Introduction The NAAQS Regulatory Review & Rulemaking (“NR3”) Coalition presents these comments on the Environmental Protection Agency’s (“EPA” or the “Agency”) proposed “Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 8-Hour Ozone NAAQS” ("Proposed Rule"). [1] The Proposed Rule addresses emissions under Clean Air Act ("Act") § 110 (a)(2)(D)(i)(I) (the “Good Neighbor Provision”) from upwind sources that EPA has determined significantly contributes to nonattainment or interference with maintenance of the 2015 ozone national ambient air quality standards (“NAAQS”).
Members of the NR3 Coalition and their member companies are committed to reducing emissions, as necessary and consistent with the requirements of the Act, to provide air quality protective of public health and welfare, while continuing to facilitate economic growth in the United States. Our industries have worked for many decades with EPA, states, and local authorities to lower concentrations of ozone, its precursors, and other common pollutants in ambient air. As a result, between 1970 and 2020, emissions of criteria air pollutants have steadily declined, while both U.S. gross domestic product and population have grown by over 270% and 60% respectfully. [2]