Boyden Gray & Associates filed a comment yesterday on behalf of Consumers’ Research opposing the FCC’s Universal Service Fund (USF). The comment argues that the Universal Service Fund is an unconstitutional tax raised and spent by an unaccountable federal agency. What’s more, this unaccountable federal agency–the FCC– has delegated all authority over this revenue-raising scheme to a private company registered…
Boyden Gray & Associates filed a comment yesterday on behalf of Urban Air Initiative and Consumers’ Research opposing the EPA’s proposed reinstatement of a waiver for California vehicle emission standards. The comment argues that the reinstatement of the waiver would be improper because California’s greenhouse gas emissions standards have been amended since the initial waiver was granted without EPA approval….
On Monday, Boyden Gray & Associates filed comments on behalf of Urban Air Initiative urging EPA to correct its erroneous modeling of ethanol’s effect on gasoline emissions. The comments came in response to EPA’s Advanced Notice of Proposed Rulemaking on Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process. EPA acknowledged that “any assessment of costs (and…
On behalf of the Urban Air Initiative, Clean Fuels Development Coalition, 25x’25 Alliance, Nebraska Ethanol Board, and Nebraska Ethanol Industry Coalition, Boyden Gray & Associates filed comments on EPA’s Proposed Renewable Fuel Standard Rule for 2018, asking EPA to revise its outdated 2010 lifecycle analysis for corn ethanol. In its comments on the Proposed Rule, BG&A highlighted a recent USDA…
