prioritization of Mercury under TSCA
This letter details ECOS’ request for U.S. EPA to designate mercury and mercury compounds as priority chemicals under the Lautenberg Act.
ECOS Comments on Draft Guide for Access to TSCA CBI
These comments reflect state views on U.S. EPA’s draft guidance for access to TSCA Section 14(d)(4) Confidential Business Information.
ECOS Letter on Lead and Copper Rule
This letter provides comments from ECOS as part of EPA’s Federalism Consultation on the Long-Term Lead and Copper Rule.
ECOS Letter to Congress on State Input of U.S. EPA FY18 Budget
This letter details ECOS’ reiteration of state environmental agency funding priorities as Congress addresses the FY18 budget for the remainder of the fiscal year. The letter also highlights some potential challenges with a final budget determination for U.S. EPA being made late in the fiscal year.
ECOS Letter to Congress on Preserving the U.S. EPA’s IRIS
This letter urges Congress to support retaining the U.S. EPA’s Integrated Risk Information System (IRIS) Program’s funding and personnel with the Office of Research and Development (ORD). Retaining IRIS within ORD will help to ensure that state public health and environmental protection programs can continue to rely on IRIS’ invaluable and impartial health hazard assessments.
ECOS Comments on Reporting Requirements for the TSCA Mercury Inventory
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.
Letter from State Environmental Agency Associations Regarding the Vessel Incidental Discharge Act (S. 1129)
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…
ECOS Comments on TSCA Chemical Data Reporting Requirements for Inorganic Byproducts
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…
