Western Governors request that the Environmental Protection Agency (EPA) recognize states as sovereignties, with reserved powers under the U.S. Constitution, and direct agency officials to conduct early and substantive consultation with states when developing guidance documents that affect states as sovereignties or as co-regulators. “We urge EPA to revise the proposed rule to expressly distinguish states and state officials from the general public and to provide states with opportunities to engage with EPA officials, on a government-to-government basis, beyond the public comment process,” asserts the letter of June 19, 2020 sent to EPA Administrator Andrew Wheeler and signed by WGA Chair North Dakota Gov. Doug Burgum and Vice Chair Oregon Gov. Kate Brown. The Governors’ comments were in response to the proposed rule, EPA Guidance: Administrative Procedures for Issuance and Public Petitions. Read, download letter