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EPARulemakingEPA-HQ-OAR-2011-0354

Protection of Stratospheric Ozone: Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export

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Natural Resources Defense Council (NRDC) filings
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Activity

Natural Resources Defense Council (NRDC) filed 1 comment on this docket between Feb 6, 2012 and Feb 6, 2012. 17 other organizations filed here. The comment window closed 5289d ago.

What Natural Resources Defense Council (NRDC) filed (1)

Feb 6, 2012· Comment submitted by David Doniger, Policy Director, Climate and Clean Air Program, Natural Resources Defense Council (NRDC)· EPA-HQ-OAR-2011-0354-0067

Attached are comments on behalf of the Natural Resources Defense Council, Institute for Governance & Sustainable Development, and Environmental Investigation Agency

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Abstract

In 2009, EPA finalized a rule allocating HCFC allowances for the 2010-2014 control periods (74 FR 66412). One aspect of this rulemaking relating to how allowances are allocated was challenged. The D.C. Circuit Court, in Arkema v EPA, ruled in favor of the petitioners and vacated the existing allowances. Under EPA's reading of the vacature, no allowances exist once the court issues its mandate absent action by the EPA. The rulemaking featured in this docket addresses the court's vacature and would allocate HCFC-22 and HCFC-142b allowances for 2012-2014.

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Co-filers (17)

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