INGAA recommends that the EPA retain the current 75 part per billion (ppb) ozone NAAQS rather than pursue a more stringent standard.
In addressing its concerns, INGAA raises the following specific issues: (1) ambient ozone levels are declining and likely will continue to decrease in the coming years; (2) there is significant uncertainty in both the health benefits and implementation costs (3) EPA’s analysis is based on the use of “unknown” controls; and (3) if the EPA chooses to adopt lower NAAQS, INGAA supports the proposed grandfathering provisions for Prevention of Significant Deterioration (PSD) permitting.
Related
Natural Gas & Power Industries’ Reliability Alliance:
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
