In this letter, ECOS reiterates its active interest in compliance and enforcement matters. This letter offers general and specific comments on the NEI’s for EPA’s consideration. Among other things, these comments…
Compliance & Enforcement
Comments on U.S. EPA’s Office of Civil Rights “FY 2015- 2020 External Compliance and Complaints Draft Strategic Plan”
This letter contains the ECOS Planning Committee’s response to EPA’s Office of Civil Rights “FY 2015-2020 External Compliance and Complaints Draft Strategic Plan.” This letter offers a few suggestions for…
EPA Letter to ECOS on NPDES Rule
As the U.S. Environmental Protection Agency finalizes the NPDES E-Reporting Rule, I want to extend my appreciation for the exemplary EPA-state collaboration that brought us to this moment and personally…
Letter to EPA on Draft Environmental Justice (EJ) 2020 Action Agenda Framework
This letter to EPA contains comments on the Draft EJ 2020 Action Agenda Framework (draft Framework) released on April 15, 2015. ECOS supports the draft Framework’s structure, which establishes general Environmental Justice…
2014 Environmental Innovations Green Report: State Bridge-Building, E-Initiatives Yield Results
In 2014, ECOS was pleased to receive 17 impressive nominations and to present awards at its Fall Meeting in Santa Fe to the following five deemed by the Executive Committee…
Pennsylvania’s Permit Review Process and Permit Decision Guarantee
Description of Initiative: By signing Executive Order 2012-11 last July, Gov. Tom Corbett charged the Pennsylvania Department of Environmental Protection (DEP) with developing and implementing a policy that results in…
2013 State Innovations Report
State-developed initiatives are solving pressing challenges, both in protecting human health and the environment and in enhancing operations within agencies themselves. From incorporating new technologies in data tracking and permitting…
Letter to U.S. EPA on Draft National Strategy for Improving Oversight of State Enforcement Performance
This letter provides comments in response to EPA’s Draft “National Strategy for Improving Oversight of State Enforcement Performance.” This letter recommends that EPA remove specific language or implications of “work sharing”…
Use of Impact Analyses in Rulemaking
This report examines the different types of impact analyses which are performed by state environmental agencies as part of the rulemaking process, common criterion required for inclusion in these analyses,…
Tom Easterly, IN, Testifies on U.S. EPA Consent Decrees
This testimony addresses the U.S. Environmental Protection Agency’s use of “consent decrees,” and the impact this has on the operations of state environmental agencies.
