Due to unclear terms and requirements that were newly adopted by EPA in the final rule, AGA utility members are unable to determine with assurance how to comply with the Subpart W rule. This lack of clarity will likely result in the submittal of conflicting and unreliable emissions data and, thereby, undermine the purposes of Subpart W. AGA and its members did not have an opportunity to submit comments on these issues during the comment period on the proposed rule, because the new terms and requirements were not included in the proposed rule. AGA believes these problems can be resolved if EPA allows an opportunity for AGA to provide its comments and proposed solutions to EPA. AGA is therefore petitioning for EPA’s reconsideration of the Subpart W final rule.
The cover letter and petition are posted under Environmental Comments and can be accessed by clicking here.