Feb 23, 2023 2023 IPAA Comments on HAPS Consent Decree
On February 23, IPAA submitted comments on the Proposed Hazardous Air Pollutants Consent Decree, Clean Air Act Citizen Suit Docket ID No. EPA-HQ-OGC-2023-0028.
Dear Administrator Regan:
The following Comments on the proposed consent decree referenced above (“Proposed CD”) are submitted on behalf of the Independent Petroleum Association of America (“IPAA”). IPAA has been actively involved in the rulemaking process for the new source performance standards (“NSPS”) and national emissions standards for hazardous air pollutants (“NESHAP”) as originally proposed on August 23, 2011. IPAA supported the effort to bifurcate the proposed NSPS rule and the proposed NESHAP rule which was ultimately granted by the U.S. Court of Appeals for the District of Columbia in American Petroleum Institute v. EPA, No. 121405. Said decision held the NESHAP rulemaking in abeyance and required EPA to provide the court and parties periodic updates which IPAA has received. The Proposed CD is a function of the typical “sue and settle” approach taken by many environmental organizations. …