Comment letters submitted by UCLA Emmett Institute faculty addressing environmental law and policy issues. 

 

Letter to County of Los Angeles on Phase-out of Oil and Gas Production

July 19, 2021 | Sean Hecht, Beth Kent

On July 19, 2021, Sean Hecht, Co-Director of the Frank G. Wells Environmental Law Clinic, and Beth Kent, Emmett/Frankel Fellow of the Frank G. Wells Environmental Law Clinic, submitted a comment letter to the County of Los Angeles’s Office of the County Counsel to express support for updating the County’s 40-year-old oil and gas production codes to include stronger protections for public health and the environment. The letter was submitted on behalf of the Los Angeles Neighborhood Land Trust. The letter urges the County to prohibit new drilling and phase out existing oil and gas operations in areas within the County’s land-use authority. View publication page. Download PDF. 

 

Letter on Potential Phase-Out of Oil and Gas Production Operations at the Inglewood Oil Field

July 19, 2021 | Cara Horowitz 

On July 19, 2021, Cara Horowitz, Co-Director of the Frank G. Wells Environmental Law Clinic, wrote to staff of the Los Angeles County Board of Supervisors to share information relevant to the potential phase-out of oil and gas production activities in the Inglewood Oil Field, the largest urban oil field in the U.S., and to provide an assessment of how to accomplish such a phase-out. The letter was researched and drafted by Clinic students Madison Dipman ‘22 and Reilly Nelson ‘22 and was submitted on behalf of Clinic client the Natural Resources Defense Council. View Publication Page. Download PDF.

 

Comment Letter Supporting EPA’s Corporate Average Fuel Economy Preemption Rule

June 10, 2021

On June 10, 2021, ten Emmett Institute faculty members submitted comments to EPA supporting the Corporate Average Fuel Economy Preemption rule, which would repeal the Safer Affordable Fuel-Efficient Vehicles Rule Part One: One National Program rule (2019 Rule). The comment letter argues the 2019 Rule contravened Congress’ intent in enacting the Energy Policy and Conservation Act and its subsequent amendments, relied on dubious legal authority to adopt a preemption determination, and failed to adhere to bedrock principles of administrative procedure. The comment letter supports repealing the 2019 Rule in its entirety. View Publication Page. Download PDF. 

Comment Letter on EPA Review of the Ozone National Ambient Air Quality Standards

October 1, 2020 | Sean Hecht, Siyi Shen

On October 1, 2020, 40 legal scholars submitted a comment letter to the U.S. Environmental Protection Agency to express their serious concerns with the Trump Administration EPA's proposed revision to air quality standards for ozone, the primary component of smog. The letter, authored by the UCLA Law Emmett Institute's Sean Hecht and Siyi Shen, argues that the composition and role of EPA’s Clean Air Scientific Advisory Committee render the proposed action legally deficient, and will result in National Ambient Air Quality Standards that contravenes Congress’s will. View publication page. Download PDF.

 

Comment Letter on Proposed Solar Geoengineering Experiment at Harvard

July 31, 2020 | Adrien Abecassis, Charles Corbett, Benjamin Harris, Edward Parson, Jesse Reynolds

On July 31, 2020, UCLA Law faculty members Adrien Abecassis, Charles R. Corbett, Benjamin Harris, Edward A. Parson, and Jesse L. Reynolds submitted a comment letter to an independent advisory committee for a proposed Harvard solar geoengineering experiment. The comment letter praises the experiment’s governance framework as a whole and suggests ideas for creating a meaningful, appropriate public engagement process. View publication page. Download PDF.

 

Comment Letter for 100 Legal Scholars on EPA Supplemental Notice of Proposed Rulemaking—Strengthening Transparency in Regulatory Science

May 18, 2020 | Sean Hecht, Julia Stein

On May 18, 2020, Emmett Institute supervising attorney and project director Julia Stein and co-executive director Sean Hecht filed a comment letter to EPA on behalf of 100 U.S. law professors urging the agency to withdraw its revamped “Transparency in Science” rule. View publication page. Download PDF.

 

Letter to City of Los Angeles on Public Participation in City Planning Process During COVID-19 Restrictions

March 23, 2020 | Sean Hecht

On March 23, 2020, Sean Hecht, Co-Director of the Frank G. Wells Environmental Law Clinic, wrote to Los Angeles city leaders to request that the city take immediate action to address the impact of COVID-19 and the city and state “Safer At Home” orders on public participation in planning processes in the city. Hecht recommends that any public comment periods be extended, and new public review documents such as draft and final environmental impact reports not be released, until at least an additional 45 days after city business resumes as usual. View publication page. Download PDF.

 

Comment Letter on Oil and Gas Buffer in City of Los Angeles

December 17, 2019 | Sean Hecht, Benjamin Harris

On December 17, 2019, Sean Hecht and Benjamin Harris of the Frank G. Wells Environmental Law Clinic submitted comments on behalf of the Los Angeles Neighborhood Land Trust to the Los Angeles City Attorney, conveying support for an ordinance establishing a health and safety buffer around oil and gas operations in the City of Los Angeles. View publication page. Download PDF.

 

Comment Letter Opposing EPA Proposal to Weaken Methane Rule

November 29, 2019 | Sean Hecht, Harjot Kaur

On November 25, 2019, Emmett Institute faculty members Sean Hecht and Harjot Kaur submitted a comment letter to the Environmental Protection Agency in response to the Proposed Policy Amendments 2012 and 2016 New Source Performance Standards for the Oil and Natural Gas Industry (the "Proposed Rule"). View publication page. Download PDF.

 

Comment Letter to CARB on Proposed Updated Tropical Forest Standard

August 29, 2019 | William Boyd, Ann Carlson, James Salzman, Harjot Kaur, and Cara Horowitz

On August 29, 2019, Emmett Institute faculty members William Boyd, Ann Carlson, James Salzman, Harjot Kaur, Cara Horowitz submitted a comment letter to California Air Resources Board in support of the proposed Updated Tropical Forest Standard. In a previous letter commenting on the original proposed Standard, the authors concluded that approving this Standard presents an opportunity for CARB (and California) to help lead the global fight against tropical deforestation. View publication page. Download PDF.

 

Comment Letter Opposing Pebble Mine’s Draft Environmental Impact Statement

July 1, 2019 | Michael Burger, Cara Horowitz, Nathaniel Logar

In a comment letter submitted to the U.S. Army Corps of Engineers on July 1, 2019, Cara Horowitz, Co-Executive Director of the Emmett Institute and Nathaniel Logar, Emmett/Frankel Fellow at the Emmett Institute join Michael Burger, Executive Director of the Sabin Center for Climate Change Law at Columbia Law School to critique the recent Draft Environmental Impact Statement (“DEIS”) for the Pebble Limited Partnership’s proposal to develop the deposit as an open pit mine. View publication page. Download PDF.

 

Comment Letter Opposing Federal Proposal to Narrow Reach of Lightbulb Efficiency Standards

May 3, 2019 | Julia Stein, Cara Horowitz, Harjot Kaur

Emmett Institute faculty members submitted a comment letter on the U.S. Department of Energy’s Notice of Proposed Rulemaking on Energy Conservation Standards for General Service Lamps. The authors argue that the Department of Energy’s efforts to narrow the reach of lightbulb efficiency standards would sacrifice consumer savings and environmental protection in a misguided attempt to thwart application of energy efficiency standards the market has already embraced, all in direct contravention of legislative mandates pursuant to the Energy Policy and Conservation Act. View publication page. Download PDF.

 

Comment Letter from Electricity Grid Experts on EPA’s Affordable Clean Energy (ACE) Rule Proposal

March 18, 2019 | Cara Horowitz, Ann Carlson, William Boyd, Nathaniel Logar

On October 23, 2015, EPA finalized emission standards for new coal-fired power plants under Section 111(b) of the Clean Air. The rule was intended to achieve reductions in pollution by setting emissions standards based on the level of emissions achievable by the best system of emission reduction. In late 2018, EPA proposed amendments that would weaken the 2015 Rule significantly. On March 18, 2019, a group of Emmett Institute faculty submitted a comment letter on behalf of experts in the operations of the U.S. electricity grid, opposing EPA’s proposal to weaken these pollution standards. They argue that the EPA’s proposed weakening is not justified by the record and would not, as EPA claims, improve grid reliability. View publication page. Download PDF.

 

Comment Letter from Technological Innovation Experts on EPA's Affordable Clean Energy (ACE) Rule Proposal

March 18, 2019 | Sean Hecht

On March 18, 2019, Sean Hecht submitted a comment letter on behalf of experts in technology innovation, diffusion, and pollution control, arguing that EPA’s proposal to weaken pollution standards for new and modified coal-fired power plants violates federal law, and the prior standard, adopted by the agency in 2015, is the proper one. View publication page. Download PDF.

 

Comment Letter Opposing EPA’s Proposed Affordable Clean Energy (ACE) Rule

October 31, 2018 | Cara Horowitz, Ann Carlson, William Boyd, Nathaniel Logar

On October 29, 2018, Emmett Institute faculty submitted a comment letter with and on behalf of a group of nationally renowned experts on the operations of the U.S. electric grids, in response to the recent proposal by the U.S. Environmental Protection Agency to promulgate the Affordable Clean Energy (ACE) Rule in place of the Clean Power Plan (CPP). The authors write in firm opposition to EPA’s ACE proposal. View publication page. Download PDF.

 

Comment Letter Supporting CARB’s Proposed Tropical Forest Standard

October 29, 2018 | Cara Horowitz, Ann Carlson, Harjot Kaur

On October 29, 2018, Emmett Institute faculty submitted a comment letter in support of California Air Resources Board’s proposed Tropical Forest Standard. The authors conclude that approving the standard presents an opportunity for CARB to lead the world in tropical forest protection and conservation. View publication page. Download PDF.

 

Comment Letter on EPA and NHTSA Proposed Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule

October 25, 2018 | Julia Stein, Ann Carlson, Cara Horowitz, Sean Hecht, Meredith Hankins

On October 25, 2018, Emmett Institute faculty members Julia Stein, Ann Carlson, Cara Horowitz, Sean Hecht, and Meredith Hankins submitted comments on the proposed Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2012-2026 Passenger Cars and Light Trucks. View publication page. Download PDF.

 

Comment Letter on EPA Proposed Rule on Science in Regulatory Process

August 30, 2018 | Julia Stein, Sean Hecht

On behalf of 68 environmental and administrative law professors affiliated with 47 universities around the country, UCLA Emmett Institute faculty members Sean Hecht and Julia Stein filed a comment letter urging EPA's Acting Administrator Andrew Wheeler to withdraw the "Strengthening Transparency in Science" proposed rule. View publication page. Download PDF.

 

Comment Letter Supporting California’s Vehicle Emissions Program

May 31, 2018 | Meredith Hankins, Ann Carlson, Cara Horowitz, Sean Hecht

On May 31, 2018, Ann Carlson, Cara Horowitz, Sean Hecht and Meredith Hankins of UCLA Law School's Emmett Institute on Climate Change and the Environment submitted a comment letter to the California Air Resources Board in response to their request for public input on possible amendments to the state's greenhouse gas vehicle emission regulations. The comment letter supports action by CARB to maintain the current stringency of California's vehicle emission program in the face of attempted weakening at the federal level. View publication page. Download PDF.

 

Comment Letter for Grid Experts Opposing Repeal of Clean Power Plan

April 25, 2018 | Cara Horowitz, Ann Carlson, William Boyd, Nathaniel Logar

On April 25, 2018, Cara Horowitz, Nat Logar, & Ann Carlson of UCLA Law School’s Emmett Institute on Climate Change and the Environment, together with William Boyd of University of Colorado Law School, submitted a comment letter to the U.S. Environmental Protection Agency with and on behalf of five electric grid experts: Benjamin F. Hobbs, Brendan Kirby, Kenneth J. Lutz, James D. McCalley, and Brian Parsons. The comment letter opposes EPA’s proposal to repeal the Clean Power Plan to regulate carbon dioxide emissions from existing fossil-fuel-fired electric generating units. View publication page. Download PDF.