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Office of the Vermont Attorney General

MULTI-STATE COMMENTS, LETTERS, STATEMENTS

DateAction (COMMENTS, STATEMENT OR LETTER)TopicSubject/IssuesStates involvedStatus/Outcome
4/26/2021LETTERCLIMATE 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, D.C., and the Chief Legal Officers of Chicago and Denver4/26/2021
3/11/2021COMMENTSENERGY EFFICIENCYMultistate 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 YorkSent 03/11/2021
03/05/2021COMMENTSPESTICIDESComments 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, D.C. Sent 03/05/2021
2/1/2021COMMENTSENERGYThe 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 Advocate2/1/2021
1/25/2021COMMENTSCLEAN 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, VT1/25/2021
1/11/2021COMMENTSCLEAN WATERMultistate 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, D.C.Sent 01/11/2021
12/23/2020COMMENTSNATIONAL ENVIRONMENTAL POLICY ACTThe 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, D.C., 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
12/22/2020COMMENTSPESTICIDESComments 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, D.C.12/22/2020
12/17/2020COMMENTSGREENHOUSE 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, MA12/17/2020
12/10/2020COMMENTSTSCARecall 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, D.C., and the Corporation Counsel of the City of New York12/10/2020
11/20/2020COMMENTSCLEAN AIRSupplement 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, WI11/20/2020
11/18/2020COMMENTSCLEAN WATERMultistate 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, D.C., CA Water Resources & Regional Water Quality Control BoardsSent 11/18/2020
11/13/2020PETITIONCLEAN 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, D.C., City and County of Denver11/13/2020
11/9/2020COMMENTSENERGY EFFICIENCYMultistate 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, D.C., City of New YorkSent 11/09/2020
11/6/2020COMMENTSCLIMATE 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
10/21/2020LETTERNOTICE 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, WI10/21/2020
10/19/2020COMMENTSCLIMATE 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, D.C.10/19/2020
10/13/2020COMMENTSENERGY EFFICIENCYMultistate 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, D.C., City of New York10/13/2020
10/1/2020COMMENTSCLEAN AIR ACTMultistate 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, D.C., IL, MD, MA, NJ, OR, PA, RI, VT, WA, WI, and the Corporation Counsel of the City of New York10/1/2020
8/3/2020COMMENTSCLEAN AIR ACTComments 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, D.C.8/3/2020
7/6/2020COMMENTSTSCAComments submitted to the EPA regarding the risk evaluation for perchloroethylene. Docket ID No. EPA-HQ-OPPT-2019-0502 (May 4, 2020) NY, D.C., HI, IL, ME, MD, MA, MN, NJ, OR, RI, VT7/6/2020
6/29/2020COMMENTSCLEAN 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
6/29/2020LETTERCOVID-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, D.C.Sent 06/29/2020
6/2/2020COMMENTSTOXICSComments 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, D.C.Sent 06/02/2020
6/1/2020COMMENTSENERGY EFFICIENCYComments 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, D.C.Sent 06/01/2020
5/15/2020COMMENTSENERGY EFFICIENCYComments providing input on the Department of Energy’s energy efficiency rulemakings.VT, CA, CT, IL, ME, MD, MA, MI, MN, NV, NJ, NY, WA, D.C.Sent 05/15/2020
4/6/2020COMMENTSENVIRONMENTAL 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, D.C.Sent 04/06/2020
3/10/2020COMMENTSNEPA REGULATIONSComments to the White House Council on Environmental Quality opposing the proposed revisions to the NEPA implementing regulationsVT, WA, CA, D.C., NY, DE, IL, MD, MA, NJ, NC, OR, PA and the Territory of GuamSent on 03/10/2020
2/18/2020COMMENTSCLEAN 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, MISent 02/18/20
1/27/2020LETTERNEPA REGULATIONSLetter 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, D.C., NY, DE, IL, MD, MA, NJ, NC, OR, PA and the Territory of GuamSent 01/27/20
1/21/2020COMMENTSHAZERDOUS AND SOLID WASTE MANAGEMENTComments 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, MISent 01/21/20
1/21/2020COMMENTSLAND 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, MASent 01/21/20
12/30/2019LETTERTSCAComments 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, D.C.Sent on 12/30/19
11/22/2019COMMENTSCLEAN 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, D.C., the City of Chicago, the City and County of Denver, and the Colorado Department of Public Health and EnvironmentSent 11/22/19
11/4/2019COMMENTSENERGY EFFICIENCYComments 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, D.C., IL, MA, MD, ME, MI, MN, NJ, NV, OR, WA and the Corporation Counsel of the City of New YorkSent 11/04/19
10/28/2019COMMENTSCLEAN AIR

CHEMICAL SAFETY
Supplemental Comments to EPA re: elimination of chemical accident safety requirementsVT, NY, PA, IL, IA, ME, MD, MA, MI, NJ, OR, RI, WASent 10/28/19
10/21/2019COMMENTSCLEAN WATERComments 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, D.C.Sent 10/21/19
10/16/2019COMMENTS
ENERGY EFFICIENCYComments 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 NYSent 10/16/19
10/10/2019COMMENTS
CLEAN AIR

ETHYLENE OXIDE EMISSIONS
Comments to EPA urging stricter standards for ethylene oxide (EtO) emissionsVT, IL, CA, CT, DE, D.C., IA, MD, MA, MN, NM, NY, NC, RI, VA, WASent 10/10/19
9/9/2019COMMENTS
ENERGY EFFICIENCYComments 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, D.C, City of New YorkSent 9/9/19
8/26/2019COMMENTS
NATIONAL FORESTSComments to NEPA/USDA Forest Service opposing proposed revisions to the USDA Forest Services’ regulations implementing NEPAVT, CA, CO, IL, NYSent 8/26/19
8/26/2019COMMENTS
CLEAN AIRComments to NEPA opposing CEQ’s draft guidance on consideration of greenhouse gas emissionsVT, CA, CO, CT, DE, D.C., IL, ME, MD, MA, MN, NM, NJ, NY, NC, OR, PA, RI, WASent 8/26/19
8/20/2019COMMENTS
CLEAN AIR

CHEMICAL SAFETY
Supplemental Comments to EPA re: Accidental Release Prevention RequirementsVT, NY, PA, IL, IA, ME, MD, MA, MI, NJ, NM, OR, RI, WASent 8/20/19
8/15/2019COMMENTS
ENDANGERED SPECIES ACT

PESTICIDES
Comments to EPA opposing proposed method for evaluating pesticide impacts on endangered speciesVT, NM, CA, MD, MA, NJ, NY, OR, PA, WA, D.C.Sent 8/15/19
8/7/2019COMMENTSCLEAN AIRComments to EPA opposing Competitive Enterprise Institute’s (CEI) request for EPA withdrawal of finding that greenhouse gas emissions endanger public health and welfareVT, MA, CA, CT, DE, IL, MD, NJ, NM, NY, NC, OR, PA, RI, WA, D.C. and CA Air Resources BoardSent 8/7/19
8/6/2019COMMENTSENERGY EFFICIENCYComments 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, D.C. and the City of NYSent 8/6/19
7/25/2019COMMENTSCLEAN WATERComments 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 DEPSent 7/25/19
7/23/2019COMMENTSCLEAN AIR

VEHICLE EMISSIONS
Comments to EPA and NHTSA opposing proposed rollback of vehicle emissions and fuel economy standardsVT, NY, CO, CT, DE, ME, MA, MD, NJ, OR, PA, WASent 7/23/19
7/12/2019LETTERTSCA

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 D.C.Sent 7/12/19
6/20/2019LETTERCLEAN AIR

VEHICLE EMISSIONS
Letter to Congress re: hearing on EPA and NHTSA proposed rollback of vehicle emissions and fuel economy standardsVT, NY, CT, ME, MD, MA, NJ, OR, PA, WASent 6/20/19
6/7/2019COMMENTSCLEAN WATERComments 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, D.C.Sent 6/7/2019
5/24/2019COMMENTSCLEAN WATERComments to EPA urging the agency not to weaken current guidance on state water quality certifications under Clean Water Act section 401VT, NY, CA, CO, CT, ME, MD, MA, MN, NJ, NM, NC, OR, PA, RI, WA, CT DEEP, NY DEP, NC DEQ, PA DEPSent 5/24/19
5/10/2019LETTEREPA BUDGET CUTSLetter 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 proposedVT, NY, CA, CT, DE, HI, IL, IA, ME, MD, MA, MN, NJ, NM, NC, OR, RI, VA, Washington D.C. and the PA DEPSent 5/10/19
5/6/2019COMMENTSENERGY EFFICIENCYComments 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 RuleVT, CA, CO, CT, IL, ME, MD, MI, MN, NY, NC, OR, WA, MA, Washington D.C. and the City of NYSent 5/6/19
5/3/2019COMMENTSENERGY EFFICIENCYComments 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, D.C. and the City of NYSent 5/3/19
4/25/2019COMMENTSCLEAN WATERComments to the US Army Corps of Engineers on its Regulatory Policy Directives Memorandum on Timeframe for Clean Water Act Section 401 Water Quality CertificationsVT, NY, CA, CO, CT, ME, MD, MN, NJ, MC, RI, WA, MA and VASent 4/25/2019
4/17/2019COMMENTSCLEAN AIRComments 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, D.C. and 6 state & county officesSent 4/17/2019
4/15/2019COMMENTSCLEAN 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 DCSent 4/15/2019
3/18/2019COMMENTSCLEAN 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 CountySent 3/18/2019
3/18/2019LETTERCLEAN 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 YorkSent 3/18/2019
3/13/2019COMMENTSENERGY

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, DCSent 3/13/2019
3/1/2019COMMENTSENERGY EFFICIENYComments 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 YorkSent 3/1/19
2/13/2019COMMENTSCLEAN 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 AgencySent 2/13/2019
1/28/2019COMMENTSENERGYComments to FERC urging Commissioner McNamee to recuse himself from FERC Docket AD18-7Sent 1/28/2019
1/14/2019COMMENTSCLEAN 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
1/3/2019COMMENTSCLEAN 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 2016VT, CA, IL, MD, NJ, OR, PA, RI, and the California Air Resources Board Sent 1/3/19
12/21/2018COMMENTSCLEAN 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 standardsVT, 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
12/17/2018COMMENTSCLEAN 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 ChicagoSent 12/17/18
12/11/2018LETTERCLEAN 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 plantsNY, 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
11/19/2018LETTERPROPOSED 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 BoardSent 11/19/18
11/15/2018COMMENTSCLEAN 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 chemicalsMA, CA, DE, IL, IO, ME, MD, MN, NJ, NY, NC, OR, VA, VT, WA, DCSent 11/15/18
10/31/2018COMMENTSCLEAN POWER PLAN

REPLACEMENT
Comments to EPA opposing proposed rule intended to replace Clean Power PlanNY, 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
10/26/2018COMMENTSVEHICLE 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 trucksCA, 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 NYSent 10/26/18
10/26/2018COMMENTSVEHICLE 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 trucksCA, 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 JoseSent 10/26/18
9/24/2018COMMENTSENDANGERED 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, DCSent 9/24/2018
9/13/2018LETTERRequest to maintain funding for the EPA at its FY2018 levels and omit all anti-environmental riders from the spending measureLetter 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
9/11/2018LETTERCLEAN 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 FLSent 9/11/2018
8/27/2018LETTERCLEAN 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, DCCA sent 8/27/2018
8/23/2018COMMENTSCLEAN 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
8/20/2018COMMENTSCouncil 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
8/13/2018COMMENTSCost/Benefit Analyses in Environmental MattersComments 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
8/13/2018COMMENTSCLEAN 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
8/3/2018COMMENTSRisk Evaluations for Toxic SubstancesA 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, DCComments Filed 8/3/2018
8/2/2018STATEMENTCLEAN 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, DCVermont Press Release

MA Press Release 8/2/2018
7/13/2018LETTERCLEAN 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 BoardLetter sent 7/13/2018
5/21/2018COMMENTSCLEAN WATERComments 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, VTSent 5/21/2018
5/9/2018COMMENTSENERGY
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, VTSent 5/9/2018
5/2/2018COMMENTSCLEAN 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, WASent 5/2/2018
4/26/2018COMMENTSCLEAN 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
3/23/2018LETTERCLEAN 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 LandfillsCA, IL, MD, NM, OR, RI, VT, CA Air Resource Board and PA Dept. of Environmental ProtectionLetter sent 3/23/2018
3/9/2018LETTEREPA 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 ProtectionLetter sent 3/9/2018
2/26/2018COMMENTSCLEAN 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
1/9/2018COMMENTSCLEAN 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
1/5/2018COMMENTSCLEAN 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, WA1/5/2018
12/20/2017LETTEREPA 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
12/13/2017COMMENTSCLEAN 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, DCSent 12/13/2017
12/8/2017COMMENTSCLEAN 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
11/6/2017LETTERCLEAN 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.
10/23/2017COMMENTSENERGYComments 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.
10/10/2017COMMENTSCLEAN 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
10/5/2017LETTERCLEAN 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
10/5/2017COMMENTSCLEAN 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 EPLetter sent 6/8/2017
9/27/2017COMMENTSCLEAN 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, DCEPA issued final Repeal Rule 10/22/19.
9/25/2017COMMENTSCLEAN 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
8/25/2017LETTERCLEAN 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 AgencyLetter sent 8/25/2017
8/21/2017LETTERCLEAN 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 StandardsNY, CT, DC, IA, ME, MD, MA, NC, OR, PA, VT, WA
8/9/2017COMMENTSCLEAN 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
7/7/2017LETTERNational 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, VTLetter sent 7/7/2017
6/29/2017LETTERCLEAN 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 ChicagoLetter sent 6/29/2017
6/26/2017LETTERLetter 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, DCLetter sent 6/26/2017
6/8/2017LETTERCLEAN 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 EPLetter sent 6/8/2017
6/6/2017STATEMENTCLEAN AIR
Paris Climate Agreement
Reaffirm commitment to Paris Climate AgreementCA, CT, DE, HI, IA, ME, MD, MA, MN, NM, NY, NC, OR, PA, RI, VT, VA, DCMA Press Release (6/5/17)
6/5/2017COMMENTSPESTICIDES
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, VT6/5/2017
4/26/2017LETTERCLEAN 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
4/3/2017LETTERCLEAN 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
3/30/2017LETTEREPA 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 budgetCT, HI, IL, IA, ME, MD, MA, NY, OR, PA, RI, and DC
3/16/2017STATEMENTCLEAN 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 2022-2025VT, 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
3/3/2017STATEMENTCLEANWATER

WOTUS
Statement by coalition of attorneys general opposing executive order that guts clean water protectionsVT, MY, HI, MA, OR, DCVT press release (3/3/17)
2/28/2017LETTERLetter urging withdrawal of subpoenas duces tecum on AGs re ExxonAGs 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
2/15/2017LETTERCLEAN 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 speciesVT, NY, CA, IL, NE, MA, MI, OR, RI, WASent 2/15/17
2/6/2017LETTERCLEAN 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.
1/17/2017LETTERCABINET (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 CarperVT, DE, HI, MD, MA, NY, OR, RI, DC1/17/17 - Letter Sent

MA Press Release (1/18/17)