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State Officials Criticize EPA's Use of 'Guidance'

While the EPA’s April 2010 Guidance Memorandum regarding coal-mining permits is already subject to a lawsuit brought by the State of West Virginia and the National Mining Association (NMA), other states are chiming in against EPA’s use of such interim guidance.ˇ

The Environmental Council of the States (ECOS) has approved nine resolutions drafted by various state environmental secretaries protesting EPA’s use of guidance. These state officials claim that such guidance frustrates the states abilities to navigate their respective rulemaking processes and, quite simply, obey the law.

Steven Brown, ECOSs executive director, has recently drafted a report criticizing EPA’s guidance memos and explaining how states ought to review permits for water pollution and mountaintop-removal coal mining to comply with the Clean Water Act.

Brown feels that the EPA is attempting to speed along the rulemaking process, noting that the agency has sometimes directed regional offices to reject permits that do not follow the April 2010 guidance.  According to Brown, this creates a problem where state laws do not permit their agencies to be any stricter than the federal rules require.

There’s a strong desire among some people to right what they believe is an environmental wrong.ˇ Brown said.  “That’s fine.  They should do that.  But they should use the laws and procedures that are in place, and the court decisions over the years, to do it not come up with some cheap shortcut that is impossible for states to   One could certainly imagine what life would be like if sheriffs’ offices took such shortcuts, or the FBI did.  It wouldn’t be a very pleasant place to live, now would it? (Greenwire, March 23).

Source for article can be found here.  Link to resolutions can be found here.