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 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Biofuels Coalition, Boyden Gray & Associates filed a Request for Correction of Information asking EPA to revise its outdated and flawed analysis of the emissions of ethanol and gasoline throughout their production and use.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…
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…
On behalf of the States of Kansas and Nebraska, Boyden Gray & Associates filed the final briefs yesterday in a challenge to EPA’s new vehicular emissions model, MOVES2014. The States are required to use the computer model when they prepare State Implementation Plans for EPA’s air quality standards, but EPA did not give notice and accept comments on the model…
On August 17, Boyden Gray & Associates filed a complaint in the D.C. District Court challenging EPA’s failure to produce documents in response to a Freedom of Information Act (FOIA) request. The documents at issue relate to the design of an EPA fuel effects study known as the EPAct study, which was the basis for EPA’s new vehicular emissions model,…
On July 2, Boyden Gray & Associates filed the Petitioners’ opening brief in Kansas v. EPA (D.C. Cir. No. 14-1268), challenging EPA’s new vehicular emissions model. In the challenged rule, which was promulgated without notice and an opportunity for comment, EPA requires States to use its new model, MOVES2014, in developing state implementation plans for compliance with National Ambient Air Quality Standards under the Clean Air…