Coalition Comments on EPA's Proposed Revised Cross-State Air Pollution Rule Update for the 2008 Ozone NAAQS

The American Fuel & Petrochemical Manufacturers, American Petroleum Institute, Portland Cement Association, American Chemistry Council, and United States Chamber of Commerce (the “Associations”) respectfully submit these comments on EPA’s proposed Revised Cross-State Air Pollution Rule Update for the 2008 Ozone National Ambient Air Quality Standard (“NAAQS”) established under the federal Clean Air Act (“CAA” or “Act”). 85 Fed. Reg. 68,964 (Oct. 30, 2020) (“Proposed Rule”).

The Associations’ members include owners and operators of refining, chemical manufacturing, cement manufacturing and other industrial facilities that have sources that are considered for regulation in the Proposed Rule. These facilities already control emissions as required by existing federal and state law, and thus have already made substantial emissions reductions under CAA regulations and associated state implementation plans (“SIPs”) issued under the Act, as well as through other mechanisms. The Associations’ members would incur significant additional costs were EPA to require additional emissions controls under the Proposed Rule.