Public Comments / Publications

This listing does not include regulatory comments written on behalf of clients where submittal is made by client.

FMEA Comments to U.S. EPA On Clean Power Plan Repeal April 26, 2018

Clean Power Plan (CPP) Replacement ANPR Questions and Answers February 26, 2018

Comments Regarding Federalism Consultation in Anticipation of Proposed Rule to Revise Existing 1991 Lead and Copper Rule March 8, 2018

Comments to Federal Energy Regulatory Commission (FERC) In Response to Grid Reliability and Resilience Pricing Questionnaire, Oct 23, 2017

Commentary, POWER Magazine, Oct.1, 2017. Also on page 56 of paper version.

What Electric Utilites Need to Know About Natural Gas, American Coal Magazine, Issue 2, 2017

Comments to EPA Science Advisory Board on biomass as fuel, August 2017

Comments Regarding Evaluation of Existing EPA Regulations, May 15, 2017

Impact of Federal Regulation on Domestic Manufacturing Comments to Department of Commerce (regarding EPA), March 31, 2017

Push to Natural Gas Presents Advantages and Challenges to Electric Utilities Given Current Infrastructure’s Readiness, January 2017

Comments on the National Emission Standards for Hazardous Air Pollutants: Ferroalloys Production Reconsideration of NESHAP Proposed Rule Comments, August 18, 2016

APPA SAB Comments Dec 2013 Written comments follow oral testimony on behalf of APPA, former employer.

Implications of Greater Reliance on Natural Gas for Electricity Generation Designed for APPA and managed by Aspen Environmental (consultant)

Natural Gas, Hydraulic Fracturing and Implications for Electric Utilities

Contributing Author / Advisor

Electric reliability/NERC Report (Contributing Author/ Unpaid Advisor), November 2017

Small Business Comments

Dept. of Labor Changes to ERISA Allowing Association Health Plans (AHP) (March 6, 2018)

Comments to U. S. Bureau of Census Questions for Small Businesses (Feb. 12, 2018)

Comments to SBA on health care regulatory reform for small business under Executive Orders 13777 and 13771, Oct 2, 2017

Blog

WSJ Story Today on Regulations Not to Be Missed

Many of us in regulated industries have worried about increasing scope of regulations. Perhaps sometimes industry comes across in the news like we don't approve of any regulations or don't even like stop signs. Of course that is not the case.  This Wall Street Journal...

read more