Comment submitted by David S. Baron, Attorney, EarthJustice, on behalf of the Natural Resources Defense Council (NRDC)

Notice of correction: The following sentence appears on page 5 of our comments submitted today: EPA’s proposed rule merely requires that emissions from the “outside” area “contribute to” PM2.5 concentrations in the nonattainment area – it does not require the PM2.5 benefits from cutting those outside emissions to be at least equivalent to those achievable by reductions inside the nonattainment area. The sentence should read: EPA’s proposed rule merely requires that emissions from the “outside” area “contribute to” ozone concentrations in the nonattainment area – it does not require the ozone benefits from cutting those outside emissions to be at least equivalent to those achievable by reductions inside the nonattainment area.