Public Comments / Publications
This listing does not include regulatory comments written on behalf of clients where submittal is made by client.
Petition to Dept. of Justice regarding anti-competitiveness consequences of DOE’s distribution transformer proposed rule with reliance upon one steel company – March 27, 2023
Comments submitted to U. S. Dept. of Energy on proposed distribution transformer energy efficiency standard – March 23, 2023.
Comments to PHMSA regarding natural gas pipeline reliability and regulatory reform – August 2020
Environmental Law Institute Webinar – April 2020
Gas Pipeline Comments PHMSA – April 2020
Comments on EPA’s Proposed Rule on Lead and Copper Corrosion in Pipes – February 2020
Comments to NERC regarding draft NERC gas-electric reliability guidance – December 2019
Comments to U. S. Environmental Protection Agency (EPA) Regarding Re-proposal of U. S. EPA’s New Source Performance Standard (NSPS) for Methane – December 2019
Comments to PHMSA Regarding LNG by Rail, PHMSA 2018-0025, Dec. 2019 (submitted October 25, 2019)
Comments to FERC regarding NERC Reliability Standard – August 26, 2019
Comments to PHMSA Regarding LNG By Rail – July 26, 2019
Oil & Gas NSPS for Methane – EPA Reconsideration December 17, 2018
“ACE” CO2 NSPS Comments to EPA October 31, 2018
Cost Benefit ANPRM Comments August 13, 2018
Comments regarding Steel/Aluminum Tariffs August 10, 2018
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
2019 Electric Gas Working Group (EGWG) study and advisor to North American Electric Reliability Corporation (NERC) – by invitation only. (Final 2019 work product not yet issued).
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
EPA and Construction Industry’s Jan. 19th, 2017 Construction General Permit (CGP) Needs Correction
Last summer I wrote about EPA’s proposed rule on Construction General Permit (CGP) and the ridiculous requirements about testing for PCBs from caulk in all demolition debris. The EPA had, perhaps with good intention, over-reached, because PCB in demolition debris is...
EPA’s Ferroalloy Regulation Is Not Transparent But Tucked A Gift for All Industries Inside
On August 29 EPA closed its comment period for its limited reconsideration on an obscure ferroalloy regulation. To oversimplify, ferroalloy production is essential to make steel and we only have two of these companies in the U. S. So their NESHAP is not exactly the...
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...
EPA’s proposed rule for construction industry’s debris should give one pause
We have all been overwhelmed with tragic news and sometimes in that process we lose track of other smaller stories. Earlier in July the Washington Examiner had a story about the U. S. EPA regulations that made me think. Of course we need national and state regulations...