MULTI-STATE COMMENTS, LETTERS, STATEMENTS

Date	Matter Type	Action Item	Subject/Issue	States Involved
07/16/2024	COMMENTS	CLIMATE CHANGE ENVIRONMENTAL JUSTICE	Multistate comment letter to the Federal Emergency Management Agency supporting rulemaking petition addressing extreme heat and wildfire smoke.	AZ, CA, CO, CT, DC, IL, MD, MA, MI, NJ, NM, NY, OR, VT
07/12/2024	COMMENTS	ENVIRONMENTAL JUSTICE PUBLIC SAFETY	Multistate reply comment letter to the Federal Communications Commission regarding implementation of multilingual access to wireless emergency alerts.	NY, CT, DC, IL, MD, MA, MN, NV, NM, NJ, OR, RI, VT, WA, WI, New York City
04/03/2024	COMMENTS	PLASTICS	Multistate comment letter to the U.S. Department of State advocating for an ambitious, comprehensive, and legally binding international agreement to end plastic pollution.	NY, CA, CT, DC, HI, MA, NJ, PA, VT
02/27/2024	COMMENTS	CAA WAIVER	Support for CA’s request for waiver for the ACC II regulations under the CAA.	CA, CO, CN, DE, HI, ME, MD, MN, NJ, NY, NC, OR, RI, VT, WA, WI, MI, MA, PA, DC, cities of Chicago, New York, Oakland, San Jose
02/26/2024	COMMENTS	PLASTICS	Multistate comments on U.S. General Services Administration’s proposal to amend the General Services Acquisition Regulation seeking to reduce single-use plastic packaging, 88 Fed. Reg. 88,856 (Dec. 26, 2023).	DC, MA, CA, CT, DE, IL, MD, MN, OR, VT, WA
02/16/2024	COMMENTS	PUBLIC COMMENT CAA ENFORCEMENT	Comment requesting participation in EPA CAA settlement.	VT, ME, MD, MA, NY, OR, RI, WA
02/13/2024	COMMENTS	CLIMATE	Comments on “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review,” 87 Fed. Reg. 74,702 (Dec. 6, 2022)	CA, CO, CT, DE, IL, ME, MD, MI, MN, NM, NY, NC, OR, VT, WA, WI, MA, PA, DC, the City of Chicago
02/09/2024	COMMENTS	PESTICIDES	FIFRA exemption for treated seed and paint products.	OR, MA, NY, HI, IL, MD, MN, NM, VT
01/16/2024	COMMENTS	ENVIRONMENTAL PROTECTION PUBLIC HEALTH ENERGY EFFICIENCY	Multistate comments on the Environmental Protection Agency’s proposed changes to EPA’s Safer Choice Standard, 88 Fed. Reg. 78,017 (Nov. 14, 2023).	AZ, MA, DC, VT, MD, CT, MN, CA, PA, NJ, NY, OR, Corporation Counsel of the City of New York
11/06/2023	COMMENTS	PIPELINE SAFETY PUBLIC HEALTH	Multistate comments supporting the U.S. Pipeline and Hazardous Materials Safety Administration’s proposed revisions to the pipeline safety regulations to require operators of gas distribution pipelines to update their distribution integrity management programs, emergency response plans, operations and maintenance manuals, and other safety practices. 88 Fed. Reg. 61,746 (Sept. 7, 2023).	MA, AZ, CT, DE, ME, MD, MN, NJ, NY, OR, PA, VT, WI, and DC
10/27/2023	COMMENTS	RAIL SAFETY	Multistate comments supporting and offering suggestions on the US Pipeline and Hazardous Materials Safety Administration’s proposed rule to close informational gaps between railroads and first responders. 88 Fed. Reg. 41,541 (June 27, 2023).	PA, CT, DE, IL, MA, ME, MD, NJ, NY, OR, VT WI, DC
09/29/2023	COMMENTS	ENVIRONMENTAL PROTECTION	Multistate comments on Council on Environmental Quality’s proposed Phase 2 Rule revising its National Environmental Policy Act implementing regulations. 88 Fed. Reg. 49924 (July 31, 2023).	WA, CA, NY, CO, DC, CT, DE, IL, ME, MD, MA, NJ, NC, OR, PA, RI, VT, WI, Harris County Attorney’s Office (TX), and New York State Department of Environmental Conservation
09/25/2023	LETTER	INFLATION REDUCTION ACT CLIMATE CHANGE	Joining States ask Congress for equitable and effective implementation of the IRA, to respond to the growing and accelerated climate change-induced disasters.	MA, DE, IL, ME, MD, MI, NJ, NY, OR, RI, VT
09/20/2023	COMMENTS	ENERGY EFFICIENCY	A multistate comment letter that supports the U.S. Department of Energy’s (DOE) proposed conservation standards for consumer water heaters. Anticipated to save consumers money on energy bills and reduce greenhouse gas emissions.	NY, CO, CT, MD, IL, MN, ME, NV, OR, MA, PA, WA, DC
09/08/2023	COMMENTS	PUBLIC HEALTH WATER AND AIR POLLUTION	Multi-state comments on the EPA’s draft supplement to the 1,4-dioxane risk evaluation and draft revised risk determination for 1,4-dioxane.	NY, HI, IL, MD, MA, MN, OR, PA, and WA
08/25/2023	LETTER	PUBLIC HEALTH	Multi-State Letter of Congress on Proposed Amendments to the Radioactive Exposure Compensation Act (RECA).	NM, AZ, CO, CT, DE, DC, MD, MN, NV, NY, PA, OR, and RI
08/16/2023	COMMENTS	PIPELINE SAFETY CLIMATE CHANGE	Multistate comments on Pipeline and Hazardous Materials Safety Administration’s proposed rule to reduce methane emissions from new and existing gas transmission pipelines. 88 Fed. Reg. 31,890 (May 18, 2023).	MD, NY CT, DE, DC, IL, MA, MI, NJ, OR, PA, VT, and WI
08/18/2023	COMMENTS	WASTE DISPOSAL WATER AND AIR POLLUTION	Multi-State Comments on proposed Significant New Use Rule on Certain Chemical Substances relating to Chemical Recycling.	MD, CA, DC, MA, CT, HI, MN, NJ, NY, OR, PA, RI, WA, and WI
08/14/2023	COMMENTS	CLIMATE CHANGE	Multistate comments on the U.S. Postal Service’s Draft Supplemental Environmental Impact Statement for its Next Generation Delivery Vehicles Acquisition program. 88 Fed. Reg. 42401 (June 30, 2023).	NY, CA, CO, CT, DE, DC, IL, ME, MD, NJ, OR, PA, RI, VT, WA, the Corporation Counsel of the City of New York, and the District Council of the Bay Area Air Quality Management District
07/31/2023	COMMENTS	PLASTICS WASTE MANAGEMENT WATER POLLUTION	Multistate comments on the U.S. Environmental Protection Agency’s Draft National Strategy to Prevent Plastic Pollution, 88 Fed. Reg. 27502 (May 2, 2023).	CA, CO, CT, DE, DC, MD, MA, MI, MN, NJ, NY, OR, PA, and VT
07/21/2023	COMMENTS	ENVIRONMENTAL JUSTICE	Multistate comments on Federal Communications Commission’s Notice of Proposed Rulemaking on Wireless Emergency Alerts, 88 Fed. Reg. 40, 606 (June 21, 2023).	NY, CO, CT, DC, IL, MD, MA, MN, NV, NJ, NM, OR, RI, VT, WA, WI, NYC
07/07/2023	COMMENTS	AIR QUALITY ENVIRONMENTAL JUSTICE	Multistate comments on the U.S. Environmental Protection Agency’s proposed revisions to the New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry, and the National Emission Standards for Hazardous Air Pollutants for the Group I & II Polymers and Resins Industry. 88 Fed. Reg. 25,080 (Apr. 25, 2023).	NJ, CT, IL, MD, MA, MI, NY, OR, PA, RI, VT, and WI
07/05/2023	COMMENTS	AIR QUALITY CLIMATE CHANGE	Multistate comments on the U.S. Environmental Protection Agency’s proposed rule titled “Multi-Pollutant Emission Standards for Model Years 2027 Light-Duty and Medium-Duty Vehicles, 88 Fed. Reg. 29,184 (May 5, 2023), which proposes federal standards for emissions of greenhouse gases and criteria pollutants.	CA, CO, CT, DE, DC, HI, IL, ME, MD, MA, MN, NJ, NM, NY, NC, OR, PA, RI, VT, WA, WI, the Cities of Chicago, Los Angeles, New York and Oakland, and the City and County of Denver
06/30/2023	COMMENTS	PUBLIC HEALTH	Multi-state comments to the EPA’s proposed risk management rule for methylene chloride.	NY, IL, MD, MA, OR, WI, and DC
06/29/2023	LETTER	AIR QUALITY ENVIRONMENTAL JUSTICE	Multistate notice of intent to sue the U.S. Environmental Protection Agency for failure to comply with its mandatory duty to review and, as appropriate, revise the New Source Performance Standards for residential wood heaters.	NY, AK, IL, MD, MA, MN, NJ, OR, VT, WA, and the Puget Sound Clean Air Agency
06/27/2023	COMMENTS	AIR QUALITY ENVIRONMENTAL JUSTICE	Multistate comments on the U.S. Environmental Protection Agency’s proposed amendments to the National Emission Standards for Hazardous Air Pollutants for ethylene oxide emissions from commercial sterilization facilities. 88 Fed. Reg. 22,790 (Apr. 13, 2023).	IL, CO, CT, MD, MA, MI, NJ, NY, OR, PA, RI, VT, and WI
06/27/2023	LETTER	PESTICIDES PUBLIC HEALTH ENVIRONMENTAL JUSTICE	Multistate comments on the U.S. Environmental Protection Agency’s proposed interim registration review decision and draft risk assessment for ethylene oxide under the Federal Insecticide, Fungicide and Rodenticide Act. 88 Fed. Reg. 22,447 (Apr. 13, 2023).	NY, CT, IL, MD, MA, MI, NJ, OR, RI, VT, and WI
06/23/2023	COMMENTS	AIR QUALITY ENVIRONMENTAL JUSTICE	Multistate letter commenting on the U.S. Environmental Protection Agency’s proposal, as part of a residual risk and technology review, to strengthen certain aspects of its National Emission Standards for Hazardous Air Pollutants for certain coal and oil-fired power plants. 88 Fed. Reg. 24,854 (Apr. 24, 2023).	MA, MN, CT, IL, ME, MD, MI, NJ, NM, NY, OR, PA, RI, VT, WA, WI, and the Cities of Baltimore, Chicago, and New York
06/20/2023	COMMENTS	FEDERAL AGENCY RULEMAKING CLIMATE CHANGE ENVIRONMENTAL JUSTICE	Multistate letter commenting on the U.S. Office of Management and Budget’s proposed revisions to Circular A-4, which provides guidance to federal agencies on how to assess the impacts of regulations as part of rulemakings. 88 Fed. Reg. 20,195 (April 7, 2023).	NY, CT, DC, IL, MD, MA, MI, MN, NJ, NM, OR, RI, VT, and WA
06/16/2023	COMMENTS	CLIMATE CHANGE AIR QUALITY ENVIRONMENTAL JUSTICE	Multistate letter commenting on the U.S. Environmental Protection Agency’s proposal to strengthen its greenhouse gas emission standards for model year 2027 heavy duty vehicles and issue new greenhouse gas emission standards for model year 2028 through 2032 heavy duty vehicles. 88 Fed. Reg. 25,926 (April 27, 2023).	CA, CT, HI, IL, ME, MD, MA, MN, NJ, NY, NC, OR, PA, RI, VT, WA, WI and the Cities of New York, Los Angeles, and Chicago
06/12/2023	COMMENTS	VEHICLE FUEL ECONOMY	Multistate letter supporting the U.S. Department of Energy’s proposal to update the petroleum fuel economy factors used for taking electric and other alternative-fueled vehicles into account in calculating the average fuel economy of automakers’ fleets for purposes of compliance with federal fuel economy standards. 88 Fed. Reg. 21,525 (April 11, 2023).	CA, CT, DC, HI, IL, ME, MD, MA, MI, MN, NY, OR, PA, RI, VT, WA and the Cities of New York and Chicago
05/08/2023	LETTER	CLEAN WATER	Multistate letter requesting the Environmental Protection Agency and National Oceanic and Atmospheric Administration to take action to address the harm posed by microfibers (microplastics released from washing machines) to the nation’s waters.	CT, CA, DE, DC, IL, MD, MI, MN, NV, NY, OR, PA, RI, VT, WA, and WI
05/08/2023	COMMENTS	PUBLIC HEALTH	Multistate letter responding to federal Consumer Product Safety Commission’s request for information regarding hazards posed by gas ranges. 88 Fed. Reg. 14,150 (Mar. 7, 2023).	DC, DE, MD, MA, MN, NY, RI, OR, VT, WA, and the City of New York
04/17/2023	COMMENTS	ENERGY EFFICIENCY	Multistate comments on the U.S. Department of Energy’s proposed revisions to the Energy Conservation Program: Energy Conservation Standards for Consumer Conventional Cooking Products, 88 Fed. Reg. 6818.	NY, DC, CA, CO, CT, MN, ME, OR, MD, VT, WA, MA, PA, and NYC
03/28/2023	COMMENTS	AIR QUALITY ENVIRONMENTAL JUSTICE	Multistate comment letter on EPA’s proposal to strengthen some but not all of the National Ambient Air Quality Standards for particulate matter.	CA, CT, DE, IL, MD, MA, MI, MN, NJ, NY, OR, PA, RI, VT, WA, WI
03/27/2023	PETITION FOR RECONSIDERATION	AIR QUALITY ENVIRONMENTAL JUSTICE	Multistate petition asking EPA to reconsider certain compliance flexibilities contained in its final rule setting NOx and PM emission standards for heavy duty vehicles and engines (trucks, vans and buses), starting in Model Year 2027. 88 Fed. Reg. 4296	NY, CO, DE, HI, IL, ME, MD, MI, MN, OR, RI, VT, WA, WI, MA and PA
03/27/2023	COMMENTS	POLLINATOR PROTECTION	Multistate comments on applications to register new uses of the pesticide sulfoxaflor, use of which is harmful to pollinators, including honeybees.	CA, AZ, HI, IL, MD, MA, MN, NJ, NM, NY, OR, VT, and WA
03/01/2023 and 03/14/2023	LETTERS (Combined)	CLIMATE CHANGE	Multistate letter to Congressional leaders, including Senator Sanders, opposing a joint resolution introduced by Senator Mike Braun (R-IN) and Representative Andy Barr (R-KY) under the Congressional Review Act to overturn the Department of Labor’s final rule regarding investment advisors’ consideration of environmental, social and governance (ESG) factors, including risks from climate change, in providing investment advice, titled Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights, 87 Fed. Reg. 73822 (Dec. 1, 2022). The letter was submitted to Congressional leaders on March 1, 2023, and forwarded to President Biden on March 14, 2023.	CA, AZ, CT, DE, IL, ME, MD, MA, MI, MN, NJ, NM, NV, NY, NC, OR, PA, RI, VT, WA and DC
02/27/2023	COMMENTS	AIR QUALITY	Multistate comment letter on EPA’s proposed rule to revise its regulations governing state plans for existing stationary sources of air pollutants under Section 111(d) of the Clean Air Act. 87 Fed. Reg. 79,176.	NY, CA, CO, CT, HI, IL, ME, MD, MA, MI, MN, NJ, OR, RI, VT, WA, WI, DC, and the Cities of Boulder, Chicago and Denver
02/21/2023	COMMENTS	PUBLIC SAFETY ENVIRONMENTAL JUSTICE	Multistate letter opposing a request for a special permit authorizing the rail transport of cryogenic liquified ethane from Marcus Hook, PA to undisclosed locations in Canada, Mexico and on the U.S. Gulf Coast.	MD, NY, DE, IL, MA, MI, MN, NJ, OR, PA, RI, VT, WA and DC
02/13/2023	COMMENTS	CLIMATE CHANGE AIR QUALITY ENVIRONMENTAL JUSTICE	Multistate letter supporting EPA’s proposal to supplement its previous proposal to update and strengthen standards providing for reduction of emissions of greenhouse gases and other harmful air pollutants from new, modified, reconstructed and existing oil and natural gas facilities. 87 Fed. Reg. 74,702.	CA, CO, CT, DE, IL, ME, MD, MI, MN, NM, NY, NC, OR, VT, WA, WI, MA, PA, DC, and the City of Chicago
02/13/2023	COMMENTS	CLIMATE CHANGE	Multistate letter supporting the U.S. Department of Defense, General Services Administration, and National Aeronautics and Space Administration’s proposed rule, which proposes to amend the Federal Acquisitions Regulation to require certain federal contractors to disclose climate-related risks to their businesses and their greenhouse gas emissions. Federal Acquisition Regulation: Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk, 87 Fed. Reg. 68,312 (November 14, 2022).	CA, DC, MA, CO, CT, DE, IL, ME, MD, MN, NJ, NM, NY, OR, PA, RI, VT, and WA
02/02/2023	COMMENTS	CLIMATE CHANGE	Multistate letter supplementing previously submitted scoping comments on U.S. Postal Service’s supplemental environmental impact statement for its delivery vehicle replacement plan.	NY, CA, CO, CT, DE, DC, IL, ME, MD, NJ, NC, OR, PA, RI, VT, WA, Corporation Council of the City of New York, and District Council of the Bay Area Air Quality Management District
01/30/2023	COMMENTS	CLIMATE CHANGE ENVIRONMENTAL JUSTICE	Multistate comment letter supporting EPA’s proposed rule, which would restrict use of high global warming potential hydrofluorocarbons in aerosols, foam blowing, refrigeration, air conditioning and heat pumps. 87 Fed. Reg. 76,738 (Dec. 15, 2022).	NY, CA, DE, DC, HI, IL, ME, MD, MN, NJ, NC, OR, VT, WA and WI
01/17/2023	COMMENTS	AIR QUALITY ENVIRONMENTAL JUSTICE	Multistate comment letter supporting EPA’s proposed finding that lead emissions from aircraft fueled by leaded aviation gas causes or contributions to air pollution that may reasonably be anticipated to endanger the public health and welfare. 87 Fed. Reg. 62,753 (Oct. 17, 2022).	CA, CT, MD, MA, MN, NJ, NY, OR, PA, VT, and WI
10/31/2022	COMMENTS	CLEAN AIR CHEMICAL SAFETY	Multistate comment letter on EPA’s proposed rule, Safer Communities by Chemical Accident Prevention, 87 Fed. Reg. 53,556 (Aug. 31, 2022), which would revise EPA’s Risk Management Program regulations under Section 112(r) of the Clean Air Act.	NY, CA, CT, HI, IL, IA, ME, MD, MA, MI, MN, NM, NC, OR, PA, RI, VT, WA, WI, DC, and Harris County, TX
10/13/2022	COMMENTS	CLIMATE CHANGE	Multistate comments on the Federal Highway Administration’s proposed rule to institute a greenhouse gas performance measure for the national highway system.	CA, CO, IL, MD, MN, NY, OR, RI, WA, WI, MA, and DC
10/06/2022	COMMENTS	ENERGY EFFICIENY	Multistate comments supporting the U.S. Department of Energy’s proposed efficiency standards for consumer furnaces.	NY, IL, MA, ME, MD, MN, NV, NJ, NM, OR, VT, WA, DC, City of New York
09/06/2022	COMMENTS	WATER AND AIR POLLUTION WASTE DISPOSAL	Multistate comments on General Services Administration’s Advance Notice of Proposed Rulemaking concerning reducing procurement of single-use plastics.	MA, CA, IL, CT, DE, MD, MN, OR, WA, DC, and City of New York.
08/15/2022	COMMENTS	CLEAN AIR CLIMATE CHANGE	Multistate comments on scope of analysis that should be undertaken pursuant to U.S. Postal Service’s Notice of Intent to prepare a supplement to its Final Environmental Impact Statement for its acquisition of vehicles to replace a substantial portion of its delivery fleet.	CA, CO, CT, DE, IL, ME, MD, MI, NJ, NM, NC, OR, PA, RI, WA, DC, the Corporation Counsel of the City of New York, and the District counsel of the Bay Area Air Quality Management District
08/08/2022	COMMENTS	CLEAN AIR	Multistate comments on EPA’s proposed Clean Water Act Section 401 Water Quality Improvement Rule.	CA, CO, CT, IL, MA, ME, MD, MI, MN, NJ, NM, NY, NC, OR, PA, RI, VT, WA, WI, DC, CA Water Resources & Regional Water Quality Control Boards
08/08/2022	COMMENTS	CLEAN WATER	Multistate comments on EPA’s proposed “Clean Water Act Section 401 Water Quality Certification Improvement Rule.”	CA, CO, CT, IL, MA, ME, MD, MI, MN, NJ, NM, NY, NC, OR, PA, RI, VT, WA, WI, DC, CA State Water Resources Control Board, Nine CA Regional Water Quality Control Boards
08/02/2022	COMMENTS	CLEAN AIR CLIMATE CHANGE	Multistate comments in support of California’s requests to EPA for waivers allowing California to enforce its Heavy-Duty Omnibus regulation, Advanced Clean Trucks regulation, Zero Emission Airport Shuttle Bus regulation, and Zero Emission Powertrain Certification regulation. See 87 Fed. Reg. 35,765 (June 13, 2022); 87 Fed. Reg. 35,768 (June 13, 2022).	CA, CO, CT, DE, HI, IL, MD, MN, NJ, NY, OR, RI, WA, WI, MA, DC, and the City of New York
6/17/2022	COMMENTS	CLIMATE CHANGE INVESTOR PROTECTION	Multistate comments on United States Security and Exchange Commission’s proposed rule which would require registered companies to make climate related disclosures.	CA, CO, CT, DE, HI, IL, ME, MD, MA, MI, MN, NV, NM, NY, OR, RI, VT, WA, WI, and DC
05/22/2022	COMMENTS	ENVIRONMENTAL JUSTICE	The NY AGO requested multi-state sign-on to a comment letter about the Council on Environmental Quality’s beta version of the Climate and Economic Justice Screening Tool. The letter “commend[s] the CEQ for developing the CEJST, [but expresses concern] that the CEJST, in its beta form, does not identify and prioritize communities that are most overburdened with pollution, suffer from chronic underinvestment, and are often communities of color. To better identify and prioritize these communities, the [letter recommends that the] CEJST…incorporate a cumulative impacts approach that includes race and ethnicity and accounts for the discriminatory practices that have led to today’s environmental injustices.”	NY, MD, MA, NC, OR, VT, DC
5/16/2022	COMMENTS	AIR ENVIRONMENTAL JUSTICE	Multistate comments on EPA’s proposal to strengthen NOx emissions standards for heavy duty vehicles (trucks and buses).	CA, CO, CT, DE, HI, IL, ME, MD, MN, NJ, NY, NC, OR, RI, VT, WA, WI, MA and DC

04/25/2022	COMMENTS	ELECTRIC GRID	Multistate comments to Federal Energy Regulatory Commission regarding use of dynamic line ratings.	CT, CA, DE, DC, ME, MD, MA, MI, MN, OR, PA, RI, VT	04/25/2022
04/11/2022	COMMMENTS	CLEAN AIR	Multistate comments supporting the U.S. Environmental Protection Agency’s reaffirmation of its prior determination that it is “appropriate and necessary” to regulate power plant emissions of mercury and other air toxics under Section 112 of the Clean Air Act.	MA, PA, CA, CT, DE, IL, IA, ME, MD, MN, NJ, NM, NY, NC, OR, RI, VT, WA, WI, DC, and the Cities of Baltimore, Chicago, and NY	04/11/2022
04/04/2022	COMMENTS	CLEAN AIR	Multistate comments on U.S. Environmental Protection Agency’s proposed rule which would set standards for particulate matter emissions from aircraft. Control of Air Pollution from Airplanes and Airplane Engines: Emission Standards and Test Procedures, 87 Fed. Reg. 6324 (Feb. 3, 2022).	CA, CT, IL, MD, MA, NJ, NY, OR, PA, VT, WA, WI	04/04/2022
03/31/2022	COMMENTS	CHEMICAL SAFETY CLIMATE CHANGE	Multistate letter to federal Pipeline and Hazardous Materials Safety Administration urging denial of renewal of special permit authorizing liquid natural gas transportation by rail from Wyalusing, PA to Gibbstown, NJ.	NY, MD, DE, IL, MA, MI, MN, OR, RI, VT, WA	03/31/2022
02/28/2022	COMMENTS	FUEL ECONOMY	Multistate comments supporting a petition filed by non-governmental organizations. The petition asks the U.S. Department of Energy to revise its petroleum equivalency factor, which provides fuel economy values for electric and other alternative-fuel vehicles used by the Department of Transportation in determining the compliance of automakers’ light-duty vehicle fleets with federal fuel economy standards.	CA, DE, DC, HI, IL, ME, MD, MI, MN, NV, NY, OR, PA, RI, VT, City of Los Angeles, City of NY, City of Oakland	02/28/2022
02/07/2022	COMMENTS	CLEAN WATER	Multistate comments supporting EPA and Army Corps proposed rule on the definition of waters of the United States (WOTUS).	CA, NY, CT, IL, ME, MD, MA, MI, NM, NC, OR, VT, WA, WI, DC, City of New York, CA State Water Resources Control Board	Sent 02/07/2022
01/31/2022	COMMENTS	CLEAN AIR CLIMATE CHANGE	Multistate comment letter supporting the Environmental Protection Agency’s proposed rule, which would strengthen its current 2016 rule regulating methane emissions from new oil and gas facilities, and, for the first time, set emission guidelines for states to use in developing plans regulating methane emissions from existing oil and gas facilities. 86 Fed. Reg. 63,110 (November 15, 2021).	CA, CO, CT, DE, IL, ME, MD, MI, MN, NJ, NY, NC, OR, RI, VT, WA, WI, MA, PA, DC, City of Chicago	01/31/2022
01/27/2022	COMMENTS	ENERGY EFFICIENCY	Multistate comments urging U.S. Department of Energy to adopt the 45 lumens per watt “backstop” efficiency standard for general service lamps.	NY, CA, CO, IL, MA, ME, MD, MI, MN, NV, NJ, NM, OR, VT, WA, DC, City of New York	Sent 01/27/2022
01/12/2022	LETTER	CLIMATE CHANGE AUTOMOBILE EMISSIONS ENVIRONMENTAL ENFORCEMENT	Multi-state letter to the National Highway Traffic Safety Administration requesting that it make a mandatory 2022 cost of living adjustment of civil penalties for violation of federal automobile fuel economy standards.	NY, CT, DE, IL, IA, ME, MD, MA, MN, NJ, OR, PA, RI, VT, WA	01/12/2022
12/23/2021	LETTER	PUBLIC SAFETY CLIMATE CHANGE	Multistate comments supporting the United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration’s proposed rule, which would suspend its July 2020 rule, which authorized bulk transport of liquefied natural gas nationwide by rail in tank cars.	MD, NY, CT, DE, IL, MA, MI, MN, NJ, OR, PA, RI, VT, WA, DC	12/23/2021

12/13/2021	LETTER	CLIMATE CHANGE	Letter to U.S. Department of Labor supporting its proposed rule which would allow fiduciaries under the federal Employee Retirement Income Security Act to consider environmental, social and governance factors, including climate-change related considerations, in evaluating and selecting plan investments.	CA, CT, DE, DC, MD, MA, MN, NM, NY, NC, OR, VT	12/13/2021
11/26/2021	COMMENTS	ELECTRIC GRID	Multistate reply comments on the Federal Energy Regulatory Commission’s Advance Notice of Proposed Rulemaking regarding possible reforms of transmission planning processes, which reply to comments submitted by others.	CT, CT Department of Energy and Environmental Protection, CT Public Utilities Regulatory Authority, CT Consumer Counsel, DE, DC, MD, MD Office of People’s Counsel, MA, MN, NJ, NJ Board of Public Utilities, RI, VT	11/26/2021
11/24/2021	COMMENTS	ENERGY EFFICIENCY	Multistate comments to the U.S. Department of Energy supporting efficiency standards for manufactured housing.	NY, IL, MA, ME, MI, NV, NJ, NM, OR, VT, WA, City of New York	11/24/2021
11/22/2021	COMMENTS	NEPA	Multistate comments supporting Council on Environmental Quality’s proposed rule revising portions of its regulations implementing the National Environmental Policy Act regarding: (1) the “purpose and need” for agency action; (2) a “ceiling” provision preventing federal agencies from imposing additional procedures or requirements; and (3) the definition of “effects” analyzed in environmental reviews.	WA, CA, NY, CO, DC, DE, Guam, Harris County, IL, ME, MD, MA, NJ, NM, City of New York, NC, OR, PA, RI, VT, WI, The NY State Department of Environmental Conservation	11/22/2021
10/26/2021	LETTER	CLEAN AIR ENVIRONMENTAL JUSTICE	Multistate letter to EPA Administrator and National Climate Advisor requesting more stringent regulation of nitrogen oxide emissions from heavy duty trucks.	CA, DE, CO, HI, IL, MA, ME, MD, MN, PA, RI, VT, WA, WN, DC	10/26/2021
10/26/2021	LETTER	FUEL ECONOMY STANDARDS	Multi-state comment letter on National Highway Traffic Safety Administration’s proposed rule, which would strengthen the Corporate Average Fuel Economy Standards for Model Year 2024-2026 cars and light trucks.	CA, CO, CT, DE, HI, IL, ME, MD, MI, MN, NV, NJ, NM, NY, NC, OR, RI, VT, WA, WN, MA, PA, DC, Cities and Counties of Denver and San Francisco, the Cities of LA, NY, Oakland, San Jose	10/26/2021
10/18/2021	COMMENTS	ENERGY EFFICIENCY	Multistate comments supporting the U.S. Department of Energy’s proposed amendment of its energy efficiency standards program definitions for general service lamps and general service incandescent lamps and associated definitions.	NY, CA, CO, IL, MA, ME, MD, MI, MN, NV, NJ, NM, OR, VT, WA, DC, City of New York	Sent 10/18/2021
10/12/2021	COMMENTS	ENERGY EFFICIENCY	Multistate comments supporting DOE’s proposed rescission of two Rules regarding efficiency standards for short-cycle dishwashers, washers, and dryers	CA, CO, CT, IL, MA, MD, ME, MI, MN, NM, NV, NJ, NY, OR, VT, WA, DC, City of New York	Sent 10/12/2021
10/12/2021	COMMENTS	ENERGY EFFICIENCY	Multistate comments supporting DOE’s notice of proposed interpretation regarding EPCA’s “features” provision for residential gas furnaces and commercial gas water heaters.	NY, CO, IL, MA, ME, MD, MI, MN, NV, NJ, NM, OR, VT, WA, DC, City of New York	Sent 10/12/2021
10/12/2021	COMMENTS	ELECTRIC GRID	Multistate comments on the Federal Energy Regulatory Commission’s Advance Notice of Proposed Rulemaking regarding possible reforms of transmission planning processes.

10/04/2021	COMMENTS	CLIMATE CHANGE MIGRATORY BIRDS	Multistate scoping comments on federal Bureau of Land Management’s Supplement Environmental Impact Statement for the Arctic National Wildlife Refuge Coastal Plain Oil and Gas Leasing Program.	WA, MA, CT, DE, IL, ME, MN, NJ, NY, OR, VT	Sent 10/04/2021
9/27/2021	COMMENTS	CLIMATE CHANGE CLEAN AIR	Multi-state comments on the Environmental Protection Agency’s proposed greenhouse gas emission standards for 2023 and later Model Year light-duty vehicles.	CA, CO, CT, DE, HI, IL, ME, MD, MN, NV, NJ, NM, NY, NC, OR, RI, VT, WA, WN, MA, PA, D.C., the Cities and Counties of Denver and San Francisco, the Cities of LA, NY, Oakland, and San Jose	Sent 9/27/2021
9/20/2021	COMMENTS	ENERGY EFFICIENCY	Multistate comments supporting the U.S. Department of Energy’s proposed changes to its Test Procedure Interim Waiver Process Rule.	NY, CO, CT, IL, MA, ME, MD, MI, MN, NV, NJ, NM, OR, PA, VT, WA, DC, City of New York	Sent 9/20/2021
9/20/2021	COMMENTS	AUTOMOBILE FUEL ECONOMY STANDARDS	Multistate comment letter supporting the National Highway Traffic Safety Administration’s proposal to reinstate an increase in civil penalties for violations of Corporate Average Fuel Economy Standards by light-duty vehicles, starting with Model Year 2019.	CA, NY, CT, DE, IL, IA, ME, MD, MA, MN, NJ, OR, PA, RI, WA, VT	Sent 9/20/2021
09/14/2021	LETTER	CLIMATE CHANGE ENVIRONMENTAL JUSTICE	Letter to Congressional leadership requesting inclusion of measures to address climate change and prioritize environmental justice in the budget reconciliation bill being considered by Congress.	NY, CA, CT, DE, HI, IL, IA, ME, MD, MA, MI, MN, NM, OR, RI, VT, VA, WA, WI, D.C	Sent 9/14/2021
9/13/2021	COMMENTS	ENERGY EFFICIENCY	Multistate comments on the U.S. Department of Energy’s further revised, improved Process Rule.	CA, CO, CT, IL, ME, MD, MA, MI, MN, NV, NJ, NY, OR, PA, VT, WA, DC, City of New York	Sent 9/13/2021
9/3/2021	COMMENTS	CLEAN WATER	Multistate comments on EPA and Army Corps plans to initiate new rulemaking o the definition of waters of the United States (WOTUS).	CA, NY, CT, IL, ME, MD, MA, MI, NJ, NM, NC, OR, RI, VT, VA, WA, WI, DC, City of New York, CA State Water Resources Control Board	Sent 9/3/2021
8/2/2021	COMMENTS	CLEAN WATER	Multistate comments supporting EPA’s proposal to reconsider and revise its Clean Water Act Section 401 Certification Rule.	CA, CO, CT, MA, ME, MD, MI, MN, NJ, NM, NY, NC, OR, PA, RI, VT, VA, WA, DC	Sent 8/2/2021
7/29/2021	COMMENTS	NEPA	Comment letter supporting EPA’s proposal to extend the time for federal agencies to propose updated National Environmental Policy Act implementing procedures to conform to changes to Council on Environmental Quality implementing procedures that are being reviewed by the Biden Administration.	WA, CA, NY, CO, DC, CT, DE, Guam, Harris County, IL, ME, MD, MA, MI, NV, NJ, NM, City of NY, NC, OR, PA, RI, VT, WI, and the NY Dept. of Env. Conservation	Sent 07/29/2021
7/6/2021	COMMENTS	CLEAN AIR CLIMATE CHANGE	Multistate comments supporting EPA’s reconsideration of the Safer Affordable Fuel Efficient Vehicles (SAFE) 1 rule, which urge EPA to reverse its: (1) withdrawal of portions of a 2013 Clean Air Act waiver of preemption for California’s greenhouse gas emission and zero emission vehicle standards for light duty vehicles, which have been adopted by Vermont; and (2) determination that Section 177 of the Clean Air Act does not authorize other states to adopt California’s standards.	CA, NY, CO, CT, DE, DC, HI, IL, ME, MD, MA, MI, MN, NV, NJ, NM, NC, OR, PA, VT, WA, WI, City of Los Angeles, City of New York, City of San Francisco, and City of San Jose	Sent 7/6/2021

7/1/2021	COMMENTS	CLEAN AIR CLIMATE CHANGE	Comments to United States Environmental Protection Agency in support of its proposed rule that would phase-out the production and use of certain hydrofluorocarbons.	MA, CA, CT, DL, IL, IA, ME, MD, MN, NJ, NY, OR, VT, City of NY, DC, MD Dept. of the Environment, and CA Air Resource Board	Sent 7/1/2021
6/21/2021	COMMENTS	CLIMATE CHANGE	Comments to the federal Office of Management and Budget on its “Technical Support Document: Social Costs of Carbon, Methane and Nitrous Oxide, Interim Estimates Under Executive Order 13990,” which discusses “interim values” for the social cost of greenhouse gases for use in federal agency decision making, and a proposed review aimed at developing revised values by January 2022.	NY, CO, CT, DE, IL, MD, MN, NJ, NC, OR, VT, WI, MA, and the CA Air Resource Board	Sent 6/21/2021
6/14/2021	COMMENTS	CLEAN AIR CLIMATE CHANGE	Letter supporting Environmental Protection Agency’s proposed interim final rule rescinding December 2020 rule on consideration of costs and benefits in Clean Air Act rulemakings.	NY, CT, IL, IA, MD, MA, MN, NJ, NM, NC, OR, PA, RI, VT, VA, WI, DC, and the State of CA Air Resources Board	Sent 6/14/2021
6/14/2021	COMMENTS	CLIMATE CHANGE	Letter to Security and Exchange Commission responding to its request for public input on current and potential SEC regulation of climate change disclosures.	CA, CT, DE, IL, MD, MA, MI, MN, NY, OR, VT, WI	Sent 6/14/2021
6/11/2021	COMMENTS	CLEAN AIR CLIMATE CHANGE	Comments supporting National Highway Traffic Safety Administration’s proposal to repeal a portion of the SAFE 1 rule in which it declared that state vehicular greenhouse gas emission standards are preempted by federal law.	CA, CO, CT, HI, IL, ME, MD, MA, MI, MN, NV, NJ, NM, NY, NC, OR, PA, VT, WA, WI, the City of Los Angeles, the City of Oakland, the City and County of San Francisco, and the City of San Jose	Sent 6/11/2021
5/27/2021	COMMENTS	ENERGY EFFICIENCY	Multistate comments on the US Department of Energy’s revised, improved process rule.	CA, CO, CT, IL, ME, MD, MA, MI, MN, NV, NJ, NY, OR, PA, VT, WA, DC, City of New York	Sent 5/27/2021
5/26/2021	COMMENTS	ENERGY EFFICIENCY	Multistate comments on the US Department of Energy’s request for information on whether to amend standards for consumer boilers.	CO, IL, ME, MD, MA, MI, MN, OR, NV, NJ, NY, VT, WA, DC, City of New York	Sent 5/26/2021
5/21/2021	LETTER	CLEAN AIR	Letter to EPA requesting it to consider revoking approval of an alternative test method used by wood heater manufacturers to certify compliance with particulate matter emission standards.	NY, AK, MD, MA, NJ, OR, RI, VT, WA, and the Puget Sound Clean Air Agency	5/21/2021
4/26/2021	LETTER	CLIMATE CHANGE CLEAN AIR	Letter to Congressional leadership supporting Congressional Review Act resolution that would disapprove an EPA rule that eliminated control requirements for methane and volatile organic compound emissions from oil and gas facilities.	NY, CA, CO, CT, DE, IL, IA, ME, MD, MA, MI, MN, NJ, NM, NC, OR, PA, RI, VT, WA, DC, and the Chief Legal Officers of Chicago and Denver	4/26/2021
3/11/2021	COMMENTS	ENERGY EFFICIENCY	Multistate comments on the US Department of Energy’s rulemaking priorities.	CA, CO, IL, MA, MD, ME, NY, NC, NV, OR, PA, VT, WA, City of New York	Sent 03/11/2021

03/05/2021	COMMENTS	PESTICIDES	Comments on the Environmental Protection Agency’s proposed Interim Registration Review Decision, and related Revised Draft Human Health Risk Assessment and Ecological Risk Assessment for the pesticide chlorpyrifos under the Federal Insecticide, Fungicide and Rodenticide Act.	NY, CA, HI, MD, MA, OR, VT, WA, DC	Sent 03/05/2021
2/1/2021	COMMENTS	ENERGY	The Multi-State comments support the Federal Energy Regulatory Commission’s November 19, 2021 Order that proposed reforms to the Open Access Transmission Tariff and regulations under the Federal Power Act; namely, the comments support proposed ambient-adjusted and dynamic line ratings and transparency reforms. The proposed reforms would require transmission providers to implement near term ambient-adjusted ratings on transmission lines, Regional Transmission Organizations (RTOs) and Independent Systems Operators (ISOs) to implement systems and procedures to allow minimum hourly transmission line updates, and RTOs and ISOs to share transmission line ratings and methodologies with transmission providers, relevant RTOs, and relevant ISOs.	VT, MA, RI, CT, CT Department of Energy and Environmental Protection, CT Office of Consumer Council, ME Office of the Pubic Advocate, NH Consumer Advocate	2/1/2021
1/25/2021	COMMENTS	CLEAN AIR CLIMATE CHANGE	Multistate comment letter opposing the National Highway Traffic Safety Administration’s Interim Final Rule repealing for model years 2019-2021 a Congressionally mandated increase in civil penalties for violation of Corporate Average Fuel Economy Standards to adjust for inflation. 86 Fed. Reg. 3016 (January 14, 2021).	CA, NY, CT, DE, IL, IA, ME, MD, MA, MN, NJ, OR, RI, WA, VT	1/25/2021
1/11/2021	COMMENTS	CLEAN WATER	Multistate comments opposing portion of EPA Draft Guidance for applying SCOTUS Hawaii Wildlife Fund decision.	CA, CT, IL, MA, MD, ME, MI, NM, OR, RI, VT, DC	Sent 01/11/2021
12/23/2020	COMMENTS	NATIONAL ENVIRONMENTAL POLICY ACT	The comment letter opposes the United States Department of Transportation’s proposed rule modifying its internal procedures for complying with the National Environmental Policy Act, which were made to conform to recent changes to the Council on Environmental Quality’s National Environmental Policy Act implementing regulations, which a group of states, including Vermont, have challenged in federal court.	NY, DE, DC, GUAM, IL, MD, MA, MI, MN, NJ, NM, NC, OR, PA, VT, WA, WI, the corporation counsel of the city of NY, the county attorney of Harris County, TX	12/23/2020
12/22/2020	COMMENTS	PESTICIDES	Comments opposing EPA’s proposed interim registration decision for the pesticide 1,3 Dichloropropene (1,3-D) under the Federal Insecticide, Fungicide and Rodenticide Act, in which EPA indicates an intent to proceed with downgrading the cancer risk to humans of the pesticide.	CA, OR, MN, VT, NM, NY, IL, DC	12/22/2020
12/17/2020	COMMENTS	GREENHOUSE GASES WILDLIFE PROTECTION	Comments on BLM’s call for nomination of parcels in Arctic National Wildlife Refuge to be leased for oil and gas development and opposing notice of lease sale.	WA, CT, DE, IL, ME, MD, MN, NJ, NY, OR, RI, VT, MA	12/17/2020
12/10/2020	COMMENTS	TSCA	Recall that EPA is evaluating the top 20 high-risk chemicals under TSCA, and we’ve joined four prior comments on other chemicals.	NY, HI, IL, ME, MD, MA, MN, NJ, NC, OR, PA, RI, VT, VA, WA, DC, and the Corporation Counsel of the City of New York	12/10/2020
11/20/2020	COMMENTS	CLEAN AIR	Supplement to comments submitted 6/29/20 opposing EPA’s April 2020 review of the national ambient air quality standards for particulate matter, which requests EPA to consider recent scientific studies.	NY, CA, CT, DE, IL, MD, MA, MI, MN, NJ, OR, PA, RI, VT, VA, WA, WI	11/20/2020
11/18/2020	COMMENTS	CLEAN WATER	Multistate comments on FERC’s proposed rule regarding the time period for waiver under Section 401 of the Clean Water Act.	CT, IL, ME, MD, MA, MI, MN, NV, NJ, NM, OR, PA, RI, VT, VI, DC, CA Water Resources & Regional Water Quality Control Boards	Sent 11/18/2020

11/13/2020	PETITION	CLEAN AIR CLIMATE CHANGE	Petition to EPA which asks it to reconsider two recently issued final rules regarding emission of methane and other pollutants by the oil and gas sector- Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Review, 85 Fed. Reg. 57,018 (Sept. 14, 2020), and Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration, 85 Fed. Reg. 57,398 (Sept. 15, 2020).	CA, CO, CN, DE, IL, ME, MD, MN, NJ, NM, NY, OR, RI, VT, WN, MI, MA, PA, VA, City of Chicago, DC, City and County of Denver	11/13/2020
11/9/2020	COMMENTS	ENERGY EFFICIENCY	Multistate comments opposing DOE’s supplemental proposed interpretive rule that would effectively rollback efficiency standards for residential gas furnaces and commercial gas water heaters.	CA, CO, IL, ME, MD, MA, MN, NY, OR, VT, WA, DC, City of New York	Sent 11/09/2020
11/6/2020	COMMENTS	CLIMATE CHANGE LAND AND WILDLIFE PROTECTION	Comments opposing the federal Bureau of Land Management’s proposal to allow seismic exploration for oil and gas in the Arctic National Wildlife Refuge.		11/6/2020
10/21/2020	LETTER	NOTICE OF POSSIBLE AMICUS BRIEF CLASS ACTION FAIRNESS ACT	Comment letter from states to ensure that proposed national class action Settlement Agreement does not release future state claims for PCB contamination. Case No. 2:16-cv-03493-FMO-AS, US District Court Central District of CA-Western Division.	MD, CA, AK, AZ, CT, DE, HI, IA, ME, MA, MI, MN, NJ, NM, OR, RI, TX, TN, UT, VT, WI	10/21/2020
10/19/2020	COMMENTS	CLIMATE CHANGE CLEAN AIR	Comments to EPA opposing the proposed rule Control of Air Pollution from Airplanes and Airplane Engines: GHG Emission Standards and Test Procedures, Docket No. EPA HQ-OAR-2018-0267, 82 Fed. Reg. 51,556 (Aug. 20, 2020).	CA, CT, IL, MD, MA, MN, NJ, NY, OR, VT, WA, DC	10/19/2020
10/13/2020	COMMENTS	ENERGY EFFICIENCY	Multistate comments opposing DOE’s proposed rule to eliminate efficiency standards for quicker-cycle washers and dryers by creating a separate “product class” for them.	VT, CO, CT, IL, MA, ME, MI, MN, NV, NJ, NM, NY, NC, OR, WA, DC, City of New York	10/13/2020
10/1/2020	COMMENTS	CLEAN AIR ACT	Multistate comments opposing EPA’s proposal to retain National Ambient Air Quality Standards for Ozone at level set in 2015. Docket ID No. EPA-HQ-OAR-2018-0279, 85 Fed. Reg. 49,830 (Aug. 14, 2020)	NY, CA, CT, DC, IL, MD, MA, NJ, OR, PA, RI, VT, WA, WI, and the Corporation Counsel of the City of New York	10/1/2020
8/3/2020	COMMENTS	CLEAN AIR ACT	Comments submitted to the U.S. Environmental Protection Agency’s proposed rule purportedly “increasing consistency and transparency” in the consideration of benefits and costs in Clean Air Act rulemakings. Docket ID No. EPA-HQ-OAR-2020-00044, 85 Fed. Reg. 35,612 (June 11, 2020)	NY, CA, CT, IL, IA, MD, MA, MN, NJ, NC, OR, PA, RI, VT, VA, WA, WI, DC	8/3/2020
7/6/2020	COMMENTS	TSCA	Comments submitted to the EPA regarding the risk evaluation for perchloroethylene. Docket ID No. EPA-HQ-OPPT-2019-0502 (May 4, 2020)	NY, DC, HI, IL, ME, MD, MA, MN, NJ, OR, RI, VT	7/6/2020
6/29/2020	COMMENTS	CLEAN AIR ACT AMBIENT AIR QUALITY	Comments opposing EPA’s April 2020 review of the national ambient air quality standards for particulate matter because the EPA Administrator did not strengthen the standards.	VT, NY, CA, IL, CT, DE, MA, MI, MN, NJ, OR, PA, RI, VI, WA, WI	Sent 06/29/2020

6/29/2020	LETTER	COVID-19 NEPA ENDANGERED SPECIES ACT CLEAN WATER ACT	Letter sent to President Trump expressing concerns over EO 13927. This EO allows federal agencies to use emergency authority to bypass review and permitting requirements in NEPA, ESA, CWA, and other environmental laws.	VT, MD, MA, CA, CO, CT, DE, IL, MI, MN, NJ, NY, OR, VT, WA, WI, DC	Sent 06/29/2020
6/2/2020	COMMENTS	TOXICS	Comments to EPA regarding the draft of TSCA’S risk evaluation for asbestos.	VT, CA, HI, IL, ME, MD, MA, MN, NJ, NY, OR, RI, WA, DC	Sent 06/02/2020
6/1/2020	COMMENTS	ENERGY EFFICIENCY	Comments providing input to the Department of Energy’s request for information on whether to amend certain lightbulb energy efficiency standards.	VT, CA, CO, CT, IL ME, MD, MA, MI, MN, NE, NJ, NY, OR, WA, DC	Sent 06/01/2020
5/15/2020	COMMENTS	ENERGY EFFICIENCY	Comments providing input on the Department of Energy’s energy efficiency rulemakings.	VT, CA, CT, IL, ME, MD, MA, MI, MN, NV, NJ, NY, WA, DC	Sent 05/15/2020
4/6/2020	COMMENTS	ENVIRONMENTAL JUSTICE PESTICIDES TOXICS	Comments to EPA regarding 1,3-Dichloropropene (1,3-D), also known as Telone, asking EPA to revise the draft human health risk assessment for 1,3-D.	VT, CA, IL, MN, NM, NY, OR, DC	Sent 04/06/2020
3/10/2020	COMMENTS	NEPA REGULATIONS	Comments to the White House Council on Environmental Quality opposing the proposed revisions to the NEPA implementing regulations	VT, WA, CA, DC, NY, DE, IL, MD, MA, NJ, NC, OR, PA and the Territory of Guam	Sent on 03/10/2020
2/18/2020	COMMENTS	CLEAN AIR ETHYLENE OXIDE EMISSIONS	Comments to EPA re: National Emission Standards for Hazardous Air Pollutants: Ethylene Oxide (EtO) Commercial Sterilization and Fumigation Operations and concerns of the effectiveness of these standards.	VT, IL, MD, RI, MA, IA, NJ, NY, DE, MN, MI	Sent 02/18/20
1/27/2020	LETTER	NEPA REGULATIONS	Letter to the Council on Environmental Quality re: Notice of Proposed Rulemaking: Update to the Regulations for Implementing the Procedural Provisions of NEPA. Request for an extension of the public comment period by 90 days.	VT, WA, CA, DC, NY, DE, IL, MD, MA, NJ, NC, OR, PA and the Territory of Guam	Sent 01/27/20
1/21/2020	COMMENTS	HAZERDOUS AND SOLID WASTE MANAGEMENT	Comments to EPA regarding the “Coal Ash Proposal” and the “ELG Proposal” in opposition to the proposals’ rollbacks on regulations and extension of deadlines.	VT, MD, PA, IL, MI	Sent 01/21/20
1/21/2020	COMMENTS	LAND USE GHG EMISSONS	Comments to US Bureaus of Land Management’s (BLM) Draft Integrated Activity Plan and Environmental Impact Statement regarding the National Petroleum Reserve in AK, which could open 6.6 million acres of the Reserve to oil and gas leasing.	VT, CA, CT, DE, IL, MD, MN, NJ, NY, OR, WA, MA	Sent 01/21/20

12/30/2019	LETTER	TSCA	Comments to EPA addressing problem formulations of the risk evaluations for the ten chemical substances that are the subject of EPA’s initial chemical risk evaluations.	MA, CA, HI, MA, MD, NJ, NY, OR, VT, WA, DC	Sent on 12/30/19
11/22/2019	COMMENTS	CLEAN AIR EMISSION STANDARDS	Comments to EPA opposing the proposed rule “Oil and Natural Gas Sector: Emissions Standards for New Reconstructed, and Modified Sources Review” and continued support for the EPA’s 2016 emission standards for new, reconstructed, and modified sources in the oil and natural gas sector.	VT, CA, CO, CT, DE, IL, IA, ME, MD, MI, MN, NJ, NM, NY, NC, OR, RI, WA, MA, PA, DC, the City of Chicago, the City and County of Denver, and the Colorado Department of Public Health and Environment	Sent 11/22/19
11/4/2019	COMMENTS	ENERGY EFFICIENCY	Comments to Department of Energy (DOE) opposing the proposed determination that energy conservation standards for general incandescent lamps (GISLs) do not need to be amended.	VT, NY, CA, CO, CT, DC, IL, MA, MD, ME, MI, MN, NJ, NV, OR, WA and the Corporation Counsel of the City of New York	Sent 11/04/19
10/28/2019	COMMENTS	CLEAN AIR CHEMICAL SAFETY	Supplemental Comments to EPA re: elimination of chemical accident safety requirements	VT, NY, PA, IL, IA, ME, MD, MA, MI, NJ, OR, RI, WA	Sent 10/28/19
10/21/2019	COMMENTS	CLEAN WATER	Comments opposing EPA’s Proposed Rule Updating Regulations on Water Quality Certifications under the Clean Water Act.	VT, WA, NY, CA, CO, CT, DE, HI, IL, ME, MD, MI, MN, NJ, NM, NC, OR, RI, WI, MA, PA, VA, DC	Sent 10/21/19
10/16/2019	COMMENTS	ENERGY EFFICIENCY	Comments to DOE opposing creation of new product class for certain quick-cycle dishwashers.	CA, CT, IL, MA, MD, ME, MN, NJ, NY, OR, VT, WA, DC, City of NY	Sent 10/16/19
10/10/2019	COMMENTS	CLEAN AIR ETHYLENE OXIDE EMISSIONS	Comments to EPA urging stricter standards for ethylene oxide (EtO) emissions	VT, IL, CA, CT, DE, DC, IA, MD, MA, MN, NM, NY, NC, RI, VA, WA	Sent 10/10/19
9/9/2019	COMMENTS	ENERGY EFFICIENCY	Comments to DOE opposing proposed interpretive rule regarding gas residential furnaces and commercial water heaters.	CA, CO, IL, ME, MD, MA, MI, NJ, NY, OR, VT, WA, DC, City of New York	Sent 9/9/19
8/26/2019	COMMENTS	NATIONAL FORESTS	Comments to NEPA/USDA Forest Service opposing proposed revisions to the USDA Forest Services’ regulations implementing NEPA	VT, CA, CO, IL, NY	Sent 8/26/19
8/26/2019	COMMENTS	CLEAN AIR	Comments to NEPA opposing CEQ’s draft guidance on consideration of greenhouse gas emissions	VT, CA, CO, CT, DE, DC, IL, ME, MD, MA, MN, NM, NJ, NY, NC, OR, PA, RI, WA	Sent 8/26/19

8/20/2019	COMMENTS	CLEAN AIR CHEMICAL SAFETY	Supplemental Comments to EPA re: Accidental Release Prevention Requirements	VT, NY, PA, IL, IA, ME, MD, MA, MI, NJ, NM, OR, RI, WA	Sent 8/20/19
8/15/2019	COMMENTS	ENDANGERED SPECIES ACT PESTICIDES	Comments to EPA opposing proposed method for evaluating pesticide impacts on endangered species	VT, NM, CA, MD, MA, NJ, NY, OR, PA, WA, DC	Sent 8/15/19
8/7/2019	COMMENTS	CLEAN AIR	Comments to EPA opposing Competitive Enterprise Institute’s (CEI) request for EPA withdrawal of finding that greenhouse gas emissions endanger public health and welfare	VT, MA, CA, CT, DE, IL, MD, NJ, NM, NY, NC, OR, PA, RI, WA, DC, and CA Air Resources Board	Sent 8/7/19
8/6/2019	COMMENTS	ENERGY EFFICIENCY	Comments to DOE on Notice of Proposed Rulemaking regarding test procedure interim waiver process for efficiency, urging DOE to withdraw its proposal	VT, NY, CA, ME, WA, MN, IL, CO, MD, MI, CT, OR, NJ, MA, PA, DC, and the City of NY	Sent 8/6/19
7/25/2019	COMMENTS	CLEAN WATER	Comments opposing EPA’s revised guidance (issued 6/7/19) on Clean Water Act section 401. This guidance was issued under the President’s April 10, 2019 “Executive Order on Promoting Energy Infrastructure and Economic Growth.”	VT, VA, CT, MD, ME, MA, MN, NJ, NM, NY, OR, PA, RI, WA, PA DEP	Sent 7/25/19
7/23/2019	COMMENTS	CLEAN AIR VEHICLE EMISSIONS	Comments to EPA and NHTSA opposing proposed rollback of vehicle emissions and fuel economy standards	VT, NY, CO, CT, DE, ME, MA, MD, NJ, OR, PA, WA	Sent 7/23/19
7/12/2019	LETTER	TSCA ASBESTOS	Letter to Congress in support of the “Alan Reinstein Ban Asbestos Now Act of 2019”	VT, MA, CA, CT, DE, HI, IA, ME, MD, MN, NJ, NY, NC, OR, RI, VA, WA and DC	Sent 7/12/19
6/20/2019	LETTER	CLEAN AIR VEHICLE EMISSIONS	Letter to Congress re: hearing on EPA and NHTSA proposed rollback of vehicle emissions and fuel economy standards	VT, NY, CT, ME, MD, MA, NJ, OR, PA, WA	Sent 6/20/19
6/7/2019	COMMENTS	CLEAN WATER	Comments objecting to EPA’s “Interpretive Statement on Application of the Clean Water Act National Pollutant Discharge Elimination System to Releases of Pollutants from a Point Source to Groundwater.”	VT, MD, CA, CO, CT, ME, MA, MI, OR, RI, DC	Sent 6/7/2019
5/24/2019	COMMENTS	CLEAN WATER	Comments to EPA urging the agency not to weaken current guidance on state water quality certifications under Clean Water Act section 401	VT, NY, CA, CO, CT, ME, MD, MA, MN, NJ, NM, NC, OR, PA, RI, WA, CT DEEP, NY DEP, NC DEQ, PA DEP	Sent 5/24/19

5/10/2019	LETTER	EPA BUDGET CUTS	Letter to US House and Senate Majority and Minority Leaders re: Fiscal Year 2020 Budget for the US Environmental Protection Agency (EPA) and the deep cuts proposed	VT, NY, CA, CT, DE, HI, IL, IA, ME, MD, MA, MN, NJ, NM, NC, OR, RI, VA, DC, and the PA DEP	Sent 5/10/19
5/6/2019	COMMENTS	ENERGY EFFICIENCY	Comments to DOE on Notice of Proposed Rulemaking for Proposed Procedures for Use in New or Revised Energy Conservation Standards and Test Procedures for Consumer Products and Commercial/Industrial Equipment (“the Process Rule”), urging DOE not to revise the Rule	VT, CA, CO, CT, IL, ME, MD, MI, MN, NY, NC, OR, WA, MA, Washington D.C. and the City of NY	Sent 5/6/19
5/3/2019	COMMENTS	ENERGY EFFICIENCY	Comments to DOE urging it not to withdraw two lighting efficiency rules that revise definitions of general service lamp (GSL) and general service incandescent lamp (GSIL).	VT, CA, NY, NJ, OR, CO, CT, IL, ME, MD, MI, MN, NC, WA, MA, DC, and the City of NY	Sent 5/3/19
4/25/2019	COMMENTS	CLEAN WATER	Comments to the US Army Corps of Engineers on its Regulatory Policy Directives Memorandum on Timeframe for Clean Water Act Section 401 Water Quality Certifications	VT, NY, CA, CO, CT, ME, MD, MN, NJ, MC, RI, WA, MA and VA	Sent 4/25/2019
4/17/2019	COMMENTS	CLEAN AIR	Comments to the EPA opposing the agency’s reversal of course on its decision to regulate power plant emissions of mercury and other air toxins under the Clean Air Act.	VT, MA, CA, CT, DE, IL, IA, ME, MD, MI, MN, NV, NJ, NM, NY, NC, OR, RI, VA, WA, DC, and 6 state & county offices	Sent 4/17/2019
4/15/2019	COMMENTS	CLEAN WATER WOTUS	Comments to the EPA and US Army Corp of Engineers opposing the new proposed Waters of the United States (WOTUS) Rule (the “Replacement Rule”)	VT, NY, CA, CT, ME, MD, MA, MI, NJ, NM, OR, RI, VA, WA and DC	Sent 4/15/2019
3/18/2019	COMMENTS	CLEAN AIR GREENHOUSE GAS EMISSIONS	The States and Cities urge EPA to withdraw the Proposed Rule and leave the Current Standard in place. EPA promulgated the Current Standard in 2015 after considering an extensive factual record and explaining and supporting its legal justifications for its action.	VT, CA, CT, DE, IL, IA, ME, MD, MA, MN (by and through its MN Pollution Control Agency), NJ, NM, NY, NC, OR, PA, RI, VA, WA, DC, the MD Dept. of the Environment, and the cities of Boulder, Chicago, Los Angeles, New York, Philadelphia, and South Miami, and Broward County	Sent 3/18/2019
3/18/2019	LETTER	CLEAN AIR EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS	Request for Additional Public Hearings for Proposed Rule: National Emission Standards for Hazardous Air Pollutants: Coal and Oil-Fired Electric Utility Steam Generating Units—Reconsideration of Supplemental Finding and Residual Risk and Technology Review, 84 Fed. Reg. 2670 (2/7/19)	VT, MA, CT, DE, IL, IA, ME, MD, MN, NV, NJ, NY, NC, OR, RI, VA, WA, and the Cities of Chicago and New York	Sent 3/18/2019
3/13/2019	COMMENTS	ENERGY COASTAL PLAIN OIL AND GAS LEASING PROGRAM	Comments on the Coastal Plain Oil and Gas Leasing Program Draft Environmental Impact Statement (DEIS) prepared by the Bureau of Land Management. Significant concerns about the DEIS’s incomplete review of the far-reaching environmental and climate impacts of the first proposed oil and gas leasing program on the Coastal Plain of the Arctic National Wildlife Refuge. 83 Fed. Reg. 67337 (12/28/18)	VT, WA, DE, OR, ME, MD, MI, MN, NJ, NY, NC, RI, MA, PA, VA, DC	Sent 3/13/2019
3/1/2019	COMMENTS	ENERGY EFFICIENY	Comments to Department of Energy calling for the publication of proposed energy efficiency standards for residential gas furnaces and commercial gas water heaters that would increase energy efficiency from 80% to 92-95%, and opposing industry petition for interpretive rule that would effectively weaken standards.	VT, NY, IL, ME, MA, MN, NJ, OR, WA, DC and City of New York	Sent 3/1/19

2/13/2019	COMMENTS	CLEAN AIR WOOD HEATERS, HYDRONIC HEATERS, FORCED AIR FURNACES	Comments opposing EPA's Advance Notice of Proposed Rulemaking for Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces. 83 Fed. Reg. 61,585 (11/30/18)	VT, NY, CT, IL, MD, MA, MN, NJ, OR, RI, WA, and Puget Sound Air Quality Agency	Sent 2/13/2019
1/28/2019	COMMENTS	ENERGY	Comments to FERC urging Commissioner McNamee to recuse himself from FERC Docket AD18-7		Sent 1/28/2019
1/14/2019	COMMENTS	CLEAN AIR WOOD HEATERS	Comments opposing EPA’s proposed to the new source performance standards (NSPS) to allow a two-year sell-through period for non-compliant wood boilers and force-air furnaces, which would allow increased emissions and negative health impacts in violation of the Clean Air Act.	VT, NY, MD, MA, MN, OR, WA and Puget Sound Air Quality Agency	Sent 1/14/19
1/3/2019	COMMENTS	CLEAN AIR LANDFILLS	Comments to EPA opposing the delay in implementing the Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills, which was finalized in August of 2016	VT, CA, IL, MD, NJ, OR, PA, RI, and the California Air Resources Board	Sent 1/3/19
12/21/2018	COMMENTS	CLEAN AIR NATIONAL CLIMATE ASSESSMENT AND PROPOSED RULES WEAKENING GHG EMISSION STANDARDS FOR MOTOR VEHICLES AND POWER PLANTS	Supplemental comments on rollbacks of power plant and automobile greenhouse gas standards	VT, NY, CA, CT, DE, HI, IL, IA, ME, MD, MA, MN, NJ, NM, NC, OR, PA, RI, VA, WA, DC and Broward County (FL) and the cities of Boulder (CO), Chicago, LA, NY, Philadelphia and South Miami (FL)	Sent 12/21/18
12/17/2018	COMMENTS	CLEAN AIR EMISSION STANDARDS FOR OIL AND GAS	Comments to EPA opposing the proposed Reconsideration Rule and continued support of EPA’s 2016 emission standards for new, reconstructed and modified sources in the oil and natural gas sector. Requesting EPA withdraw changes that will increase emissions and recommending that EPA continue to implement and enforce the 2016 standard	CA, CT, IL, IA, ME, MD, NJ, NY, OR, RI, VT, WA, MA and City of Chicago	Sent 12/17/18
12/11/2018	LETTER	CLEAN AIR NATIONAL CLIMATE ASSESSMENT AND PROPOSED RULES WEAKENING GHG EMISSION STANDARDS FOR MOTOR VEHICLES AND POWER PLANTS	Letter to EPA opposing proposed rules to weaken greenhouse gas emission standards for motor vehicles and power plants	NY, CA, CT, DE, HI, IL, IA, ME, MD, MA, MN, NJ, NM, NC, OR, PA, VT, VA, WA, DC and cities of Boulder (CO), Chicago, LA, NY, Philadelphia, Oakland, SF and South Miami (FL)	Sent 12/11/18
11/19/2018	LETTER	PROPOSED EPA RULE FOR “OIL AND GAS SECTOR: EMISSION STANDARDS FOR NEW, RECONSTRUCTED and MODIFIED SOURCES RECONSIDERATION”	Request to EPA that it make public all compliance data submitted to the Agency pursuant to the new source performance standards (NSPS) for the oil and natural gas sector. Further request for EPA to make public any summation, study or other analysis of the data that EPA has in its possession.	CA, IL, IA, ME, MD, NY, RI, VT, WA, MA, DC, Corporation Counsel of the City of Chicago, and the California Air Resources Board	Sent 11/19/18
11/15/2018	COMMENTS	CLEAN AIR REFRIGERANT MANAGEMENET PROGRAM	Comments to EPA opposing proposed revisions to limit the scope of the Refrigerant Management Program and thereby increase emissions of dangerous chemicals	MA, CA, DE, IL, IO, ME, MD, MN, NJ, NY, NC, OR, VA, VT, WA, DC	Sent 11/15/18
10/31/2018	COMMENTS	CLEAN POWER PLAN REPLACEMENT	Comments to EPA opposing proposed rule intended to replace Clean Power Plan	NY, CA, CT, DE, IL, IA, ME, MA, MD, MN, NM NC, OR, PA, RI, VT, VA, WA, DC and cities of Bolder (CO), Chicago, LA, NY, Philadelphia, and South Miami (FL)	Sent 10/31/18

10/26/2018	COMMENTS	VEHICLE EMISSIONS ROLLBACK	Comments to EPA and National Highway Traffic Safety Administration opposing proposed rollback of greenhouse gas emissions and fuel economy standards for model years 2021-2026 passenger cars and light duty trucks	CA, CT, DE, HI, IA, IL, ME, MD, MN, NC, NJ, NM, NY, OR, RI, VT, WA, MA, PA, VA, DC and cities of Oakland, LA, SF, San Jose and NY	Sent 10/26/18
10/26/2018	COMMENTS	VEHICLE EMISSIONS ROLLBACK	Comments to National Highway Traffic Safety Administration opposing draft Environmental Impact Statement (EIS) for “SAFE” Vehicles Rule for Model Year 2021-2026 passenger cars and light duty trucks	CA, CT, DE, HI, IL, IA, MA, ME, MD, MN, NC, NJ, NM, NY, PA, OR, RI, VT, VA, WA, DC and cities of LA, NY, Oakland, SF and San Jose	Sent 10/26/18
9/24/2018	COMMENTS	ENDANGERED SPECIES ACT Docket No. FWS-HQ-ES-2018-0006: Revision of Regs for Listing Species and Designating Critical Habitat, 83 Fed. Reg. 35,193 (7/25/2018) Docket No. FWS-HQ-ES-2018-0009: Revision of Regs for Interagency Cooperation, 83 Fed. Reg. 35,178 (7/25/2018) Docket No FWS-HQ-ES-2018-0007: Revision of Regs for Prohibitions to Threatened Wildlife and Plants, 83 Fed. Reg. 35,174 (7/25/2018)	Comments on the three proposed rules that would undermine the effective implementation of the Endangered Species Act. The Proposed Rules are untethered to, and in clear violation of, the species-protective requirements and overriding conservation purpose of the Endangered Species Act (“ESA” or “Act”) enacted by Congress in 1973. In plain disregard of established law, they would wreak havoc on one of our nation’s most successful conservation laws and harm the States’ vital interests in species protection.	MA, CA, MD, NY, OR, PA, RI, VT, WA, DC	Sent 9/24/2018
9/13/2018	LETTER	Request to maintain funding for the EPA at its FY2018 levels and omit all anti-environmental riders from the spending measure	Letter to Majority Leader McConnell, Minority Leader Schumer, Speaker Ryan, and Minority Leader Pelosi urging Congress to ensure funding for the EPA is maintained at least at its FY2018 levels, omitting all anti-environmental riders from the spending measure.	NY, CA, DE, IA, ME, MD, MA, NJ, OR, RI, VT, WA, DC, PA (Dept. of Environmental Protection)	Sent 9/13/2018
9/11/2018	LETTER	CLEAN AIR Request for Extension of Comment Period Regarding Proposed Rule to Replace the Clean Power Plan, 83 Fed. Reg. 44,746 (Aug. 31, 2018)	Requesting that EPA extend the comment period for the proposed rule to replace the Clean Power Plan by 60-days, to a total of 121 days from the date of publication in the Federal Register.	NY, CA, CT, DE, HI, IL, IA, ME, MD, MA, MN (Minn Pollution Control Agency), NJ, NM, NC, OR, PA, RI, VT, VA, WA, DC, City of Boulder, CO, Chicago, Los Angeles, New York, Philadelphia, and South Miami, and Broward County FL	Sent 9/11/2018
8/27/2018	LETTER	CLEAN AIR Letter to Wheeler/EPA and King/NHTSA RE Request for Extension of Comment Period and Additional Public Hearings Regarding Joint Proposed Rule to Roll Back Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards for Model Years 2021-2026 Light-Duty Vehicles Docket IDs: EPA-HQ-OAR-2018-0283 & NHTSA-2018-0067/NHTSA-2017-0069.	Requesting extension of the comment period for the joint proposed rule to a total of 120 days from the date of publication in the Federal Register. Also requested that the deadline for comments on NHTSA's draft EIS for the joint proposed rule be extended to alight with the 120-comment period.	CA, CT, DE, IA, IL, ME, MD, MA, MN, NJ, NY, NC, OR, PA, RI, VT, WA, DC	CA sent 8/27/2018
8/23/2018	COMMENTS	CLEAN AIR Comments on Accidental Release Prevention Requirements: Risk Management Program Under the Clean Air Act Docket EPA-HQ-OEM-2015-0725 Published at 83 Fed. Reg. 24,850 (May 30, 2018)	Comments urging EPA to abandon the proposed rule and to implement the Accident Prevention Amendments as promulgated.	NY, IL, IA, ME, MD, MA, NJ, NM, OR, RI, VT, WA
8/20/2018	COMMENTS	Council on Environmental Quality (CEQ) regulations regarding the National Environmental Policy Act (NEPA)	Comments in response to CEQ’s June 20, 2018 Advance Notice of Proposed Rulemaking urging CEQ not to weaken NEPA regulations.	VT, MA, NJ, NY, OR, PA DEP, WA,	Sent 8/20/18
8/13/2018	COMMENTS	Cost/Benefit Analyses in Environmental Matters	Comments in response to EPA’s On June 13, 2018 Advance Notice of Proposed Rulemaking, urging EPA not to go forward with a cost/benefit rule that would weaken environmental protection.	VT, NY, CA, IL, IA, MA, MD, MN (MPCA), NJ, OR, PA DEP, WA, DC	Sent 8/13/18
8/13/2018	COMMENTS	CLEAN WATER WOTUS	Comments in response to EPA’s “supplemental notice” regarding its proposal to repeal the 2015 WOTUS Rule, urging EPA not to go forward with the “Repeal Rule.”	VT, NY, CA, CT, MA, ME, MD, NJ, OR, RI, WA, DC	Sent 8/13/18

8/3/2018	COMMENTS	Risk Evaluations for Toxic Substances	A coalition of 11 AGs submitted comments to the EPA critical of the Agency’s proposed framework for the evaluation of the risk posed by toxic chemicals like asbestos to public health and the environment.	MA, CA, HI, ME, MD, NJ, NY, OR, VT, WA, DC	Comments Filed 8/3/2018
8/2/2018	STATEMENT	CLEAN AIR Intention to file suit against EPA, DOT over Car Emission Standards	A coalition of 20 AGs announced that they were prepared to fight the Trump Administration’s proposal to revoke California’s waiver under the Clean Air Act, which allows the State to set its own emissions standard for greenhouse gas emissions. The AGs announced that they are also prepared for a legal battle over the Administration’s proposal to weaken emissions standards for passenger cars and light trucks for model years 2021 through 2026.	MA, CT, DE, HI, IL, IA, ME, MD, MN, NJ, NM, NY, NC, OR, PA, RI, VT, VA, WA, DC	Vermont Press Release MA Press Release 8/2/2018
7/13/2018	LETTER	CLEAN AIR Submitted letter demanding withdrawal of EPAs Glider Truck Rule	Request for Withdrawal or Administrative Stay of US EPA's “Conditional No Action Assurance Regarding Small Manufacturers of Glider Vehicles.”	CA, CT, IL, ME, MD, MA, NJ, NY, NC, OR, PA, VT, WA, Pennsylvania Dept. of Environmental Protection, CA Air Resources Board	Letter sent 7/13/2018
5/21/2018	COMMENTS	CLEAN WATER	Comments urging EPA not to roll back its longstanding position that the Clean Water Act regulates the discharge of pollutants that move from point sources into surface waters via a direct hydrologic connection through groundwater or other conduit.	MD, CA, MA, OR, VT	Sent 5/21/2018
5/9/2018	COMMENTS	ENERGY FERC’s Request for Information from RTOs and ISOs regarding Grid Resiliency	Comments urging FERC not to make recommendations nor draw conclusions related to the resiliency of the New England energy market based solely on ISO-NE's analysis of the market and reiterating objections to requiring ratepayers to subsidize uneconomic energy sources based on exaggerated resiliency concerns.	MA, RI, VT	Sent 5/9/2018
5/2/2018	COMMENTS	CLEAN AIR Comments on 2018 CAFE Penalty Docket No. NHTSA-2018-0017	VT Joined multi-state comments to the National Highway Traffic Safety Administration (NHTSA) over a proposal to cut by over 60 percent the penalty to automakers for violating national fuel economy standards.	NY, CA, DE, DC, IL, IA, MD, MA, NJ, OR, VT, VA, WA	Sent 5/2/2018
4/26/2018	COMMENTS	CLEAN AIR Comments on the Environmental Protection Agency’s proposed Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units, 82 Fed. Reg. 48,035 (Oct. 16, 2017)	VT Joined in opposition to the EPA's proposed Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units. The rule EPA seeks to repeal, commonly known as the “Clean Power Plan” or “CPP,” 80 Fed. Reg. 64,662 (Oct. 23, 2015), sets the first nationwide emission limits on one of our country’s largest sources of harmful greenhouse gases—existing fossil-fueled power plants.	CA, CT, DC, DE, HI, IL, IA, ME, MD, MA, NC, NM, NY, OR, PA, RI, VT, VA, WA, County of Broward FL, Cities of Boulder CO, Chicago IL, New York NY, Philadelphia PA, and South Miami FL.	Sent 4/26/2018
3/23/2018	LETTER	CLEAN AIR Letter to Scott Pruitt/EPA re Notice of Intent to Sue for Failure to Enforce the 2016 Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills 40 C.F.R. Part 60 Subpart Cf	Notice of Intent to Sue for Failure to Enforce the 2016 Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills	CA, IL, MD, NM, OR, RI, VT, CA Air Resource Board and PA Dept. of Environmental Protection	Letter sent 3/23/2018
3/9/2018	LETTER	EPA BUDGET CUTS Urged Congress to Fund EPA, Strip Anti-Environment Riders from Budget	NY AG led a coalition of 14 AGs in sending a letter to congressional leaders urging them "to ensure that funding for the Environmental Protection Agency is maintained at least at its FY 2017 levels, that EPA’s vital core and specific programs receive necessary continued funding, and that all anti-environmental riders that would prohibit, de-fund or otherwise amend key health and environmental protection policies of the Agency are omitted from the spending measure."	NY, CA, DE, IL, IA, ME, MD, MA, NJ, OR, RI, VT, VA, DC, PA Dept. of Environmental Protection	Letter sent 3/9/2018
2/26/2018	COMMENTS	CLEAN AIR Comments on EPA Advance Notice of Proposed Rulemaking re Greenhouse Gas ("GHG") Emissions from Existing Electric Utility Generating Units, 82 Fed. Reg. 61,507 (12/28/2017)	NY AG led 18 AGs in filing comments opposing the "Environmental Protection Agency’s Advance Notice of Proposed Rulemaking ('Advance Notice') on a 'potential' replacement to the Clean Power Plan."	NY, CA, CT, HI, IL, IA, ME, MD, MA, MN, NM, NC, OR, PA, RI, VT, VA, WA, DC, and cities of Boulder (CO), Chicago, New York, Philadelphia, and South Miami (FL) and the count of Broward (FL)	Sent 2/26/2018

1/9/2018	COMMENTS	CLEAN AIR Comments on EPA Administrator Scott Pruitt's Improper Prejudgment of Outcome of Proposed Repeal of Clean Power Plan Docket ID No. EPA-HQ-OAR-2017-0355	This letter specifically focuses on the lack of due process and fairness resulting from prejudgment of the outcome of this rulemaking and procedural failures of EPA.	CA, DE, HI, IL, ME, MD, NM, NY, OR, VT, WA, MA, DC, County of Broward (FL), Cities of Boulder (CO), Chicago, New York, Philadelphia, and South Miami (FL)	01/09/2018
1/5/2018	COMMENTS	CLEAN AIR Comments on proposed "Repeal of Emission Requirements for Glider Vehicles, Glider Engines, and Glider Kits," Docket ID No. EPA-HQ-OAR-2014-0827	In opposition to the EPA's proposal to repeal those provisions of the final rule entitled “Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles – Phase 2,” that apply to glider vehicles, glider engines, and glider kits. Gliders are heavy duty vehicles where a used or refurbished engine is incorporated into a new vehicle chassis. These trucks are typically manufactured alongside of, and sold as, new trucks.	CA, NY, CT, IL, MD, MA, NM, NC, OR, PA, VT, WA	1/5/2018
12/20/2017	LETTER	EPA BUDGET CUTS Letter to Congress opposing FY2018 budget cuts for the EPA and anti-environmental riders.	Letter to Majority Leader McConnell, Minority Leader Schumer, Speaker Ryan, and Minority Leader Pelosi expressing opposition to deep and damaging proposed cuts to the fiscal year 2018 budget for the Environmental Protection Agency (“EPA” or “Agency”) and the anti-environmental riders contained in the federal government appropriation legislation in both the United States Senate and House of Representatives.	NY, CA, IL, IA, ME, MD, MA, OR, RI, VT, VA, DC, Secretary of PA Dept. of Environmental Protection
12/13/2017	COMMENTS	CLEAN WATER WOTUS	Comments to US EPA and the Army Corps of Engineers proposed rule (“Suspension Rule”) to delay effective date of 2015 WOTUS Rule.	NY, CA, HI, ME, MD, MA, OR, RI, VT, WA, DC	Sent 12/13/2017
12/8/2017	COMMENTS	CLEAN AIR Comments on EPA's Notices of Data Availability regarding proposed delays of oil and natural gas sector emission standards EPA-HQ-OAR-2017-0346 and EPA-HQ-OAR-2010-0505 12/8/2017	Comments on the EPA’s two notices of data availability published on November 8, 2017 (the “NODAs”) in support of the two proposed rules titled “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements” and “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Three Month Stay of Certain Requirements”	CA, IL, IA, ME, MD, MA, NM, NY, OR, PA, RI, VT, WA, DC, and the City of Chicago
11/6/2017	LETTER	CLEAN AIR Letter to Transportation Secretary Chao	Attorneys general "called on the Federal Highway Administration (FHWA) to keep in place and enforce the Greenhouse Gas Performance Measure. The Measure went into effect on September 28, 2017. It requires all states to track on-road greenhouse gas emissions, to set locally-appropriate performance targets, and to ensure consistency in data collection.
10/23/2017	COMMENTS	ENERGY	Comments to FERC opposing DOE proposed rule that would subsidize coal and nuclear plants.	MA, CA, CT, IL, MD, NC, OR, RI, VT, WA, CT DEEP, RI Div. of Public Utilities & Carriers, NH Office of Consumer Advocate	FERC issued order terminating rulemaking 1/8/18.
10/10/2017	COMMENTS	CLEAN AIR Comments letter to Danielson/US DOT-NHTSA on Reconsideration of final rule on raising the civil penalty rate for CAFE standard violations Docket No. NHTSA–2017–0059 Filed: 10/10/2017	Submitted comments in response to the National Highway Traffic Safety Administration’s (NHTSA) request for comments on its reconsideration of the Interim Final Rule issued on July 5, 2016. The Interim Final Rule increased the Corporate Average Fuel Economy (CAFE) penalty from $5.50 to $14 per tenth of a mile per gallon (mpg). The Rule also increased the maximum amount to which the agency can increase the CAFE penalty from $10 to $25 per tenth of an mpg. In the Final Rule issued on December 28, 2016, the NHTSA decided that the adjusted CAFE penalty would apply beginning in model year 2019. Attorneys General urged the Highway Administration to implement the Final Rule without change.	NY, DC, IA, MD, MA, OR, PA, VT, WA
10/5/2017	LETTER	CLEAN AIR Notice of Intent to Sue for Failure to Issue Designations for 2015 Ozone National Ambient Air Quality Standards	EPA has failed to promulgate nationwide designations for the 2015 ozone NAAQS. Accordingly, the States intend to file a lawsuit in federal district court to compel EPA to comply with its obligations under the statute.	NY, CA, CT, IL, IA, ME, MN (Minnesota Pollution Control Agency, OR, RI, VT, WA, MA, PA, DC
10/5/2017	COMMENTS	CLEAN AIR Letter to Pruitt/EPA and Chao/NHTSA Reconsideration of Final Determination Midterm Evaluation of Greenhouse Gas Emissions Standards for Model Years 2022-25 Light-Duty Vehicles and Comment on Model Year 2021 Greenhouse Gas Emission Standards Docket No. EPA-HQ-OAR-2015-0827	Letter to E. Scott Pruitt, EPA and Elaine Chao, USDOT/NHTSA, in response to the EPA and NHTSA's joint Request for Comment on Reconsideration of the Final Determination of the Mid-Term Evaluation of Greenhouse Gas Emissions Standards for Model Year 2022-2025 Light-Duty Vehicles.	NY, CT, DE, DC, IA, ME, MD, MA, OR, PA, RI, VT, WA, Secretary of the Commonwealth of PA Dept of EP	Letter sent 6/8/2017

9/27/2017	COMMENTS	CLEAN WATER WOTUS	Comments opposing proposed rule (“Repeal Rule”) by the USEPA and US Army Corps of Engineers that would repeal the 2015 WOTUS Rule.	NY, CA, ME, MD, MA, OR, VT, WA, DC	EPA issued final Repeal Rule 10/22/19.
9/25/2017	COMMENTS	CLEAN AIR Comments letter to Tamm/NHTSA on Scoping for the Environmental Impact Statement for Corporate Average Fuel Economy Standards Model Years 2022-2025 Docket No. NHTSA-2017-0069 Filed: 9/25/2017	Comments in response to the National Highway Traffic Safety Administration’s Notice of Intent to prepare an environmental impact statement and request for scoping comments for corporate average fuel economy (CAFE) standards for model years 2022-2025 and the possible evaluation of the standards for model year 2021.	NY, DC, IA, ME, MD, MA, OR, PA, VT, WA
8/25/2017	LETTER	CLEAN AIR Amended Proposed Consent Decree United States v. Harley-Davidson, Inc. US Dist. Court D.C. Docket No. 1:16-cv-01687 82 Fed. Reg. 34,977	The States object to the proposed decree as amended, specifically the decision by the DOJ and the EPA to forego a $3 million emissions mitigation project included in the original decree.	NY, MA, DE, IL, IA, ME, MD, OR, RI, VT, WA, DC, and the Puget Sound Clean Air Agency	Letter sent 8/25/2017
8/21/2017	LETTER	CLEAN AIR EPA and NHTSA Greenhouse Gas Emissions Standards for Model Year 2022-2025 Light-Duty Vehicles; Model Year 2021 Greenhouse Gas Emissions Standards. 82 Fed. Reg. 39551 (Aug. 21, 2017)	VT Joined multi-state letter responding to EPA and NHTSA; Comments on Reconsideration of Final Determination of the Mid-Term Evaluation of Greenhouse Gas Emissions Standards for Model Year 2022-2025 Light-Duty Vehicles and Comment on Model Year 2021 Greenhouse Gas Emissions Standards	NY, CT, DC, IA, ME, MD, MA, NC, OR, PA, VT, WA
8/9/2017	COMMENTS	CLEAN AIR EPA's Notices of Data Availability regarding proposed delays of oil and natural gas sector emission standards EPA-HQ-OAR-2017-0346 and EPA-HQ-OAR-2010-0505	Comments on the Environmental Protection Agency’s (“EPA”) two notices of data availability published on November 8, 20171 (the “NODAs”) in support of the two proposed rules titled “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements” and “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Three Month Stay of Certain Requirements”	CA, IL, IA, ME, MD, MA, NM, NY, OR, PA, RI, VT, WA, DC, and the City of Chicago
7/7/2017	LETTER	National Monuments Executive Order 13792	Letter to Secretary Zinke re concerns with Executive Order 13792 and its implication that the President or Secretary has the authority to revoke or reduce past National Monument proclamations.	CA, ME, NM, WA, VT	Letter sent 7/7/2017
6/29/2017	LETTER	CLEAN AIR Clean Air Act; Notice of Intent to Sue for Failure to Establish Guidelines for Standards of Performance for Methane Emissions from Existing Oil and Gas Operations under Clean Air Act Section 111(d)	States request that the EPA remedy its failure under the Clean Air Act to establish guidelines for limiting methane emissions from existing sources in the oil and natural gas sector.	NY, CA, CT, IL, IA, ME, MD, MA, NM, OR, PA, RI, VT, WA, DC, City of Chicago	Letter sent 6/29/2017
6/26/2017	LETTER	Letter to Senators McConnel & Schumer in Opposition of S.951: Regulatory Accountability Act of 2017 (RAA)	Letter to Senators McConnell & Schumer in opposition to S.951, the Regulatory Accountability Act of 2017.	NY, CA, DE, IA, ME, MD, MA, OR, RI, VT, WA, DC	Letter sent 6/26/2017
6/8/2017	LETTER	CLEAN AIR Letter to Pruitt/EPA re Midterm Evaluation of Emission Standards for Passenger Cars and Light Duty Trucks for Model Years 2022-25	Letter to E. Scott Pruitt, EPA, in response to his letter to California Governor Brown dated May 2, 2017, regarding the Environmental Protection Agency’s midterm evaluation of the current federal standards for greenhouse gas emissions from cars and light-duty trucks.	NY, CT, DE, DC, IA, ME, MD, MA, OR, PA, RI, VT, WA, Secretary of the Commonwealth of PA Dept of EP	Letter sent 6/8/2017
6/6/2017	STATEMENT	CLEAN AIR Paris Climate Agreement	Reaffirm commitment to Paris Climate Agreement	CA, CT, DE, HI, IA, ME, MD, MA, MN, NM, NY, NC, OR, PA, RI, VT, VA, DC	MA Press Release (6/5/17)

6/5/2017	COMMENTS	PESTICIDES VT joined multi-state filing of legal objections requesting a response and vacate of EPA Administrator's 3/29/2017 order to leave existing tolerances in effect for chlopryrifos. No. EPA-HQ-OPP-2007-1005	EPA Administrator’s order reverses prior administration’s notice to revoke all chlorp yrifos food tolerances. Previous EPA could not find that human exposures to chlorpyrifos met the safety standard under the FFDCA. The administrative records relied upon by EPA at the time showed lack of safety associated with the continued use of chlropyrifos on food because of its adverse neurodevelopmental effects, particularly on children.	NY, WA, CA, MA, ME, MD, VT	6/5/2017
4/26/2017	LETTER	CLEAN AIR HR806 Ozone Standards Implementation Act of 2017	Letter in opposition to H.R. 806, Ozone Standards Implementation Act of 2017. This bill would delay implementation of more protective ozone air quality standards and undermine the mandate in the Clean Air Act (Act) that the national ambient air quality standards for ozone and other criteria pollutants be based on up-to-date scientific evidence and focus solely on protecting public health and welfare.	NY, CA, CT, DE, IL, IA, MD, MA, NM, OR, PA, RI, VT, VA, WA, DC, and the Acting Secretary of the Pennsylvania Department of Environmental Protection
4/3/2017	LETTER	CLEAN AIR Letter to Pruitt/EPA re Withdrawal of Information Collection Request (ICR) for the Oil and Natural Gas Industry EPA ICR No. 2548.01 Final Methane ICR	Letter opposing decision to withdraw the Final Methane ICR issued on November 10, 2016, regarding the EPA's effort to regulate methane emissions from existing sources within the oil and gas sector pursuant to the Clean Air Act.	MA, CA, DC, IL, ME, MD, NY, RI, VT
3/30/2017	LETTER	EPA BUDGET Urging congress to reject budget proposals to gut EPA	Attorney generals opposed the proposed federal budget cuts to the EPA and its critical programs. The attorneys general point to the President’s recent proposal to cut 31 percent from the EPA’s budget, which is the biggest cut of any federal agency in the White House 2018 budget	CT, HI, IL, IA, ME, MD, MA, NY, OR, PA, RI, and DC
3/16/2017	STATEMENT	CLEAN AIR AUTO EMISSIONS - CLEAN AIR Presidential Executive Order on Vehicle Emission Standards	Executive Order directs federal "roll back" (reconsideration) of vehicle greenhouse gas emission and fuel economy standards for new passenger cars and light-duty trucks model years 2022-2025	VT, NY, ME, MD, MA, OR, RI, WA, Washington D.C., Penn Dept. of Environmental Protection	Multi-State statement issued 3/15/17; VT press release 3/16/17
3/3/2017	STATEMENT	CLEANWATER WOTUS	Statement by coalition of attorneys general opposing executive order that guts clean water protections	VT, MY, HI, MA, OR, DC	VT press release (3/3/17)
2/28/2017	LETTER	Letter urging withdrawal of subpoenas duces tecum on AGs re Exxon	AGs Letter asking the withdrawal of the subpoenas duces tecum sent to our colleagues, the attorneys general of Massachusetts and New York.	MD, CA, CT, DE, DC, IL, KY, ME, MS, OR, PA, RI, VT, VA, WA	Sent 2/28/17
2/15/2017	LETTER	CLEAN WATER Letter to U.S. Senate Majority & Minority Leaders opposing the Commercial Vessel Incidental Discharge Act S.168	Letter to U.S. Senate leaders opposing “Commercial Vessel Incidental Discharge Act” legislation that would weaken protections against invasive species	VT, NY, CA, IL, NE, MA, MI, OR, RI, WA	Sent 2/15/17
2/6/2017	LETTER	CLEAN AIR Opposed U.S. Senate Resolution to Void Methane Gas Safeguards	Letter to Schumer and McConnell re opposition to Senate Joint Resolution 11. Repeal of the Rule would contradict the clear statutory mandate that Congress gave BLM in the Mineral Leasing Act of 1920, which requires BLM to take action to prevent waste of oil and gas resources.
1/17/2017	LETTER	CABINET (EPA) APPOINTMENT Appointment of Oklahoma AG Scott Pruitt as Administrator of the U.S. EPA	Letter to Senate Energy & Natural Resources Committee Chair Sen. John Barrasso & Ranking Member Sen. Tom Carper	VT, DE, HI, MD, MA, NY, OR, RI, DC	1/17/17 - Letter Sent MA Press Release (1/18/17)

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