The Air Stewardship Coalition appreciates the opportunity to submit these comments and the attached Ramboll Technical Memorandum in support of the U.S. Environmental Protection Agency’s proposal to deny the petition submitted by the New York Department of Environmental Conservation under Section 126 of the Clean Air Act. The Petition claims areas in the New York metropolitan area and western New York face issues with compliance with the 2008 and 2015 ozone national ambient air quality standards (NAAQS) due to interstate transport of emissions from a diverse array of 350+ upwind sources across nine states.
The Air Stewardship Coalition is an ad hoc group of trade associations and companies that seeks to assist EPA and states in addressing alleged interstate transport issues arising under the CAA. Our members include and represent energy and industrial facilities targeted by the NY
Petition. These facilities have already made substantial emissions reductions under EPA regulations and State Implementation Plans under the Act, as well as through other mechanisms.