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The document argues that the EPA's 2026 proposed rule to weaken the Risk Management Program (RMP) is unlawful, arbitrary, and contrary to the Clean Air Act's mandate to prevent accidental chemical releases. The commenters contend that the proposal prioritizes industry cost savings and deregulatory executive orders over public health and safety, specifically threatening vulnerable populations and children. They call for the full implementation of the 2024 SCCAP Rule, the restoration of the RMP Public Data Tool, and the retention of critical safety requirements including safer technology analyses, third-party audits, and natural hazard planning.

CATF supports the CFTC's oversight of voluntary carbon markets but argues that current crediting protocols are insufficient to prevent market manipulation and over-crediting. The organization recommends adding 'durability' and 'vintage' as essential commodity characteristics and requiring project-level transparency rather than relying on general protocol disclosures. CATF further urges the Commission to strengthen criteria for additionality, quantification (specifically leakage avoidance and business-as-usual baselines), and the mitigation of reversal risks, particularly for nature-based projects. Finally, it emphasizes the need for independent third-party verification to avoid conflicts of interest between project developers and verifiers.

A coalition of environmental organizations urges the EPA to prioritize MERP funding for enhanced monitoring, compliance assurance, and the permanent plugging of marginal conventional wells, while limiting financial assistance to private operators.

A coalition of environmental justice organizations argues that the EPA's proposed regulations for the oil and gas sector must be strengthened to protect Black, Latine, tribal, and low-income communities. The commenters detail how these groups suffer disproportionate health risks from air and water pollution, economic burdens from orphaned wells and property devaluation, and heightened climate vulnerability. They recommend specific policy enhancements, including stricter leak detection and repair (LDAR) requirements, the elimination of routine flaring, and more robust community monitoring and well-closure mandates.

The Institute for Policy Integrity critiques proposed PJM capacity market reforms, specifically the expansion of the Minimum Offer Price Rule (MOPR), arguing that penalizing resources receiving state payments for avoided emissions would reduce market efficiency and potentially increase costs for consumers.

Earthjustice and a coalition of environmental organizations oppose BSEE's proposed revisions to the 2016 Blowout Preventer Systems and Well Control Rule. They argue the proposed changes—specifically regarding drilling margins, verification organizations, blowout preventer (BOP) requirements, and real-time monitoring—increase the risk of catastrophic oil spills and worker fatalities. The authors contend that BSEE failed to provide the necessary data or quantitative risk analysis to justify these rollbacks and violated the Administrative Procedure Act, the National Environmental Policy Act, and the Endangered Species Act.

The Clean Air Task Force (CATF) critiques the Science Advisory Board's (SAB) draft review of the EPA's biogenic CO2 accounting framework, specifically opposing the use of a 100-year 'emissions horizon' for policy decisions. CATF argues that such a long timeframe is incompatible with the legal and technical capabilities of the EPA and state agencies to enforce regrowth and fossil fuel displacement assumptions. They recommend that the Biogenic Accounting Factor (BAF) be presented as a dynamic, time-dependent curve rather than a single point, allowing regulators to evaluate BAF based on specific policy contexts.

The document outlines stakeholder feedback on the California Air Resources Board's (ARB) CCS Concept Paper, arguing that CCS is critical for California's GHG goals but requires flexible, risk-based regulatory frameworks to attract investment. The authors advocate for the integration of CCS into both the Low Carbon Fuel Standard and Cap & Trade programs, express skepticism toward a 'checkbox' approach for permanence protocols, and propose a tiered, performance-based system for post-injection monitoring instead of arbitrary 50- or 100-year default periods.

The Union of Concerned Scientists (UCS) submitted a public statement to the EPA supporting the Clean Power Plan (CPP) while advocating for a mass-based emissions trading approach for states subject to a federal implementation plan. UCS argues that a mass-based system provides greater certainty for achieving emissions budgets and better integration with future carbon markets. The document provides detailed recommendations for both rate-based and mass-based models, including the expansion of eligible zero-emission resources to include distributed generation and energy efficiency. It also proposes modifications to the Clean Energy Incentive Program (CEIP) to broaden project eligibility timelines and ensure benefits reach low-income communities. Additionally, UCS emphasizes the need to protect voluntary renewable energy markets and suggests implementing interim compliance provisions to prevent emissions deficits.

A coalition of environmental organizations argues that the EPA's proposed rules for the oil and gas industry are insufficient. They demand the direct regulation of methane, the inclusion of existing sources, the elimination of exemptions for certain wells, and the regulation of hydrogen sulfide and particulate matter. The coalition also calls for more stringent toxic air pollutant limits and a more comprehensive health risk assessment for vulnerable populations.

The document argues that the expansive use of offset credits under AB 32 risks undermining the cap-and-trade system by allowing companies to avoid actual emissions reductions. The authors propose reducing the percentage of total emissions that can be met through offsets to no more than 2.5% per compliance period and implementing stricter protocol requirements to prevent 'business-as-usual' activities from being credited. They also recommend enhanced verification oversight, including performance reviews of verification bodies and measures to prevent double counting of credits across different programs.

The Centre for Environmental Rights (CER) provides detailed comments and proposed amendments to the proposed changes to the Environmental Impact Assessment (EIA) Regulations, 2014, and associated Listing Notices. The CER focuses on improving public participation, ensuring comprehensive financial provisioning for environmental rehabilitation, and opposing 'catch-all' listings for extractive industries.

EESI urges the EPA to reject proposed reductions to the 2014-2016 Renewable Fuel Standard (RFS) volumes, arguing that such cuts stifle investment in advanced and cellulosic biofuels. The document contends that the 'blend wall'—the limit of E10 ethanol in the fuel supply—is a result of oil industry restrictions rather than a lack of fuel supply. EESI proposes several solutions, including holding oil refineries accountable for infrastructure, approving mid-level ethanol blends (E25-E40) to reduce greenhouse gases and toxic aromatics, and restoring credits for FlexFuel Vehicles (FFVs). It further argues that the EPA's MOVES 2014 emissions model is flawed and that the agency should use the Clean Air Act to regulate toxic gasoline aromatics (BTEX) by promoting ethanol as a cleaner octane booster.