Public Comments / Publications
This listing does not include regulatory comments written on behalf of clients where submittal is made by client.
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).
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
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
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)
Contributing Author / Advisor
Electric reliability/NERC Report (Contributing Author/ Unpaid Advisor), November 2017
Small Business Comments
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...read more
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...read more
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
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...read more