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
Resolution 00-1: On Environmental Federalism
This resolution identifies states as co-regulators with U.S. EPA; supports Cooperative Federalism; recognizes the need for adequate funding for state and federal environmental programs; opposes preemption of state authority; and supports authorization and delegation of programs to states.
Resolution 00-9: Clarification of CERCLA Sovereign Immunity Waiver for Federal Facilities and Federal Lands
This resolution requests that Executive Order 12580 be revised to clarify that federal facilities and federal lands are subject to appropriate state regulations and are not unduly shielded by sovereign immunity and lead agency authority; and encourages Congress to pass legislation acknowledging state authority for oversight of cleanup at federal facilities and federal lands. …
Resolution 93-2: On Coordination with the National Governors’ Association
This resolution resolves that ECOS will coordinate its positions with the Natural Resources Committee of the National Governors’ Association; invite this committee to ECOS meetings; and ensure regular communication.
Resolution 17-5: On National Ambient Air Quality Standards
In this resolution, ECOS urges EPA to assess existing NAAQS to ensure they reflect current scientific information; calls on EPA to develop modeling baselines and projections to understand transported pollutant emissions; calls on EPA to work cooperatively with states to address issues where state compliance with NAAQS is impacted by transported emissions; urges EPA to…
Resolution 17-4: Federal Rule Promulgation and Implementation
In this resolution, ECOS encourages EPA to better align compliance dates for rules that reduce pollutants from the same source sectors; asserts that states should be able to set standards that are more stringent or broader than federal standards; asserts that states should have flexibility in implementing their programs to meet federal standards; encourages EPA…
Resolution 10-7: In Support of State Discretion to Regulate Pollutants within State Borders, the Retention of the Clean Air Act Waiver of California Emissions Standards, and the 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.…
Resolution 10-5: Improved Cooperative Management of Federal Programs to Reduce Nonpoint Source Pollution
In this resolution, ECOS states that the federal government should work with states to align federal programs with state water quality priorities; supports continued collaboration between states and EPA’s 319 program to develop and implement consistent and effective nonpoint source pollution control strategies; acknowledges progress made through collaboration of federal agencies; encourages continued partnerships among…
Resolution 08-16: Long-Term Financing for the National Environmental Information Exchange Network
This resolution supports continued implementation of the National Environmental Information Exchange Network; recognizes that ongoing operation and maintenance costs for the Exchange Network will be borne by all involved; requests EPA support for the use of programmatic grants for maintenance and operation of regulatory data flows; and call on Congress to provide adequate funding for the…
Resolution 11-8: On the Use of Guidance
In this resolution, ECOS states its belief that EPA should use guidance to provide direction but not require compliance by states with guidance; urges EPA to seek early involvement from states about the content and implementation of guidance; and urges EPA to use guidance only to interpret regulation, not as a substitute for regulation or…
