Public Comments / Publications

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

EPA NSPS Greenhouse Gas Proposed Rule (replacing Clean Power Plan) – August 2023

Revisions and Confidentiality Determination for Data Elements under EPA’s Greenhouse Gas Reporting Rule – July 2023

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


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...

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