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2012
AGA Comments on the EPA Stormwater Notice March 5, 2012
AGA Comments on EPA NSPS Air Rule for Turbines (Dec. 28, 2012)
Regulating Construction Site Stormwater Discharges with a Strong Statewide Program in Alabama (Dec. 3, 2012)
Federal Agency Leadership of Environmental Consultations for Natural Gas Projects (Dec. 10, 2012)
AGA Comments on Water Resources Permitting in California for Natural Gas Projects (Dec. 7, 2012)
AGA Comments on Pennsylvania Natural Diversity Index Tool for Environmental Permits (Dec. 3, 2012)
Comments on EPA’s PCB Transportation Manifest Rules (Nov. 5, 2012)
Sierra Club v. Bostick – Briefs to 10th Circuit in Appeal of Order Denying Motion for Injunction (Oct. 2012)
Courts Deny Sierra Club’s Motions for Injunction (Aug. 29, 2012)
Comments on EPA’s Draft Environmental Justice Best Practices for Permit Applicants (Aug. 27, 2012)
AGA Joins Multi-Industry Letter to Senate on TSCA Legislation (Aug. 21, 2012)
AGA Comments on EPA Proposal to Amend NESHAPS for Reciprocating Internal Combustion Engines (Aug. 9, 2012)
Sierra Club v Bostick - AGA Moves to Intervene in Support of Streamlined Utility Wetlands Permit (July 30, 2012)
Court Grants AGA's Motion to Intervene in Sierra Club v. Bostick (Aug. 1, 2012)
AGA Comments on EPA GHG Subpart W Reporting Rule Technical Corrections (June 20, 2012)
AGA Comments on EPA Subpart W Greenhouse Gas Confidential Business Information & Reporting Deferral Proposed Rule (April 9, 2012)
AGA Comments on Major Source Boiler MACT Proposed Rule (Feb. 21, 2012)
AGA Court Challenge to GHGReporting Rule Subpart W Technical Revisions (Feb. 21, 2012)
AGA Supports SoCalGas’ Challenge to California Anti-LNG Rule (Jan. 4, 2012)
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Prior to 2006

 Comments on EPA’s Draft Environmental Justice Best Practices for Permit Applicants (Aug. 27, 2012) 

AGA is a member of the NAM Business Network for Environmental Justice and joined in the comments BNEJ filed on August 27, 2012 regarding EPA’s June 26, 2012 draft documents entitled (1) “Proposed Regional Actions to Promote Public Participation
in the Permitting Process” and (2) “Draft Best Practices for Permit Applicants Seeking EPA-Issued Permits,” hereinafter collectively referred to simply as “the Draft Guidance.”

The BNEJ believes that all people should be treated fairly under the laws, including environmental laws, without discrimination based on race, color or national origin.  The BNEJ comments commend the EPA’s accurate and thoughtful description of the important role that industrial facilities play in America’s communities, while expressing the following concerns regarding the legal role and appropriate use of the Draft Guidance. 

Specifically, the Draft Guidance should:

1. Acknowledge and address the framework of existing the EPA regulations and guidance documents that in many cases already address the same issues.

2. Prioritize the activities it seeks to encourage. (For example, the EPA should differentiate between new and existing facilities, between major and minor changes to facility operations, and between communities that have serious environmental justice issues and communities that do not.)

3. Clearly state that its purpose is to provide suggestions, rather than to establish a new “procedural checklist,” and that any deviations from the Draft Guidance cannot be used to delay, oppose, or challenge a particular permit.

4. Avoid using the term “Best Practices,” because each facility and community present unique facts, making the choice of practices in each case highly site-specific.

 Comments of the Business Network for Environmental Justice

 

 
 

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