I support the EPA's proposed action. However I would like the EPA to explain why it took over 2 years for this determination to be made. When combined with the NJDEP's review period (during which EPA also provided comments), it will be over 5 years from the time of initial application to a final decision from regulatory authorities. The alternative limit is requested for obviously compelling and sound technical reasons, as required by the regulation, and the annual emission rate requested is less than what is available via a "general permit" (which can be obtained online in a matter of minutes). The proposed change represented a decrease in allowable NOx emissions of over 10 tons/year. To put it plainly, this was a no-brainer. EPA had already provided input on the permit conditions and nothing in the proposed rule or docket (as of this comment) indicates EPA took any action or requested any additional information during the 2-year review period after the submission was considered administratively and technically complete. These delays do not further any regulatory goals and are periods of extreme uncertainty for regulated entities. Whenever possible, entities will continue to seek alternative jurisdictions for their operations if these problems are not solved.
Kevin Morris
Philadelphia, PA
Comment on FR Doc # 2011-19798
This is comment on Proposed Rule
Approvals and Promulgations of Implementation Plans: Reasonably Available Control Technology for Oxides of Nitrogen for Specific Source in State of New Jersey
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Related Comments
Public Submission Posted: 08/11/2011 ID: EPA-R02-OAR-2011-0499-0007
Sep 06,2011 11:59 PM ET