Transparency. Accountability.
Fairness. Scientific Integrity.

These are our goals when it comes to government regulation and the rulemaking process. From Internet governance and healthcare, to financing and the workplace, to electricity generation and oil and gas production – excessive regulation is choking small businesses. Entrepreneurship, new business creation and job growth are suffering. The archaic and broken regulatory system needs reform. Everyone impacted by regulation needs a voice in the process, not just special interests. The lack of transparency and openness is also at the core of one of the most controversial rulemakings today: proposed revisions to ozone regulations, which the EPA is scheduled to update in 2015.

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Our Mission

The Center for Regulatory Solutions will educate the American public about the burdens and consequences of over-regulation on the economy. We will also seek to improve the rulemaking process, so that small business owners and those impacted by regulations are treated fairly. Small business owners and entrepreneurs must have a voice to ensure their needs and concerns are heard, and acted upon. This will be an essential part of our mission, because all too often, rulemakings are manipulated by certain special interests, and as a result, sound science and the rule of law give way to politics and ideology. It will be the Center’s job to expose this tendency, and make the rulemaking process more open and transparent. With your help, we will ensure regulators are held accountable for their decisions.

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CRS Welcomes Nomination of Three State Air Regulators to CASAC

Washington D.C. – Karen Kerrigan, President of the Small Business and Entrepreneurship Council on behalf of the Center for Regulatory Solutions (CRS), today welcomed the nominations of three state air regulators to the Environmental Protection Agency’s (EPA) Clean Air Scientific Advisory Committee (CASAC). CASAC is a chartered Federal Advisory Committee, established pursuant to the Clean Air Act (CAA), to provide advice, information, and recommendations to the Administrator on the scientific and technical aspects of air quality criteria and National Ambient Air Quality Standards (NAAQS) for ozone and other pollutants.

The nomination of Mr. Craig Butler of the Ohio EPA, Dr. Michael Honeycutt of the Texas Commission on Environmental Quality, and Dr. Jim Boylan of the Georgia Department of Natural resources is an opportunity for EPA to improve state-level representation on this important committee.

“The EPA has an opportunity to select the next CASAC member from among these excellent candidates,” said Kerrigan. “Each has extensive public sector experience and can bring an important state and regional perspective to CASAC that the panel is currently missing. This perspective is vital in ensuring balanced feedback and input, which can ultimately lead to a more informed recommendation conveyed to EPA.  ”

These nominations come at a time of when Congressional leaders, the EPA Inspector General and the Governmental Accountability Office (GAO), have all raised concerns about the lack of transparency, public input, and geographic diversity on the advisory committee.  For example, in February, Sen. Jim Inhofe (R-OK), Chairman of the Senate Committee on Environment and Public Works, admonished EPA for “cherry picking the same allies” to serve on its committees “at the expense of having an open and robust process for selecting external advisors.”

Under the Clean Air Act (CAA) the CASAC panel is required to have at least one representative from a state pollution control agency, a position that is currently held by a representative from the Northeast States for Coordinated Air Use Management (NESCAUM), which is already on the record supporting stricter ozone standards.  However, the states that face higher implementation burdens due to their geographies, economic activities, or their naturally-occurring background ozone levels are not currently represented on CASAC.

Now that EPA has received the nominations, a list of candidates will be posted on the SAB website  for 21 days for public comment. EPA will then make its selection from the nominees.  Throughout the selection process CRS will be a strong supporter of these qualified state regulators.

Calls to diversify CASAC have been growing, as exemplified by the Association of Air Pollution Control Agencies (AAPCA) survey of state regulators, which found that 69 percent of survey respondents disagreed that CASAC is “fairly balanced in terms of the points of view represented and the functions performed by the advisory committee.”  Further, 65 percent of respondents believed CASAC and its subpanels were unbalanced in its geographic representation.

CRS has joined these calls for greater state representation and transparency in the CASAC and filed a Freedom of Information Act (FOIA) request in April for public records and communications regarding the process for selecting new members for CASAC.

About the Nominees: 

Craig Butler is the Director of the Ohio EPA and has been a public servant for over 24 years.  Mr. Butler previously served as Chief of Ohio EPA’s Central District Office and Southeast District Office.  He is also a member of the Dangerous Wild Animal Board and a past member of the Board of Directors for the Ohio Alliance for the Environment.  Mr. Butler graduated from Mansfield University in Pennsylvania with honors with a BA in Geography and Environmental Science and from Ohio University with a Master’s in Environmental Science.

Dr. Michael Honeycutt is the Director of the Toxicology Division of the Texas Commission on Environmental Quality (TCEQ), where he has been employed for two decades.  His responsibilities include overseeing health effects reviews of air permit applications and reviewing the results of ambient air monitoring projects.   Dr. Honeycutt has also served as an expert witness in public and state legislative hearings, public meetings and has testified before the House of Representatives to discuss the importance of considering naturally-occurring background ozone levels before EPA set the new ozone standard.  EPA’s (and CASAC’s) failure to fully understand the effect of background ozone prior to issuing its new standard has since been recognized as a serious limitation of the new regulation.

Dr. Jim Boylan has extensive experience in implementing the EPA-mandated ozone standard.  He is currently the Program Manager of Georgia Department of Natural Resources’ Air Protection Branch, which protects Georgia’s air quality by monitoring ambient levels of air pollutants throughout the State.

About CRS

The Center for Regulatory Solutions is a project of the Small Business and Entrepreneurship Council, a 501c(4) advocacy, research, education and networking organization dedicated to protecting small business and promoting entrepreneurship. For twenty-three years, SBE Council has worked to educate elected officials, policymakers, business leaders and the public about policies that enable business start-up and growth.

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