OIAI Repeal Comments

In brief, three main issues:

  • The language of sections 113 and 304 unambiguously requires federal enforceability for provisions that limit “potential to emit considering controls.”
  • EPA’s “plain language” argument for repeal is simple misdirection.
  • Contrary to Congressional intent, EPA has impermissibly drained “considering controls” of any meaning. The best reading of the statute is, roughly, that Congress meant control equipment.

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