O&G NSPS Comments

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 mean what it said.

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