Comments on Imperial County Ozone Plan and Petition for Review

Submitted December 2, 2019. Two issues raised: State must fund a position for border pollution EPA failed to give any meaning to the maintenance requirement in section 179B(a). On April 27, 2020, the Center for Biological Diversity and the Center for Environmental Health filed a petition for review in the Ninth Circuit Court of Appeals…

Comments on Chicago Ozone Plan

Comments filed May 27, 2020. Issues raised: RFP cannot be approved when plan doesn’t demonstrate attainment NOx substitutions for VOCs are not adequately justified Invalid contingency measures Motor vehicle emission budgets cannot be approved because RFP cannot be approved