Adrienne,

Are you referring a procedure EPA calls “direct final” rulemaking? This is a procedure through which EPA can issue a non-controversial regulation without a comment period. But if anyone objects, it is automatically rescinded, and becomes just a regular proposal that then is followed by a comment period and (if requested) a public hearing, and then a final rule in the normal course.

This is available only for truly non-controversial stuff, because, as I said, it is automatically rescinded if anyone objects.

If you are thinking of something else, let me know.

DAVID DONIGER

Senior Strategic Director

Climate and Clean Energy Program

NATURAL RESOURCES

DEFENSE COUNCIL

From: cdp@groups.b-team.org [mailto:cdp@groups.b-team.org] On Behalf Of Adrienne Hollis
Sent: Friday, June 22, 2018 11:44 AM
To: Combined Defense Project <cdp@groups.b-team.org>
Subject: [cdp] Re: Loophole in CAA

My apologies! I said legislation, but meant regulations!! Doing too much at one time! Thanks Melinda for spotting that!!!

Dr. Adrienne L. Hollis, Esq.

Director of Federal Policy

WE ACT for Environmental Justice

50 F Street, NW, Seventh Floor

Washington, DC 20001

office: 202-495-3036

Email: Adrienne@weact.org

Twitter: @EjToxicdoc

On Fri, Jun 22, 2018 at 11:33 AM, Adrienne Hollis <adrienne@weact.org> wrote:

Greetings Everyone;

Does anyone remember the particular section of the CAA that has a "loophole provision" allowing EPA to decide NOT to have public hearings or meetings on legislation?

I am trying to find out how many legislative actions have occurred with no public input and I remember last year that there was a provision in the CAA that EPA used to get out of that requirement.

Thanks,

Adrienne

Dr. Adrienne L. Hollis, Esq.

Director of Federal Policy

WE ACT for Environmental Justice

50 F Street, NW, Seventh Floor

Washington, DC 20001

office: 202-495-3036

Email: Adrienne@weact.org

Twitter: @EjToxicdoc

Follow us on Facebook | Twitter | Instagram

To unsubscribe from this list please go to http://www.simplelists.com/confirm.php?u=9eL1dA230sdpltwJtofm3VYlO6BnTgGj