Hana Vizcarra

Hana Vizcarra, a staff attorney at the Harvard Law School Environmental & Energy Law Program, said a final rule can differ from the proposed version within reason, but in this case, BSEE is incorporating a specific, technical document without previously mentioning it.

“I would not expect them to incorporate something as technical as this without providing an opportunity to comment on this specific standard,” said Hana Vizcarra, a staff attorney at Harvard Law School’s Environmental & Energy Law Program.

“They can’t circumvent the Clean Water Act and its requirements,” said Hana Vizcarra, an attorney at Harvard Law School’s environment and energy program. “This is going to be a long process.”