Letter Mar 1, 2012

Comments on Cross State Air Pollution Rule

BART Comments (829 KB)

On behalf of the National Parks Conservation Association, Sierra Club, Altahama Riverkeeper, Appalachian Mountain Club, Environmental Law & Policy Center, Fall-line Alliance for a Clean Environment, Friends of the Chattahoochee, GreenLaw, Midwest Environmental Defense Center, Minnesota Center for Environmental Advocacy, Natural Resources Defense Council, Ogeechee Riverkeeper, Respiratory Health Association of Metropolitan Chicago, Southern Alliance for Clean Energy, Southern Environmental Law Center, and Wiregrass Energy Network,

we submit these comments on the Environmental Protection Agency’s recent proposal (1) to exempt states subject to the Cross-State Air Pollution Rule (“CSAPR” or the “Transport Rule”) from applying source-specific Best Available Retrofit Technology (“BART”) requirements under the Clean Air Act’s regional haze program; and (2) to disapprove in part the regional haze State Implementation Plans (“SIPs”) submitted by Alabama, Florida, Georgia, Indiana, Iowa, Louisiana, Michigan, Mississippi, Missouri, North Carolina, Ohio, Pennsylvania, South Carolina, and Texas to the extent those SIPs relied on CAIR, and adopt Federal Implementation Plans (“FIPs”) for those states, replacing reliance on CAIR with CSAPR.

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