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BG&A Files Comments on Behalf of Consumers’ Research Opposing FCC’s Universal Service Fund

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…

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BG&A Files Comments on Behalf of Urban Air Initiative and Consumers’ Research Opposing Reinstatement of California Vehicle Emission Regulations Waiver

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….

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Environmental Organizations and State Governors Ask EPA to Correct Outdated Ethanol and Gasoline Lifecycle Emissions Estimates

On behalf of the Energy Future Coalition, the Urban Air Initiative, and the Governors’ Biofuels Coalition, Boyden Gray & Associates filed a Request for Correction of Information asking EPA to revise its outdated and flawed analysis of the emissions of ethanol and gasoline throughout their production and use. EPA continues to rely on its 2010 lifecycle analysis in rules related to…

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BG&A Argues States’ Emissions Model Case Before D.C. Circuit

On Thursday, Boyden Gray & Associates argued on behalf of Kansas and Nebraska in the U.S. Court of Appeals for the D.C. Circuit. The case is a challenge to EPA’s vehicular emissions model, MOVES2014. The model produces erroneous emissions estimates that will make it harder for States to comply with EPA’s air quality standards. The States argued before Judges Millett, Wilkins, and Randolph…

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