NM079 New Mexico Albuquerque/Bernalillo County and New Mexico State Certification of State Implementation Plans addressing the Federal Clean Air Act Section 110(a)(2)(D)(i)(I), the “Good Neighbor” provision, for the 2008 Ozone National Ambient Air Quality Standard (NAAQS)

Dear Ms. Fuerst: Please find attached the report of Ranajit Sahu on EPA-R06-OAR-2018-0705. As detailed in Dr. Sahu's report, the emissions assumptions in EPA's proposal fail to account for the massive expansion of oil and gas production and flaring in the Permian Basin area of New Mexico. The Sierra Club incorporates Dr. Sahu's report and respectfully requests that EPA rescind its proposed approval and conduct an accurate assessment of current emissions in the Permian Basin. Thank you and please contact me if there are questions or concerns with this submission. Sincerely, Pat Gallagher Legal Director Sierra Club Environmental Law Program 2101 Webster St. Suite 1300 Oakland, CA 94612

CORRECTION TO EARLIER COMMENTS Dear Ms. Fuerst: Please find attached the report of Ranajit Sahu on EPA-R06-OAR-2018-0705. As detailed in Dr. Sahu's report, the emissions assumptions in EPA's proposal fail to account for the massive expansion of oil and gas production and flaring in the Permian Basin area of New Mexico. The Sierra Club and the Center for Biological Diversity incorporate Dr. Sahu's report and respectfully request that EPA rescind its proposed approval and conduct an accurate assessment of current emissions in the Permian Basin. Thank you and please contact me if there are questions or concerns with this submission. Sincerely, Pat Gallagher Legal Director Sierra Club Environmental Law Program 2101 Webster St. Suite 1300 Oakland, CA 94612