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.

The images are all from the EPA’s “Documerica” project, a 1970’s program to send photographers across the U.S. to “record the state of the environment.” All images are courtesy of the National Archives and Records Administration and are in the public domain. The most convenient way to access the images is through the Flickr website….

Here it is: It has grass, sky, and an air pollution control device of about 95% control efficiency. Kind of crude, no doubt, but so is EPA’s. Let us know what you think!