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The EPA proposed a new rule on June 11, 2020, that would impose specific requirements for the Agency to utilize uniform and transparent “high-quality analysis” in its statutory obligations in the rulemaking process under the Clean Air Act (CAA). Many statutes, including the CAA, include cost consideration language but do not provide exact guidelines or […]
Public comment on the EPA’s proposed Affordable Clean Energy (ACE) rule closed October 30, 2018, and, as expected, the thousands of responses highlighted the radically diverse opinions on coal-fired energy and climate change held by Americans and industry stakeholders. The ACE proposal (August 31, 2018, Federal Register (FR)) comprised revisions of three existing regulations contained […]
In February 2018, the EPA requested public comment on whether the Agency should continue to abide by its “previous statements” regarding whether point source pollutant discharges to groundwater are subject to regulation under the Clean Water Act (CWA) if the groundwater has a hydrologic connection to Waters of the United States (WOTUS) or waters that […]