Submitted January 21, 2020. One issue: The rationale for proposing approval of the contingency measures is an attempt to circumvent the Ninth Circuit’s Bahr decision.

Submitted February 18, 2020. The comments raise two main issues: The substitution of nitrogen oxides (NOx) reductions for volatile organic compounds (VOC) reductions has no technical or legal basis. Conditional approval of the contingency measures is contrary to section 110(k)(4) and an attempt to circumvent the Ninth Circuit’s Bahr decision.

Submitted March 5, 2020. The comments raise two issues: The rule does not clearly require use of a VOC control device for all VOC emissions; The rule has inadequate monitoring, recordkeeping, and reporting (MRR).

Submitted April 6, 2020. Pennsylvania is in the Ozone Transport Region (OTR). EPA proposed to approve Pennsylvania’s submittal to address reasonably available control technology (RACT) for source categories covered by a Control Techniques Guideline (CTG). The comment letter makes two arguments: Generally, the submittal relied on the recommendations in the CTG without apparent analysis to…