Attached is testimony provided by Surbhi Sarang, Senior Attorney, Environmental Defense Fund, at July 22, 2026 public hearing.
Minor New Source Review (NSR) Air Permitting Program Public Participation Requirements for State Implementation Plans
Activity
Environmental Defense Fund filed 6 comments on this docket between Aug 4, 2026 and Aug 18, 2026. 35 other organizations filed here. The comment window closed 76d ago.
What Environmental Defense Fund filed (6)
Attached is a request from Environmental Defense Fund that EPA make available all 2022–2023 Minor NSR Public Participation Outreach records and extend the comment deadline accordingly.
Attached please find Attachment 5 to the Environmental Defense Fund public outreach minor NSR Comments originally submitted to EPA in December 2022 and refiled with EPA for consideration in this rulemaking proceeding.
Attached please find Attachments 1 through 4 of the Environmental Defense Fund public outreach minor NSR Comments originally submitted to EPA in December 2022 and refiled with EPA for consideration in this rulemaking proceeding.
Attached are comments filed with EPA by Environmental Defense Fund as part of EPA's 2022-2023 outreach on minor NSR. Though EPA states that it "considered the resulting information [from the outreach sessions] to determine how to address the regulatory framework" in its proposal, "Minor New Source Review Air Permitting Public Participation Requirements for State Implementation Plans," 91 Fed. Reg. 41,491 (July 7, 2026), EPA did not place EDF's comments in the rulemaking docket or mention them in its proposal. Accordingly, I am resubmitting these comments for inclusion in the record of this rulemaking proceeding for EPA's consideration. These comments demonstrate that public participation is directly relevant to the success of the minor NSR program in protecting ambient air quality and preventing violations of the National Ambient Air Quality Standards. Accordingly, EPA should not finalize its proposal, but should instead strengthen public participation in the program and also make the other improvements advocated for in the attached EDF comments. The attachments to those comments will be filed separately.
Attached please find Attachments 6 and 7 to the Environmental Defense Fund public outreach minor NSR Comments originally submitted to EPA in December 2022 and refiled with EPA for consideration in this rulemaking proceeding.
Abstract
This action pertains to the EPA’s federal rules for SIPs at 40 CFR part 51.160-164, which apply to the preconstruction permitting programs of state and local air pollution agencies. The purpose of this rulemaking is to address minimum requirements for public participation in the administration of minor source NSR programs.
View on regulations.gov →Co-filers (35)
See everyone who commented →- Environmental Defense FundTHIS ORG6 filings · confidence 97%
- Southern Environmental Law Center (SELC)11 filings · confidence 97%
- Air Alliance Houstontrade assoc.2 filings · confidence 85%
- American Forest & Paper Associationtrade assoc.1 filing · confidence 97%
- American Lung Associationtrade assoc.1 filing · confidence 85%
- American Petroleum Institutetrade assoc.1 filing · confidence 97%
- Anthropocene Alliancetrade assoc.1 filing · confidence 85%
- Coalition of 193 environmentaltrade assoc.1 filing · confidence 85%
- Coastal Watch Associationtrade assoc.1 filing · confidence 85%
- Dogwood Alliancetrade assoc.1 filing · confidence 85%
- Environmental and Climate Justice Committee of Staten Island NAACP Branchtrade assoc.1 filing · confidence 85%
- Environmental Protection Network (EPN)trade assoc.1 filing · confidence 97%
- GPA Midstream Associationtrade assoc.1 filing · confidence 97%
- Healthy Environment Alliance of Utahtrade assoc.1 filing · confidence 85%
- LinkMind Foundationtrade assoc.1 filing · confidence 85%
- Manufacturers of Emission Controls Associationtrade assoc.1 filing · confidence 85%
- NAACP NYS Environmental and Climate Justice Committeetrade assoc.1 filing · confidence 85%
- National Asphalt Pavement Associationtrade assoc.1 filing · confidence 85%
- National Association for the Advancement of Colored Peopletrade assoc.1 filing · confidence 85%
- National Association for the Advancement of Colored People (NAACP) Chicago Southside Branchtrade assoc.1 filing · confidence 85%
- National Coalition Against Cryptominingtrade assoc.1 filing · confidence 85%
- National Religious Partnership for the Environmenttrade assoc.1 filing · confidence 85%
- Natural Resources Defense Council (NRDC)trade assoc.1 filing · confidence 97%
- New Jersey Envriomental Justice Alliancetrade assoc.1 filing · confidence 85%
- North American Insulation Manufacturers Associationtrade assoc.1 filing · confidence 85%
- Powder River Basin Resource Counciltrade assoc.1 filing · confidence 85%
- Texas Health and Environment Alliancetrade assoc.1 filing · confidence 85%
- Texas Press Associationtrade assoc.1 filing · confidence 85%
- The Clean Air Coalition of Western New Yorktrade assoc.1 filing · confidence 85%
- The Petroleum Alliance of Oklahomatrade assoc.1 filing · confidence 85%
- The Wei LLCunverified attribution1 filing · confidence 70%
- Utah Petroleum Associationtrade assoc.1 filing · confidence 85%
- West Berkeley Alliance for Clean Air and Safe Jobstrade assoc.1 filing · confidence 85%
- West End Revitalization Associationtrade assoc.1 filing · confidence 85%
- Western Energy Alliancetrade assoc.1 filing · confidence 85%
- Yukon River Inter-Tribal Watershed Counciltrade assoc.1 filing · confidence 85%