Comments submitted on the oil and gas NSPS rollback. The main points are: EPA exceeds its authority to use error correction and abuses its discretion. EPA’s “redundancy” theory for deregulating methane is contrary to the Act. EPA’s “significant contribution” theory falls far short of the “exceptionally high” standard needed to show that Congress did not…

EPA reopened the comment period for the proposed repeal of the OIAI policy. I took the opportunity to polish the previous comments; these supersede those.