The American Public Power Association in late June filed comments in response to a U.S. Environmental Protection Agency pre-rulemaking proceeding in which it seeks feedback from stakeholders as the agency considers revisions to EPA’s regional haze rule.
The June 28 comments reply to an EPA nonregulatory rulemaking docket, Protection of Visibility: Amendments to Requirements for State Plan Rule.
The non-regulatory docket relates to the Regional Haze Rule and its implementation through State Implementation Plans (SIPs) for the third planning period.
APPA recommends that EPA continue considering all federally enforceable actions for inclusion in regional haze planning.
In addition, APPA said that EPA should:
- Prepare additional technical approaches and information to address new and smaller sources;
- Address opportunities for controls for sources that states do not have the authority to regulate, including rail yards and locomotives, ships and ports, on-road and off-road mobile sources, wildfire management on federal lands, and international transport of air pollutants, among other sources; and
- Consider opportunities to reduce emissions generated within Class I areas that may not have been directly or thoroughly addressed.
APPA said it supports states' discretion in conducting a Regional Haze Program four-factor analysis.
It said that given their unique contexts, challenges, and opportunities in different regions, one-size-fits-all approaches for visibility protection across all states are impossible.
APPA encouraged EPA not to set new measures, standards, or requirements limiting state discretion when establishing long-term strategies and recommended that EPA outline a process, condition, or procedures for states that have essentially achieved the national goal and no longer require SIP revisions.
APPA supports the extension of the SIP submittal and progress report deadlines for the third planning period.
APPA also supports EPA working with states and the regulated community to prioritize resources to address health-based standards, which will drive most, if not all, of the reasonable progress needed to meet regional haze goals.
