As a concerned citizen, I believe the EPA should adopt the "potential emissions
trigger." The potential emissions trigger is clearer as to the requirements of when
the circumstances under which a change must be considered to have a
reasonable possibility of significiantly increasing emissions. It lays out the
requirements in a much clearer way than the percentage increase trigger.
I think it is also important to require more projects to require recordkeeping and
reporting under the reasonable possibility standard. The "percentage increase
trigger" would allow more sources of emissions to avoid the reasonoable
possibility standard recordkeepeing and reporting requirements. I do not feel the
records a source owner currently keep will suffice in the requirements of predicting
any potential emissions a source can potentially produce. The EPA should
require more projects to comply with their recordkeeping standards so that
projects are held accountable for any emissions they produce.
Should the percentage increase trigger option be adopted, the percentage of
increase that would trigger the recordkeeping requirement should be as strict as
possible in order to avoid the prevention of significant deterioration.
Comment submitted by M. Weniger
This is comment on Proposed Rule
Prevention of Significant Deterioration (PSD) and Nonattainment New Source Review (NSR): Reasonable Possibility in Recordkeeping
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