Docket Number EPA - HQ - OAR - 2009 - 0491
Response to Comments on the Proposed Transport Rule: Federal Implementation Plans To Reduce Interstate Transport of Fine Particulate Matter and Ozone
                         (75 FR 45210; August 2, 2010)

                                  Transport Rule
                           Primary Response to Comments

                     U.S. Environmental Protection Agency
                          Office of Air and Radiation
                                   June 2011

Table of Contents
Introduction	vii
I. General Comments in Support of Rule That Don't Fit Into Specific Topic Areas	1
II. General Comments in Opposition to Rule That Don't Fit Into Specific Topic Areas	57
III. [Reserved]	66
III.A. EPA's Authority for This Action	67
III.B. What Air Quality Problems and Which NAAQS Does This Proposal Address?	171
III.C. CAIR and NOx SIP Call Rulemaking History	192
III.D. Primary Goals and Key Guiding Principles of Proposal	193
III.E. Why Does This Proposed Rule Focus on the Eastern Half of the United States/ 37-State Region Analyzed	212
III.F. Anticipated Rules Affecting Power Sector	221
III.G. Setting a Precedent for How to Determine Upwind State Responsibilities in Future Transport Rulemakings	271
IV. Defining "Significant Contribution" and "Interference With Maintenance"	274
IV.A. Choice of Baseline Used for Cost, Emissions, and Air Quality Analyses	285
IV.B. Approach to Identify Contributing Upwind States and Approach to Identify Downwind Nonattainment/Maintenance Receptors	301
IV.B.1. Choice of Covered Pollutants (SO2 and NOx for PM2.5 and Ozone Season NOx for Ozone)	305
IV.B.2. Choice of Air Quality Thresholds (1% of Relevant NAAQS) and Rounding Convention	311
IV.B.3. Identification of Downwind Nonattainment and Maintenance Receptors	337
IV.C. Air Quality Modeling Approach and Results	384
IV.C.1. What Air Quality Modeling Platform Did EPA Use?	388
IV.C.2. How Did EPA Project Future Nonattainment and Maintenance for Annual PM2.5, 24-Hour PM2.5, and 8-Hour Ozone?	409
IV.C.3. How Did EPA Assess Interstate Contributions to Nonattainment and Maintenance?	420
IV.C.4. What Are Estimated Interstate Contributions to Annual PM2.5, 24-Hour PM2.5, and 8-Hour Ozone Nonattainment and Maintenance?	426
IV.C.5. Proposed Geographic Coverage (States Covered)	428
IV.D. Proposed Methodology to Quantify Emissions That Significantly Contribute or Interfere With Maintenance	437
IV.D.1. Overall Approach: Emissions Reduction Cost Curves	471
IV.D.2. Overall Approach: Air Quality Assessment - Use of Air Quality Assessment Tool (AQAT)	491
IV.D.3. Overall Approach: Identify Appropriate Cost Thresholds	508
IV.D.4. Specific Application of Overall Approach: Fine Particles (PM2.5)	514
IV.D.4.a. EGU Cost Curves/ Air Quality Assessment (AQAT)/Cost Thresholds	516
IV.D.4.b. Modeling Methods/ Air Quality Assessment Tool/Results of Evaluation With Detailed Air Quality Model (CAMx)	540
IV.D.4.c. Possible Emissions Increases in Non-covered States/ Should TX Be Included for PM2.5	548
IV.D.4.d. Other Comments On Application of Approach to Fine Particles (PM2.5)	566
IV.D.5. [Reserved]	568
IV.D.5.a. Specific Application of Overall Approach to Ozone: EGU Cost Curves/ Air Quality Assessment (AQAT)/ Cost Thresholds	569
IV.D.5.b. Specific Application of Overall Approach to Ozone: Modeling Methods/ Air Quality Assessment Tool/ Results of Evaluation With Detailed Air Quality Model (CAMx)/ New York City	577
IV.D.6. Non-EGU Emissions Sources and Control Costs	581
IV.D.6.a. Non-EGU SO2 Emissions Sources and Costs	599
IV.D.6.b. Non-EGU NOx Emissions Sources and Costs	601
IV.E. State Emissions Budgets (Before Accounting for Variability)	602
IV.E.1. SO2 and Annual NOx State Emissions Budgets for EGUs - Data and Methodology	645
IV.E.2. Ozone Season NOx State Emissions Budgets for EGUs - Data and Methodology	674
IV.F. Approach to Power Sector Emissions Variability	680
IV.F.1. General Comments on Variability Approach	682
IV.F.2. Estimating Year-to-Year Variability/Determination of 1-Year Variability Limits	708
IV.F.3. Alternative Calculation Methods	717
IV.F.4. Estimating Multi-Year Variability/Determination of 3-Year (and 2-Year) Variability Limits	719
IV.F.5. Proposed Variability Limits on SO2, NOx, and Ozone Season NOx	724
IV.F.6. Estimate of Effects of Emissions Variability on Downwind Air Quality	728
IV.G. How the Proposed Approach to Significant Contribution and Interference With Maintenance is Consistent With Judicial Opinions	730
IV.H. Alternative Approaches for Significant Contribution and Maintenance That EPA Evaluated	732
V.A. Covered Pollutants (SO2 and NOx for PM2.5 and Ozone Season NOx for Ozone)	734
V.B. [Reserved]	736
V.C. Timing of Proposed Emissions Reductions Requirements (Compliance Deadlines)	737
V.C.1. Coordination With NAAQS Deadlines/Addressing Court's Concern About Timing	756
V.C.2. Reductions as Expeditiously as Practicable/Feasibility of the 2012 and 2014 Compliance Deadlines	768
V.D. [Reserved]	849
V.D.1. General Comments on Remedies/ Remedy Options Overview/Trading Ratios Approach	850
V.D.2. State Budgets/Limited Trading Proposed Remedy	891
V.D.2.a. Applicability/ Opt-in Units	944
V.D.2.b. Allocations	1025
V.D.2.b.i. Comments on Allocations Data/Corrections to Allocations Data	1059
V.D.2.b.ii. Comments on Allocations Methodology	1172
V.D.2.c. Monitoring and Reporting	1428
V.D.2.d. Assurance Provisions/Emissions Limitation Provisions	1435
V.D.2.e. Should Assurance Provisions Start in 2012 Instead of 2014?	1482
V.D.2.f. Penalties	1493
V.D.2.g. Electric Reliability	1496
V.D.2.h. How Proposed Remedy is Consistent With Court's Opinions	1525
V.D.2.i. Other Comments on State Budgets/Limited Trading Proposed Remedy	1529
V.D.3. State Budgets/Intrastate Trading Remedy Option	1533
V.D.3.a. Auctions of Allowances	1541
V.D.3.b. Other Comments on State Budgets/Intrastate Trading Remedy Option	1546
V.D.4. Direct Control Remedy Option	1548
V.D.4.a. Emission Rate Limits - Data and Methodology	1556
V.D.4.b. [Reserved]	1558
V.D.4.c. Penalties	1559
V.D.4.d. How Direct Control Remedy is Consistent With Court's Opinions	1560
V.E. Projected Costs and Emissions for Each Remedy Option	1561
V.E.1. State Budgets/Limited Trading	1566
V.F. Transition from the CAIR Cap-and-Trade Programs to Proposed Programs	1577
V.F.1. Sunsetting of CAIR, CAIR SIPs, and CAIR FIPs	1582
V.F.2. [Reserved]	1590
V.F.3. Applicability, CAIR Opt-ins and NOx SIP Call Units	1591
V.F.4. Early Reduction Provisions	1598
V.F.4.a. SO2 Allowance Bank/Use of Title IV Allowances	1619
V.F.4.b. NOx Allowance Banks/Use of CAIR NOx Allowances	1636
V.G. [Reserved]	1668
V.G.1. Title IV Interactions	1669
V.G.2. NOx SIP Call Interactions	1671
VI. Stakeholder Outreach	1673
VII. State Implementation Plan Submissions	1677
VII.A. Section 110 (a)(2)(D)(i) SIPs for the 1997 Ozone and PM2.5 NAAQS	1686
VII.B. Section 110 (a)(2)(D)(i) SIPs for the 2006 PM2.5 NAAQS	1688
VII.C. Transport Rule SIPs	1690
VIII. Permitting	1732
VIII.A. Title V Permitting	1733
VIII.B. New Source Review (NSR)	1735
IX. What Benefits are Projected for the Proposed Rule?	1754
IX.A. [Reserved]	1757
IX.B. Human Health Benefit Analysis	1758
IX.C. Quantified and Monetized Visibility Benefits	1780
IX.D. [Reserved]	1781
IX.E. How Do the Benefits Compare to the Costs of This Proposed Rule?	1782
IX.F. What are the Unquantified and Unmonetized Benefits of the Transport Rule Emissions Reductions?	1788
IX.F.1. What are the Benefits of Reduced Deposition of Sulfur and Nitrogen to Aquatic, Forest, and Coastal Ecosystems?	1789
X. Economic Impacts	1790
XI. Incorporating End-use Energy Efficiency Into the Proposed Transport Rule	1819
XI.A. How Does Energy Efficiency Contribute to Cost-effective Reductions of Air Emissions from EGUs?	1821
XI.B. How Does the Proposed Rule Support Greater Investment in Energy Efficiency?	1828
XI.C. How EPA and States Have Previously Integrated Energy Efficiency Into Air Regulatory Programs?	1830
XI.D. Incorporating End-use Energy Efficiency Into the Transport Rule	1832
XI.D.1. Options That Could be Used to Incorporate Energy Efficiency Into Allowance Based Programs	1837
XI.D.2. Why EPA Did Not Propose These Options?	1843
XII. [Reserved]	1845
XII.A. Executive Order 12866: Regulatory Planning and Review	1846
XII.B. Regulatory Flexibility Act (RFA)	1849
XII.C. Executive Order 13175: Consultation and Coordination With Indian Tribal Governments	1852
XII.D. Executive Order 13211: Actions That Significantly Affect Energy Supply, Distribution, or Use	1855
XII.E. Executive Order 12898: Federal Actions to Address Environmental Justice (EJ) in Minority Populations and Low-Income Populations	1860
XIII. Regulatory Impact Analysis	1871
XIV. Regulatory Text	1886
XIV.A. Part 97	1887
XV. Air Quality Modeling Technical Support Document (TSD)	1894
XVI. Other Comments	1898
XVII. Extension of the Comment Period	1927
XVIII. [Reserved]	1991
XVIII.A. [Reserved]	1992
XVIII.B. [Reserved]	1993
XVIII.C. Approach to Future EGU (Power Sector) Emission Projections	1994
XVIII.C.1. NPR: EGU Projections Using IPM/NEEDS V.3.02EISA	2132
XVIII.C.2. September 1, 2010 NODA: EGU Projections Using IPM/NEEDS V.4.10	2184
XIX. Transport Rule 2 and Other Future Transport Rulemakings	2420
XX. NODA on Allocations and Related Matters (January 7, 2011)	2459
XX.A. Alternative Allocations Approaches	2643
XX.A.1. General Comments on the Two Alternative Allocation Methodologies	2677
XX.A.1.a. Option 1	2769
XX.A.1.b. Option 2	2791
XX.A.2. Unit-level Comments on Data	2829
XX.A.3. Unit-level Comments on Applicability (e.g., Remove or Add Unit to Inventory of Potential Existing Units)	2861
XX.B. Calculating Assurance Provision Surrender Requirement on Designated Representative (DR) Basis	2890
XX.C. Whether Assurance Provision Approach Should Be Maintained if Allocation Approach is Changed	2928
XX.D. Allocations to New Units in Indian Country	2940
XX.E. Provisions for States to Submit Full or Abbreviated SIPs Providing for State Allowance Allocations	2950
XX.F. Other Comments on NODA 3	2990

Introduction

The following four documents respond to public comments received on the proposed Transport Rule:

   1. Transport Rule Primary Response to Comments (this document)
   2. Transport Rule Emissions Inventories Response to Comments  -  a supplemental document that responds to comments on non-EGU emissions inventories (available in the docket)
   3. Transport Rule IPM Assumptions Response to Comments  -  a supplemental document that responds to comments on the Integrated Planning Model (IPM) assumptions and EGU inventories (available in the docket)
   4. Transport Rule Engineering Feasibility Response to Comments  -  a supplemental document that responds to comments on engineering feasibility of the compliance deadlines (available in the docket)

EPA issued the following actions soliciting public comment on the proposed Transport Rule and on additional information relevant to the rulemaking:

   * Federal Implementation Plans To Reduce Interstate Transport of Fine Particulate Matter and Ozone (75 FR 45210; August 2, 2010).
   * Notice of Data Availability Supporting Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone (75 FR 53613; September 1, 2010).
         o This NODA provided an updated database of unit-level characteristics of EGUs included in EPA modeling, an updated version of the power sector modeling platform EPA used to support the final rule, and other input assumptions and data EPA provided for public review and comment.
   * Notice of Data Availability Supporting Federal Implementation Plans To Reduce Interstate Transport of Fine Particulate Matter and Ozone: Revisions to Emission Inventories (75 FR 66055; October 27, 2010).
         o This NODA provided additional information relevant to the rulemaking, including updated emission inventory data for 2005, 2012 and 2014 for several stationary and mobile source inventory components.
   * Notice of Data Availability for Federal Implementation Plans To Reduce Interstate Transport of Fine Particulate Matter and Ozone: Request for Comment on Alternative Allocations, Calculation of Assurance Provision Allowance Surrender Requirements, New-Unit Allocations in Indian Country, and Allocations by States (76 FR 1109; January 7, 2011).
         o This NODA provided additional information relevant to the rulemaking, including emissions allowance allocations for existing units calculated using two alternative methodologies, data supporting those calculations, information about an alternative approach to calculation of assurance provision allowance surrender requirements, allocations for new units locating in Indian country in Transport Rule states in the future, and provisions for states to submit SIPs providing for state allocation of allowances in the Transport Rule trading programs.
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I. General Comments in Support of Rule That Don't Fit Into Specific Topic Areas

Organization: Adirondack Mountain Club
Gomez, Rose
Comment:
Adirondack Mountain Club
ADK appreciates the hard work and careful thought that the Agency put into this rule. Upwind air pollution must be regulated to protect New York's unique ecosystems that provide New Yorkers with clear air and water, and promote a strong tourism economy. Clean air contributes to a balanced and healthy environment. ADK is pleased that this rulemaking reflects the importance of upwind pollution management for this and future generations. [EPA-HQ-OAR-2009-0491-2761, p.2]
We have a critical stake in the proposed Clean Air Transport Rule (CATR). Emissions of NOx and SO2 from fossil-fueled electric power generating plants are harmful to human communities, aquatic life, and forest ecosystems in the Appalachians, Hudson Highlands, Catskills, Adirondacks, and White Mountains. We strongly feel that deep reductions in emissions of these pollutants are crucial, not only for New York State, but for the country as a whole. [EPA-HQ-OAR-2009-0491-2761, p.2]
Gomez, Rose
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, p.86.]
This is of course something that needs to happen as quickly as possible, and 2012, in no means, is very quickly by any standard as far as I'm concerned, and as far as 2014, when emissions would be reduced by 71 percent, that's fine. The more the better.
Why couldn't it be higher? The amount of benefits, like I said, far outweigh the costs.
Response:
EPA thanks the commenters for their support of this Rule.  EPA is working as expeditiously as possible and within the full extent of its authority, under  Section 110(a)(2)(d) of the Clean Air Act, to ensure improved human health for all Americans through reductions in interstate transport of pollutants within the Transport Rule's 27 states.  EPA is under a timeframe to promulgate the Transport Rule as expeditiously as practicable, as per the remand of CAIR by the Court to the Agency for development of the current Transport Rule.
Organization: Edison Mission Energy (EME)
Comment:
Edison Mission Energy (EME)
While EME supports the overall emission reduction goals set forth in the Transport Rule as consistent with ongoing progress to achieve important air quality goals under the Clean Air Act, EME has specific concerns with key components of the Proposed Rule that must be addressed before EPA finalizes the rule. Specifically: [EPA-HQ-OAR-2009-0491-2707.1, p.2]
If the issues above are not addressed, EME submits that the Transport Rule will impose emission reduction requirements on the power generation sector that: (i) are not technically feasible, and (ii) penalize sources that installed emissions controls before, in some cases well before, the first compliance phase of the Transport Rule. Due to these deficiencies, the compliance costs of the Rule likely significantly exceed EPA's estimate of $2,500 per ton for SO2 control and $500 per ton for NOX control. Therefore, EME requests that EPA make the changes outlined in the Sections below. [EPA-HQ-OAR-2009-0491-2707.1, p.4]
EME SUPPORTS THE OVERALL EMISSION REDUCTION OBJECTIVES OF THE PROPOSED RULE [EPA-HQ-OAR-2009-0491-2707.1, p.4]
At the outset, we note that EME commented in 2004 and 2006 in support of the Clean Air Interstate Rule ("CAIR"), 3 and went as far as to intervene in support of EPA in the lawsuit brought by the State of North Carolina and other parties challenging CAIR. Consistent with these prior positions, EME supports the emission reduction objectives of the Transport Rule. The Proposed Rule would reduce NOx and SO2 emissions from EGUs in affected states by 71%and 52%, respectively, relative to 2005 emissions to address downwind nonattainment issues. By 2014, the caps currently proposed by EPA, would result in emission reductions of over 6.3 million tons of SO2 per year and 1.4 million tons of NOx per year relative to 2005 emissions. [EPA-HQ-OAR-2009-0491-2707.1, p.4]
Like CAIR, the reductions contemplated by the Transport Rule from the EGU sector are massive, and will require considerable investments and impose billions of dollars in costs for the installation and operation of emission control technology such as FGD, SCR, SNCR, and low-NOx burners. Despite these costs, EME supports these emission reductions because they are generally consistent with ongoing progress toward the attainment of important air quality goals under the CAA. Moreover, given the substantial compliance costs that will have to be borne by the power generation sector generally, EME also supports the Agency's preferred approach of achieving the proposed emission reductions using a regional cap-and-trade mechanism. A cap and-trade mechanism is a critically important component of any final Transport Rule, as it will promote efficient emissions control and will provide affected sources with much-needed compliance flexibility. As such, cap-and-trade represents sound public policy. [EPA-HQ-OAR-2009-0491-2707.1, pp.4-5]

3 See Comments of Midwest Generation/Edison Mission Energy on EPA's Proposed Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Interstate Air Quality Rule), Docket Entry EPA-HQ-OAR-2003-0053-0751 (Mar. 30, 2004); Comments of Midwest Generation EME, LLC on EPA's Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule): Reconsideration, Docket Entry EPA-HQ-OAR-2003-0053-2279 (Jan. 13, 2006).
Response:
EPA thanks the commenter for their support of this Rule.  EPA is working as expeditiously as possible and within the full extent of its authority, under  Section 110(a)(2)(d) of the Clean Air Act, to ensure improved human health for all Americans through reductions in interstate transport of pollutants within the Transport Rule's 27 states.  For more detailed information, please see Sections III.A, III.F, IV.A, IV.E, IV.F.1, V.C, V.C.2, V.D.1, V.D.2.b, V.D.2.b.ii, VII, VII.C, XVIII.C, XVIII.C.1, and XIX within the Final Response to Comments Document.
Organization: Luminant
Comment:
Luminant
In general, Luminant supports some aspects of the proposed rule, such as the appropriate exclusion of Texas from the annual SO2 and NOx programs, but Luminant believes that the timeline for implementation of all CATR programs are too short, and that it is inappropriate to conclude that Texas emissions will impact Baton Rouge. Luminant's specific comments are provided below. 2 [EPA-HQ-OAR-2009-0491-2729.1, p.4]

2. Further, Luminant is a member of and supports the comments filed by the Utility Air Regulatory Group, the Edison Electric Institute, the American Coalition for Clean Coal Electricity, the Association of Electric Companies of Texas and the Gulf Coast Lignite Council. [EPA-HQ-OAR-2009-0491-2729.1, p.4]
Response:
EPA thanks the commenters for their support of this Rule.  EPA is working as expeditiously as possible and within the full extent of its authority, under  Section 110(a)(2)(d) of the Clean Air Act, to ensure improved human health for all Americans through reductions in interstate transport of pollutants within the Transport Rule's 27 states.  EPA is under a timeframe to promulgate the Transport Rule as expeditiously as practicable, as per the remand of CAIR by the Court to the Agency for development of the current Transport Rule.
Organization: Tennessee Department of Environment and Conservation, Division of Air Pollution Control
Citizens Campaign for the Environment (CCE)
Minnesota Pollution Control Agency (MPCA)
Province of Ontario, Canada
Green America
Mid-America Regional Council (MARC) Air Quality Forum
Metropolitan Washington Air Quality Committee
Iowa Department of Natural Resources (IDNR)
Clean Energy Group
Pennsylvania Department of Environmental Protection
National Association of Clean of Air Agencies (NACAA)
New York State Department of Environmental Conservation
Maryland Department of Environment (MDE)
Constellation Energy
State of Wisconsin, Department of Natural Resources
Consolidated Edison Company of New York, Inc, (CECONY)
Clean Air Task Force
Indiana Department of Environmental Management
Republicans for Environmental Protection
Delaware Nature Society
Massachusetts Department of Environmental Protection
Pennsylvania Energy Alliance
NRG Energy
Exelon
PSEG Services Corporation
Xcel Energy Inc.
8-Hour Ozone State Implementation Plan (SIP) Coalition
American Petroleum Institute (API)
Calpine Corporation
Empire District Electric Company (Empire District)
Clean Air Council
Entergy Services, Inc.
Pew Environment Group
Sierra Club, Pennsylvania Chapter
Sierra Club
Adirondack Council
St. Louis University
International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers and Helpers (AFL-CIO Boilermakers Union)
NextEra Energy, Inc.
American Lung Association of the Upper Midwest
Respiratory Health Association of Metropolitan Chicago
Cool Joliet
Edison Electric Institute (EEI)
Greenpeace Chicago
Greenpeace Washington, DC
National Resources Defense Council (NRDC)
Pilsen Environmental Rights and Reform Organization (PERRO)
Ailey, John
Tampa Electric Company
American Lung Association
Stuckey, Richard
Mass Comment Campaign (38) (unknown organization)
Mass Comment Campaign (7,793) (Environmental Defense Fund)
Mass Comment Campaign (409) (unknown organization)
Mass Comment Campaign (679) (Greenpeace)
Environmental Law & Policy Center
DiMeo, Daniel
Mass Comment Campaign (20,795) (Sierra Club)
Mass Comment Campaign (600) (Sierra Club)
Mass Comment Campaign (1,817) (American Lung Association)
American Lung Association of Illinois
Peoria Families Against Toxic Waste
Heart of Illinois Group Sierra Club
Central Illinois Global Warming Solutions Group
Ringle, Weeks
Gifford, Casey
Fuller, Tony
Headington, Vincent
Northeast States for Coordinated Air Use Management (NESCAUM)
Parrish, Jr., Joseph
Rizzo, M.D., Albert A.
McCloskey, Natalie
American Lung Association of the Mid Atlantic
Doyle, Edward
Environmental Defense Fund (EDF)
Mothers and Others for Clean Air
Jones, Tiffini Eugene
Atlanta Faces of Homelessness Speakers Bureau
Southern Alliance for Clean Energy
Southeastern States Air Resource Managers (SESARM)
American Lung Association of Georgia
Geogians for Smart Energy Coalition
White, Dr. Yolanda
Mellinger-Birdsong, Anne
Layer, Harrison
Rennes, Beth
South Carolina Department of Health and Environmental Control
Herbert, Natasha
Larson, Nancy
Glynn, Erin
Hanberry-Martin, Susan
Martin, Lee
Nederhand, Frank
Garland, Jenna
Feinberg, Stephen
Watzman, Talie
Black, Jim
Menkes, Larry
Rogers, Nick
New Jersey Business and Industry Association
Tsou, Walter
Ozone Transport Commission (OTC)
DelCore, Amanda
Public Interest Law Center of Philadelphia
Citizens for Pennsylvania's Future, or Penn Future
Schmoyer, Rebecca
Schmerling, Mark
Maryanski, Joseph
Adkins, Frederick
Conover, Barbara
Cummings, Katherine
Pryde, Coralie
Locker, Robert
Mills, Mary
Lillstrom, Aatis
Hodgin, Bradley
Taylor, Nancy
Pendleton, Mark
MacNeille, Jeanette
Stafford, Dr. Wesley & Jane
Stimpfel, Theresa
Waddle, Tolsun
Sierra Club, New Jersey Chapter
Gardner, Robert
Hage, Martin
Strand, Rev. Dr. Horace
Rust, Morgan
New Jersey Department of Environmental Protection (NJDEP)
Michetti, Susan
Oren, Craig N.
Hansen, Gordon
Ripple, Steven
Plumb, James
Ritz, Aaron
Cheung, Eric
Chung, Dr. Esther K.
Group Against Smog and Pollution (GASP)
Fallon, Myriam
Bucic, Sarah
Greater Philadelphia Chamber of Commerce
Smith, Iskar
Fiorentino, Robert
City of Philadelphia, Department of Public Health, Air Management Services
Maher, Jeff
Kravitz, Gregg
Pietrzak, Karl
McKinley, Brad
Comment:
8-Hour Ozone State Implementation Plan (SIP) Coalition
The Coalition supports the overall goal of the transport rule -- reducing the transport of emissions to downwind nonattainment and maintenance areas.  Emissions from our member companies have been steadily decreasing for many years due to a suite of regulatory and voluntary actions that affect virtually every aspect of our operations.  We have also delivered several generations of cleaner gasoline and diesel, which have enabled significant reductions in the mobile source sector. [EPA-HQ-OAR-2009-0491-2736.1, p. 2]
Adirondack Council
We believe that the Environmental Protection Agency is taking appropriate actions to address shortcomings in CAIR that were outlined in 2008 by the U.S. Circuit Court of Appeals for the District of Columbia. We appreciate the efforts of the EPA to quickly respond to the Court's ruling and propose the Transport Rule. [EPA-HQ-OAR-2009-0491-2848.1, p.2]
We are also happy that several of our concerns from 2004 have been addressed, including further reducing the levels of pollution, shrinking the timelines for reductions and dealing with the glut of "banked" allowances that have accumulated over the last 15 years. [EPA-HQ-OAR-2009-0491-2848.1, p.2]
[These comments were also submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.61-62.]
In conclusion, the Adirondack Council strongly supports the Transport Rule and commends EPA for this action, but we believe more can and should be done to protect public health and the environment. We urge EPA to look for opportunities to implement the program with even deeper reductions in nitrogen oxides while keeping its aggressive compliance deadlines in place. [EPA-HQ-OAR-2009-0491-2848.1, p.5]
Adkins, Frederick
I am pleased that the EPA is acting to help states be good neighbors by reducing air pollution escaping across state lines. [EPA-HQ-OAR-2009-0491-0596, p.2]
Thank you for the opportunity to comment in support of the proposed rule for cutting air pollution from Pennsylvania's power plants. [EPA-HQ-OAR-2009-0491-0596, p.3]
This is a national problem that needs a national solution, and I urge the EPA to quickly finalize this common sense approach to protect public health and help states efficiently and cost-effectively clean up their air. [EPA-HQ-OAR-2009-0491-0596, p.3]
Ailey, John
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, p.50.]
I believe this is the consensus that the basic point is we do indeed support that these rules should be passed.
American Lung Association
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, pp.57-62.]
We are pleased that the U.S. Environmental Protection Agency has moved ahead to help states like Illinois fight for healthy air by requiring the cleanup of pollution that blows into these states from outside.
States can't do this on their own. States need the Transport Rule to stop that pollution at the state line.
The American Lung Association calls on the EPA to not only adopt the framework of the Clean Air Transport Rule but to strengthen the limits on the emissions nationwide.
We at the American Lung Association call on the EPA to take this opportunity to do more to protect the air we breath and the lives of our families and friends.
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.45-46.]
First, The American Lung Association is pleased with EPA's decision to create a framework for setting emissions reductions under the 'good neighbor' provisions of the Clean Air Act. Such a framework allows EPA to follow a strong, logical pathway forward. Under this framework, EPA assesses in detail the contribution from sources in each upwind state to the pollution levels in downwind states. Such a careful analysis provides strong evidence that pollution from these 31 states and the District of Columbia harm and burden people living in these nonattainment and maintenance areas. The EPA analysis is compelling evidence that to have clean and healthy air here in Pennsylvania, we need clean and healthy air throughout the entire region.
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.9.]
We are pleased that the US Environmental Protection Agency has moved ahead to help states like Georgia have healthy air by requiring cleanup of pollution from coal-fired power plants.
The American Lung Association calls on EPA to adopt the framework of the Clean Air Transport Rule, but to also set tighter limits on emissions.
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p. 13.]
This tool gives us the framework to act, to stop pollution from blowing across our states. The American Lung Association supports the framework, but also urges EPA to set the right targets and limits. Thank you.
American Lung Association of Georgia
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.56.]
The American Lung Association calls on EPA to not only adopt the framework of the Clean Air Transport Rule, but to strengthen the limits on emissions nationwide to meet the requirement of protecting human health.
These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010. See Docket Number EPA-HQ-OAR-0491-1939, pp.56-59.
This rule will save thousands of lives. We are committed to the prevention of lung disease and the promotion of lung health and this rule will further those goals.
I'll close by saying we at the American Lung Association call on EPA to take this opportunity to do more to protect the air we breathe and the lives of our family and friends.
American Lung Association of Illinois
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, pp.97-98.]
That is why the American Lung Association urges the Environmental Protection Agency to adopt the Clean Air Transport Rule.
We want the air coming across our state line not to add to the burden of pollutants that we already have here in Illinois.
We urge EPA to quickly move to adopt and put in place this important tool for our air.
Controlling air pollution at its source will promote lung health now and in the future.
I rely on EPA to protect my patients to improve their lives and even to save them.
American Lung Association of the Mid Atlantic
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.25-26, 30, 34.]
The American Lung Association calls on EPA to not only adopt the framework of the Clean Air Transport Rule, but to strengthen the limits on emissions nationwide. We need to provide even basic protection for public health.
Passage of the Clean Air Transport Rule will mean fewer people will die and more will stay healthy.
We are here today to testify strongly in favor of the proposed Clean Air Transport Rule. To underscore the need for the rule, to confirm its benefits, and to call for certain safeguards and improvements.
The Clean Air Transport Rule is clearly the kind of major step in the right direction we have been waiting for and we applaud EPAs leadership in proposing this rule.
American Lung Association of the Upper Midwest
[These comments were submitted as testimony at the Chicago, Illinois hearing.  See Docket Number EPA-HQ-OAR-0491-1746, p.15.]
The American Lung Association of the Upper Midwest recommends that U.S. EPA works towards cleaner air by promulgating the Interstate Transport Rule.
American Petroleum Institute (API)
API supports the overall goal of the transport rule -- reducing the transport of emissions from large Electric Generating Units (EGUs) to downwind nonattainment areas. Emissions from our member companies have been steadily decreasing for many years due to a suite of regulatory and voluntary actions that affect virtually every aspect of our operations. We have also delivered several generations of cleaner gasoline and diesel, which have enabled significant reductions in the mobile source sector. [EPA-HQ-OAR-2009-0491-2649.1, p. 2]
Atlanta Faces of Homelessness Speakers Bureau
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, pp.34-35.]
Reducing diesel emissions and smog in Georgia will make life better for school children, as well as for the rest of us who live and work here. Therefore, the Atlanta Faces of Homelessness Speakers Bureau supports a strong Transport Rule to reduce one of the main sources of air pollution causing harm to Georgia's children.
Black, Jim
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.87.]
Please, approve the new Transport Rule to reduce the pollution that is poisoning us all.
Bucic, Sarah
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.201.]
I am testifying today in favor of the EPA Transport Rule.
Calpine Corporation
In general Calpine enthusiastically supports the proposed rulemaking. [EPA-HQ-OAR-2009-0491-3614, p.2]
Central Illinois Global Warming Solutions Group
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, pp.121-122.]
I'm here today in full support of the EPA's actions and the Surface Transport Rule.
I believe that it embodies three principles which need to be broad-based and underlay regulation of all pollutants in our society.
I believe it's a step forward and a move to a better energy future because it helps to place the true cost of using coal and fueling our nation on coal back on to the coal plants. I'm very happy to see that the public health impacts will no longer be absorbed by the public at large, but the cost of the pollution control technologies will be put on the plant so that the cost of coal reflects its true cost rather than allowing all of these socialized costs to go out to the general public and the benefits to remain privatized to the power generators.
I think that's an important principle, and I would hope that as the EPA moves forward on things like coal ash and regulations of other pollutants that the true cost, the true expense to society of dirty fossil fuels would become clear, and eventually they would go out of the market.
Cheung, Eric
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.183-184.]
Now, I need you to do your part and address what I cannot control. I need you to do all you can to reduce the pollution outside that I have no choice but to breathe. And if this means targeting ozone from neighboring states, then I fully support and applaud you actions.
Please act accordingly, and proceed with these regulations as well as future ones that will reduce air pollution.
Chung, Dr. Esther K.
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.185 & 190.]
The new rule would have a significant and favorable impact on health by one, reducing coal pollution and its associated diseases and two, lessening the threat of global warming and its predicted ill health effects.
I commend the EPA for the proposed Transport Rule and for all of its work to preserve and improve America's health.
Citizens Campaign for the Environment (CCE)
CCE is pleased that the EPA is moving ahead quickly with the new proposed Transport Rule, and offer the following comments. GENERAL COMMENTS In general, CCE strongly supports the EPA finalizing a strengthened Transport Rule as soon as possible. [EPA-HQ-OAR-2009-0491-1937.1, p. 1]
While New York State has taken significant action to reduce its emissions, power plants from upwind states continue to damage our environment, public health, economy, and building structures in NYS. The longer we wait, the worse the problem will get, and the more expensive the solutions will become. Finalizing a strengthened Transport Rule as soon as possible will help to protect our environment, health, economy, and building structures from additional harm. [EPA-HQ-OAR-2009-0491-1937.1, pp. 1-2]
Citizens for Pennsylvania's Future, or Penn Future
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.128-130.]
We support actions by EPA that address air pollution and protect the public health.
We commend EPA for proposing this rule. We encourage EPA to make it better, with steeper reductions that reflect already-available pollution controls.
City of Philadelphia, Department of Public Health, Air Management Services
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.216.]
The City of Philadelphia commends the EPA for its efforts to protect public health by proposing to regulate nitrogen oxide, NOX and sulfur dioxide, SO2, emissions from electric generating units, EGUs, within 31 states in the eastern U.S. and the District of Columbia.
Clean Air Council
I am a concerned citizen who is in support of the proposed 'Transport Rule'. This rule will require coal burning power plants to substantially reduce their emissions, limiting the amount of ozone and particulate matter pollution that goes into the air, thus protecting the environment and public health . Inhaling ozone and fine particulate matter has been linked to health problems such as heart disease, lung cancer, asthma, bronchitis and emphysema. By enacting this proposed rule more children would be able to grow up asthma-free, fewer adults would feel the crippling effects of heart disease and emphysema, and more people would be able to breathe clean air. [EPA-HQ-OAR-2009-0491-2876 p.2]
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.41-42.]
The purpose of my testimony today is to support EPA's proposed Clean Air Transport Rule and yet urge that it be even more stringent.
Pennsylvania is the poster child for the Transport Rule. Our western borders are invaded by air pollution from neighboring states, and yet we are also an exporter of pollution. Indeed, even under the proposed rule, Western Pennsylvania will not meet the federal health standards. It cannot do so unless EPA tightens the NOX standard.
Clean Air Task Force
I. Overview
Today, fossil fuel-fired power plants remain -- despite substantial regulatory focus and resultant emission reductions in recent years -- the largest source of industrial air pollution in the country. These emissions are harmful in their own right, but through atmospheric interactions they are also primary contributors to ozone smog and fine particles, both of which are extremely harmful to human health and the environment. Earlier this month, CATF released a report updating its earlier analysis of US power plant pollution, projecting that PM emissions from the nation's coal-fired power plant fleet will cut short the lives of about 13,000 people this year. [EPA-HQ-OAR-2009-0491-2738.1, p.2]
More than a decade ago, EPA promulgated the 1997 air quality standards for fine particulate matter and 8-hour ozone. A more protective PM standard was established in 2006. In 2008, EPA adopted a stronger 8-hour ozone standard. EPA recently determined that the 2008 ozone standard did not provide the protection required under the Clean Air Act and is currently considering strengthening that standard as well. Today, however, many areas throughout the East and Midwest continue to exceed these health-based standards. In order for many Eastern nonattainment areas to have a realistic chance of meeting those standards and improving the health of their citizens, steep reductions in transported power plant emissions of SO2 and NOx are absolutely necessary. Not only will steeper reductions allow states to attain the existing PM and ozone NAAQS, but they will also be necessary to help states achieve future air quality standards for PM and ozone, which are likely to be tightened in the next year or so. Furthermore, additional reductions will deliver substantial additional public health benefits resulting from lower ambient pollution levels, regardless of attainment status. [EPA-HQ-OAR-2009-0491-2738.1, pp.2-3]
The problem would be much worse if many power plants had not reduced their emissions of SO2 and NOx over the past few years. National power plant emissions of sulfur dioxide have fallen from 10.3 million tons per year in 2004 to 5.7 million tons last year, a drop of nearly 50 percent in five years. NOx emissions from power plants have also fallen by about half during this period. While these reductions may be attributed to a number of factors, including the 'NOx SIP Call,' New Source Review enforcement actions and a variety of state regulations, these air quality gains were consolidated and extended through EPA's 2005 Clean Air Interstate Rule ('CAIR').  [EPA-HQ-OAR-2009-0491-2738.1, p.3]
We generally support the basic structure of the TR, although the proposed SO2and NOx emission reductions are inadequate. We agree with EPA that the control of both regional and local reductions is a more cost-effective, balanced, and reasonable approach to addressing nonattainment than relying on local reductions alone. 22 We also generally support EPA's two-step approach to determining significant contribution, although we do have some concerns about its application, as well as its use of non-uniform cost thresholds to determine the level of required emission reductions. [EPA-HQ-OAR-2009-0491-2738.1, p.6]
In conclusion, we support the general approach and direction of EPA's TR proposal, but we submit that it is not sufficiently stringent to adequately protect public health or to provide adequate emission reductions to allow nonattainment areas to achieve attainment of the PM and ozone NAAQS as expeditiously as practicable. EPA must finalize a stronger rule as soon as possible. [EPA-HQ-OAR-2009-0491-2738.1, p.30]
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.105-106.]
Furthermore, even at todays pollution levels, the lives of tens of thousands of Americans will be cut short and there are still over 700 coal-fired power plants in the U.S. operating with no scrubber in place. At this point, every coal-fired power plant in the United States should be well-controlled. That is why it is so important for EPA to strengthen and finalize the proposed Transport Rule.
We believe that the Transport Rule is a good step towards requiring needed air pollution reductions in the electric power sector, and we commend the EPA for bringing the proposal forward. We are concerned, however, that the proposal falls short of requiring the amount of cost-effective reductions that are reasonably obtainable and necessary to protect human health and the environment.
Clean Energy Group
The Clean Energy Group supports the proposed Transport Rule. The proposed rule will achieve important air quality, health, and economic benefits utilizing EPA's current authority. It is critical that EPA implement the rule as expeditiously as practicable to ensure realization of these benefits. We are committed to working with EPA to ensure the Agency can implement the Transport Rule by January 1,2012, and to that end, we offer these comments. [EPA-HQ-OAR-2009-0491-2702.1, p. 1]
Conover, Barbara
Thank you for taking an important step forward in the fight against pollution by proposing the Good Neighbor Rule. As you are aware, millions of people are currently breathing air that does not meet clean air standards. Soot and smog from dirty coal plants travels downwind and affects neighboring states. This pollution causes heart attacks, asthma and lung disease. [EPA-HQ-OAR-2009-0491-0917, p.2]
The 2005 CAIR was a good step in EPA's regulation of interstate air pollution as directed by the Clean Air Act.. But the 2010 Good Neighbor Rule goes further -- and I encourage you to make it as strong as possible. [EPA-HQ-OAR-2009-0491-0917, p.2]
I also encourage you to include in the rule particular safeguards for states whose own 'state level EPAs' oversee the Clean Air Act regulation do not allow their enforcement to be lax. [EPA-HQ-OAR-2009-0491-0917, pp.2-3]
Consolidated Edison Company of New York, Inc, (CECONY)
CECONY supports the efforts of all levels of government to improve our common air quality, and has received numerous awards from the U.S. Environmental Protection Agency ('EPA'). Specifically, CECONY has been recognized for reducing fugitive SF6 and CH4 emissions through its participation in the EPA's SF6 Reduction Partnership Program and Natural Gas STAR program. In 2009, Con Edison was listed for the first time to the prestigious Dow Jones Sustainability Index, and was rated first globally among utilities for performance by the Carbon Disclosure Project. In 2010, the Company underwent a third party verification of its greenhouse gas emissions and became a Climate Registered company under The Climate Registry's voluntary reporting protocol. [EPA-HQ-OAR-2009-0491-2653.1, p.1]
Constellation Energy
Our primary comment is that EPA should move forward quickly with full implementation of the rule. [EPA-HQ-OAR-2009-0491-3613, p.1]
Cool Joliet
[These comments were submitted as testimony at the Chicago, Illinois hearing.  See Docket Number EPA-HQ-OAR-0491-1746, p.23.]
We also call on the U.S. EPA as part of the Transport Rule to not allow for cap and trade of these deadly pollutants.
All plants should be required to install pollution controls. Polluters shouldn't be allowed to pick what plants they clean up when the plants are a threat to public health.
Cummings, Katherine
I urge the EPA to adopt and enforce the Transport Rule to protect and improve the health of both urban and rural Americans. Coal-fired power plants are among the biggest polluters in our country. The risk of death and disease caused by coal-fired power plant pollution threatens the health of millions of Americans. The clean up of power plants is long overdue. Georgia stepped up to start cleaning up their own power plants, but Georgia cannot stop the pollution that blows into our state from other states. We need EPA to help us clean the air we breathe. [EPA-HQ-OAR-2009-0491-0968, p.2]
I encourage the proposed EPA Transport Rule because it will reduce sulfur dioxide and nitrogen oxide pollution that create ozone smog and particle pollution that blows into our state. This will improve the health of millions of people at risk from these pollutants, especially seniors, children and people with chronic lung diseases and cardiovascular diseases, and diabetes. We also need to cut pollution that our power plants are sending to other states, too. We need to have even greater reductions in the sulfur dioxide and nitrogen dioxide emissions that create deadly ozone and fine particle pollution. [EPA-HQ-OAR-2009-0491-0968, p.2]
This Transport Rule does what we cannot do: require power plants that are spewing toxic pollution into our state to clean up their act. Too many times pollution comes into our state. Air at the state line is already too polluted. Georgia has a strong power plant clean up rule. This would apply a similar rule to other states so that pollution from Illinois, Indiana, Pennsylvania, Ohio and even Florida won't spread into our state. [EPA-HQ-OAR-2009-0491-0968, p.2]
The EPA can contribute greatly to improved health status for millions of Americans by adopting and enforcing the Transport Rule. Please adopt and enforce it for the benefit of citizens of all ages. [EPA-HQ-OAR-2009-0491-0968, p.3]
Delaware Nature Society
The organization has been studying 'energy issues' broadly for many years and supports the EPA's efforts to limit sulfur dioxide (SO2) and nitrogen oxide (NOX) through the proposed 'Transport Rule.' [EPA-HQ-OAR-2009-0491-0204.1,p.1]
DelCore, Amanda
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.121.]
So, as a resident of Philadelphia, a resident of North America, I am asking you to please implement this plan to reduce interstate transport of fine particulate matter and ozone.
DiMeo, Daniel
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, p.90.]
Again, I would like to say that I believe it's a great step towards achieving the goal of the Clean Air Act, and I hope it is one of many steps in this direction.
Doyle, Edward
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.66.]
I am excited and really happy to see what the EPA is doing in limiting transportable pollutants, sulfur dioxide and nitrous oxide.
Edison Electric Institute (EEI)
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, pp.23-25.]
Let me begin by saying that EEI shares a commitment with the Environmental Protection Agency to reduce emissions for power-generating facilities and is generally supportive of the policy objectives underlying EPA's proposed Transport Rule.
In fact, the electric power industry has already made significant progress in reducing emissions in sulfur dioxide, nitrogen oxide, even while the nation has consumed more energy and the economy has grown.
In particular, national SO2 emissions from power plants in 2009 were 64 percent lower than in 1990, and national power plant NOx emissions declined 70 percent over the same period.
Further, power generation of NOx emissions during the ozone season in the 20-state region covered by the NOx Budget Trading Program of Eastern U.S. have declined 81 percent since 1990.
In order to continue to effectively produce electricity and reduce emissions in the electric sector, we need clear, coordinated and flexible regulations that provide certainty for power companies to plan multibillion-dollar investments, many of which must serve decades into the future.
Only through carefully crafted regulations can EEI members continue to minimize costs to consumers and impacts on shareholders, avoid straining natural gas supply and prices, and continue efficient and reliable electric generation using diverse domestic energy resources.
Empire District Electric Company (Empire District)
Empire supports the EPA's remodeling of Kansas regarding inclusion for annual and ozone season NOx and for SO2.  [EPA-HQ-OAR-2009-0491-2659.1, p.1]
Entergy Services, Inc.
As it supported most elements of the Clean Interstate Air Rule ("CAIR"), Entergy supports the Proposed Clean Air Transport Rule (Transport Rule) as an effective way to reduce ozone and fine particulate levels in the eastern United States. [EPA-HQ-OAR-2009-0491-2847.1,p.1]
Environmental Defense Fund (EDF)
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.74-75.]
The Proposed Rule is an important step in protecting public health and the environment.
Environmental Law & Policy Center
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, p.75.]
The LPC is supportive of the concept of the Clean Air Interstate Rule, and we support making it even stronger.
Therefore, we support the EPA in its rule-making and encourage EPA to go even further.
Exelon
Exelon Corporation ("Exelon") offers the following comments in support of the Environmental Protection Agency's ("EPA's") Clean Air Transport Rule ("Transport Rule"). 1 Exelon urges EPA to implement the rule largely as proposed and to do so as quickly as possible. Not only will the proposed Transport Rule generate significant human health and economic benefits, it will further promote the modernization of the electric generating industry and reduce the implicit "pollution charge" that stymies growth and economic development in Exelon's primary service areas. Exelon also suggests several potential improvements to the proposed rule. [EPA-HQ-OAR-2009-0491-2666.1, p.1]
Exelon is one of the nation's leading electricity suppliers. Exelon Corporation is comprised of three principal subsidiaries: two electric transmission and distribution subsidiaries, Commonwealth Edison Company ("ComEd") and PECO Energy Company ("PECO"), serving approximately 13 million people in the greater Chicago and Philadelphia regions, respectively; and Exelon Generation Company, LLC ("Exelon Generation"), which owns and operates over 25,000 MWs of nuclear, coal, wind, hydro, solar, gas and oil-fired generation  -  the fifth largest generation fleet in the United States. Although Exelon owns and operates facilities directly affected by the Transport Rule, Exelon strongly supports the policy objectives underlying EPA's proposal. [EPA-HQ-OAR-2009-0491-2666.1, p.1]
To be sure, some in our industry will argue that compliance is not feasible because EPA is acting too quickly, that electric reliability will suffer, or that the costs are too high at a time when the nation's economy is struggling. These arguments are myopic and wrong. The history of our industry proves that EPA's regulatory pace is appropriate and can be met by industry with little, or no, innovation. Moreover, the industry can easily tolerate the retirement of the oldest and dirtiest units without affecting reliability. And while the purported feasibility and reliability arguments against the Transport Rule are simply mistaken, the argument that EPA should delay the rule because of the nation's economic struggles is pure sophistry. The record is clear that the economic costs, and in particular the healthcare costs, associated with uncontrolled emissions dwarf the compliance costs of the proposed regulation. Moreover, as more fully set forth below, uncontrolled emissions from certain regions of the country are imposing enormous economic burdens on downwind economies. Against these hard facts, EPA must move quickly to control these emissions precisely because the American economy can no longer afford to pay the costs of failing to act. [EPA-HQ-OAR-2009-0491-2666.1, pp.1-2]
Indeed, the proposed Transport Rule could and should be strengthened significantly. In its comments below, Exelon suggests several modifications to the proposal that will improve Transport Rule by (1) expediting the elimination of upwind contribution to downwind nonattainment by increasing economic incentives to reduce emissions, (2) improving the functioning of pollutant allowance markets, (3) facilitating reductions in state budgets to meet revised National Ambient Air Quality Standards ("NAAQS"), and (4) making the rule both more fair and more defensible. As described in greater detail below, Exelon suggests: [EPA-HQ-OAR-2009-0491-2666.1, p.2]
Implementing the compliance assurance provisions beginning in 2012 rather than 2014 (Comment 5.2); [EPA-HQ-OAR-2009-0491-2666.1, p.2]
Reducing the proposed state budgets so that they do not exceed the least of actual historical state emissions, the Clean Air Interstate Rule ("CAIR") state budgets and the reduced state budgets that should result from the EPA's revisions to its modeling assumptions referenced in the Notice of Data Availability published on September 1, 2010 (Comment 6); [EPA-HQ-OAR-2009-0491-2666.1, p.2]
Reducing the proposed state budgets to assure compliance with revisions to the 2008 Ozone NAAQS expected to be adopted before the final Transport Rule is adopted (Comment 7); [EPA-HQ-OAR-2009-0491-2666.1, p.2]
Providing for the issuance of allowances that include state and vintage year identifiers, and modifying the compliance assurance provisions to be based upon the number of in-state, in-vintage year allowances surrendered by a source owner each year, rather than the initial allocation of allowances that the owner receives (Comment 5.3); [EPA-HQ-OAR-2009-0491-2666.1, p.2]
Revising the method for allocating allowances so that an increasing portion of allowances are auctioned and free allowances are awarded in a manner that does not create perverse operating incentives (Comment 8); and [EPA-HQ-OAR-2009-0491-2666.1, p.2]
Allowing certain additional units to opt in to the trading program (Comment 9). Although Exelon believes that these changes would improve the proposed Transport Rule, the proposed rule is legally defensible in its present form without these improvements. Exelon therefore urges EPA to adopt and implement the Transport Rule as so modified as soon as possible, so that downwind employees and customers can realize its benefits to health and the economy without further delay. [EPA-HQ-OAR-2009-0491-2666.1, p.2]
As an owner and operator of facilities directly affected by the Transport Rule, Exelon strongly supports the policy objectives underlying EPA's proposal. It is imperative that power plants in the Transport Rule states make significant and timely reductions in emissions of nitrogen oxides ("NOX") and sulfur dioxide ("SO2") to support the attainment and maintenance of NAAQS in downwind states. Pollution from plants that have not installed adequate control equipment imposes a heavy burden on businesses and families living in areas affected by these emissions, both those near the plants and those hundreds of miles downwind. [EPA-HQ-OAR-2009-0491-2666.1, p.3]
[This comment was also submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.35.]
THE TRANSPORT RULE REPRESENTS A REASONABLE, MEASURED AND APPROPRIATE SCHEME TARGETED TO PREVENT AIR POLLUTION SOURCES INUPWIND STATES FROM INTERFERING WITH THE MAINTENANCE OR ATTAINMENT OF NAAQS IN DOWNWIND STATES.
The Transport Rule will improve health and the environment and promote economic growth and equity without impairing electric system reliability. When Congress Enacted the CAA, Congress anticipated that older units would eventually be upgraded or retired and replaced with facilities employing Best Available Control Technology ("BACT"). 8 Instead, the New Source Review ("NSR") program created perverse incentives to keep uncontrolled, antiquated inefficient units alive and operating. Today, 59% of the coal-fired units in operation where in existence when the CAA was enacted in 1970, and of those very old units, 61.3% are still entirely uncontrolled. These units, however, produce only 33.5% of the total electricity supplied by the coal-fired fleet.9 Providing a signal that these antiquated, polluting units will need to pay for an increasing percentage of the pollutants they emit will restore appropriate incentives and encourage their replacement with state of the art efficient units. [EPA-HQ-OAR-2009-0491-2666.1, p.5]
As discussed in greater detail below, the proposed Transport Rule faithfully addresses the requirements of the CAA as interpreted by the Court of Appeals for the District of Columbia Circuit. EPA applied reasonable methodologies to develop state emission budgets and carefully assessed the costs and benefits of this proposal. The proposed Transport Rule would eliminate downwind contribution to nonattainment in almost all areas, and do so without any dislocation in the electric generation and distribution system. Nonetheless, Exelon believes that there are a few areas in which the Transport Rule could be improved, and requests that EPA consider the comments below. Exelon also urges EPA to adopt and to implement the rule on the schedule Exelon has proposed below, with full compliance commencing on January 1, 2012. [EPA-HQ-OAR-2009-0491-2666.1, p.6; for additional comments pertaining to THE TRANSPORT RULE REPRESENTS A REASONABLE, MEASURED AND APPROPRIATE SCHEME TARGETED TO PREVENT AIR POLLUTION SOURCES INUPWIND STATES FROM INTERFERING WITH THE MAINTENANCE OR ATTAINMENT OF NAAQS IN DOWNWIND STATES, see pp.5-6 of this comment summary]
Exelon respectfully requests that EPA modify the proposed Transport Rule to incorporate the changes proposed by Exelon in these comments, and that EPA adopt and implement the final Transport Rule as expeditiously as possible. Exelon offers its experience and support to EPA should the agency require additional information in connection with these comments or other issues regarding the Transport Rule. [EPA-HQ-OAR-2009-0491-2666.1, p.48]
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.38.]
The proposed Transport Rule is critical to leveling the playing field and ensuring that costs are appropriately borne by the plants that are causing the problem.

8 The Senate Report stated: "Therefore, the Committee determined that existing sources of pollutants either should meet the standard of the law or be closed down, and in addition that new sources should be controlled to the maximum extent possible to prevent atmospheric emissions." Clean Air Amendments of 1970, 91st Congress  -  Committee Reports: Senate Public Works Committee Report 91-1196, Reporting S. 4358, 91 Cong. Senate Report 1196 at 3; CAA, 70 Leg. Hist. 19, 103 (Sept. 17, 1970).
9 See Ensuring a Clean, Modern Electric Generating Fleet while Maintaining Electric System Reliability, M.J. Bradley & Associates LLC & the Analysis Group (2010), attached hereto as Exhibit 1, at Table 5 [See pp.Exh-pg.16. of this comment summary for Exhibit 1 table 5]
Fallon, Myriam
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.195-197.]
I believe this rule to be a big step in the right direction as far as the air quality goes, and across our country.
Feinberg, Stephen
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.133.]
I want to voice my support for the Clean Air Transport Rule.
Restrictions on the polluting outputs of coal plants will improve air quality and health and, in turn, leading to monetary savings and a better energy future. And we can't afford to spend time and energy on building new plants like the one we're currently doing in Georgia with plants like Plant Washington in Centerville, Georgia, nor should we have to worry about air pollution that we receive from other states. We should instead be focusing on the future of clean energy.
Fiorentino, Robert
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.210.]
I love the idea of making the air better, making the industry more secure and tighter. I really like what the EPA is doing.
I really can't see any reason to not go forward and have stricter standards. I am thinking selfishly for my own health and enjoyment, and also down the line when I have children, grandchildren, what have you. I really think that we're on the right track and EPA is on the right track.
Fuller, Tony
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, p.132.]
So I'm not a scientist, but I just wanted to say there are a lot of people out there suffering because of this, and I just wanted to come in and say that I support this effort to make strong reductions in these pollutants, and I believe that the costs involved are negligible compared to the benefits that it's going to make for people in the city, and, of course, around the country as well. I guess that's it.
Gardner, Robert
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.143-144.]
I would like to applaud the EPA for taking this positive step towards restricting dangerous Sulfur Dioxide and Nitrogen oxide.
The Environmental Protection Agency is right to restrict pollution of sulfur dioxide and nitrogen oxide from dirty old coal plants across the country. Americans should not be forced to wait for clean air. This is especially so, given the clear ability of electric power companies to utilize readily available pollution-control technologies, while simultaneously ensuring a reliable electric system.
Under authority of the Clean Air Act, a strong Transport Rule will put the onus back on industry for the pollution it has tried to send far away by building taller and taller smokestacks. Many of the worst offending coal plants do not even provide electricity to the communities they pollute.
Garland, Jenna
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.131 and 132.]
Because when I was doing my research and learning about what was proposed, I thought this is exactly what we need because we know that coal-fired power plants are dangerous. We know that the plants we have today are pumping pollutants into our air. We know that the proposed plants are only going to make things worse and we need to start taking steps now.
So I'm so pleased that Administrator Jackson is a strong leader in the US EPA and I want to ask you to please do even more. Please be more -- I don't want to say aggressive, but maybe active a little more. I don't know the right word, but you know what I'm trying to say. Even more excited and active about moving forward with having this rule implemented, having it as strong as possible.
So, once again, in summation, thank you for being here. Thank you for listening to our comments. And I hope that we will soon be able to move beyond coal entirely and towards an economy powered 100 percent by clean energy.
Geogians for Smart Energy Coalition
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.60 and pp.62-63.]
We support EPA's clean Transport Rule because it will reduce sulfer dioxide and nitrogen oxide pollution that create ozone smog and fine particulate pollution that blows into our state.
This regulation by our government which is specifically charged with protecting our health will improve the health of millions of people at risk from these pollutants, especially seniors and children, people with chronic lung disease and cardiovascular diseases and diabetes.
The Clean Air Transport Rule is an opportunity to speak out for our children and other sensitive groups that rely on our knowledge and action to protect them.
This Transport Rule does what we cannot do, which is require power plants that are spewing toxic pollution into our state to clean up their act and to require some of the plants here in Georgia that send our dirty coal plant pollution to neighboring states. And as has been mentioned, this rule would require Georgia, as other states, to cut the pollution. Although there has been a great reduction already, Georgia has some of the dirtiest coal plants here in the nation.
Gifford, Casey
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, p.130.]
So I encourage the EPA to pass this rule.
Glynn, Erin
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.111 and p.113.]
I'm here today to support  the Clean Air Transport Rule and ask that it be strengthened.
So I would just like to say thank you again for coming. I support the Transport Rule and energy efficiency and clean energy would be much greater opportunities to the utility representatives that are here today.
Greater Philadelphia Chamber of Commerce
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.204.]
We are please to be here today to express our support for the proposed rules designed to help states implement the Good Neighbor provisions of the Clean Air Act which prohibits states from significantly contributing to the air quality problems of another state.
The EPA Transport Rule specifically is aimed at requiring stricter controls for air pollution that travels hundreds of miles and causes multiple health and environmental problems for surrounding regions. As a downwind state, Pennsylvania will benefit from the proposed rule changes being suggested by the EPA. These actions will have a significant impact on public health as well as on economic development and infrastructure needs within our region.
Green America
The members of Green America are deeply concerned about the environmental impacts of electric power generation in our country, and support the generation of electric power in the cleanest way possible. As we all know, ozone and fine particulate matter pose significant health risks to our citizens. The EPA has dealt with these problems diligently through the use and enforcement of the National Ambient Air Quality Standards. This summer the EPA proposed a new Transport Rule, which would help to strengthen the steps the EPA has already taken to control SOx, NOx, fine particulate matter, and ozone. The proposed 71 percent reduction of SO2 and 52 percent of NOx in covered states would create an enormous benefit for millions of Americans. [EPA-HQ-OAR-2009-0491-2611,p.2]
We at Green America wanted to send our thanks to the EPA for continuing your work in protecting our country from the significant environmental and health risks that are posed by fine particulate matter and ozone. We support the continued regulation of NAAQS pollutants and support the new Transport Rule. [EPA-HQ-OAR-2009-0491-2611,p.2]
Greenpeace Chicago
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, pp.31-33.]
Today we show our solidarity with these communities in voicing our support for the Transport Rule as an initial step in the right direction.
The Transport Rule helps put the burden back on the polluters for the damage they cause and places responsibility squarely where it belongs, not on the very people being victimized by big coal's corporate greed.
By ending public health subsidies and a free lunch for filthy plants, we can ensure that energy efficiency and renewable energy also have a place at the table when discussing compliance with the Transport Rule.
Greenpeace Washington, DC
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, pp.34-35.]
Greenpeace firmly believes that no one should have to die to keep the lights on, so on behalf of families who suffer from coal-plant pollution day in and day out and thousands of our supporters across the midwest and U.S., Greenpeace expresses its support of the Transport Rule as a means to clean air across 31 states and the District of Columbia.
With a cost-to-benefit ratio of more than 100 to 1 even industry leaders from Exelon, PSEG and Constellation Energy can see that the Transport Rule provides cost-effective common-sense protection of public health.
Based on the Clean Air Act's 42-fold return on investment, it stands to reason that the Transport Rule promises to deliver many similar air quality and cost-of-protection benefits of care, and, indeed, go further as it should.
Group Against Smog and Pollution (GASP)
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.191 & 199-200.]
We commend the agency for developing the Clean Air Transport Rule, and we welcome the reductions in PM 2.5 and ozone the rule will secure.
However, from the perspective of those of us living in southwestern Pennsylvania the proposed rule does not go far enough.
We applaud EPA for taking interstate action for an interstate problem. Knowing that our upwind pollution sources are being dealt with will allow GASP to hold our leaders in Pittsburgh more accountable for the pollution we produce ourselves.
But while we are pleased to see this rule go forward, we would like it to be even stronger.
Hage, Martin
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.148.]
I would like to put on the public record my support for the Transport Rule. I believe this rule will make the air I breathe less harmful to my body.
Hanberry-Martin, Susan
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, pp.121-122.]
One of the most important functions of government is to protect the health and safety of the citizens. And because our state is not doing it, we look to the EPA to produce strict rules that will protect our health and safety. And I'm fully in support of everything that you're doing to this end. I can't thank you enough for getting the ball rolling on this. We truly, truly need some help.
Hansen, Gordon
I applaud EPA efforts to help states be good neighbors. [EPA-HQ-OAR-2009-0491-1955,p.1]
Headington, Vincent
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, p.134.]
I'm here to support the proposed rule.
So my main reason for supporting the rule is that I believe that it would, A, reduce healthcare costs and also save costs for small employers.
Heart of Illinois Group Sierra Club
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, pp.117-120.]
We are in support of EPA and appreciate your leadership in moving forward for better air quality.
The time is now to move forward with stronger regulations, and this Transport Rule is an essential step.
We look to your rulings as a way to help our community be careful not to get out of attainment I should say, and, also, that we can improve air for us.
Herbert, Natasha
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.103.]
The Clean Air Transport Rule, if enacted, is an example of a primary method that would protect many people from developing diseases and conditions that are preventable.
I'm a supporter of this rule because it is time to clean up power plants and decrease the pollution that we are creating. Coal-fired power plants produce massive amounts of pollution which affect those living in close proximity, along with those afar due to the winds blowing particulate matter and other fine particles around.
The state of Georgia has been proactive in making steps to clean up the power plants here, but we are also affected by our neighboring states by pollution that blows in. We need EPA and the cooperation of all our neighbors to decrease pollution and prevent unnecessary asthma attacks and emergency room visits that Americans face every day due to the pollution produced by coal-fired power plants.
There are several laws at the national and state level that have been passed and enforced that save countless lives. Every time we put on our seat belts when we get in the car, we think click it or ticket. Or when we are able to breathe smokeless air on airplanes or in some indoor facilities, just think of the many individuals and lives that were saved because these laws were enacted to protect the greater population.
I support the Clean Air Transport Rule because I see it as another avenue to clean the air that we breathe and prevent unnecessary hospitalizations and the development of disease. As public health professionals, let us act in the best interests of the general public to clean up power plants so that we can all breathe cleaner air.
Hodgin, Bradley
I am 100% behind you and the E.P.A., and I'm sure most Americans are also in implementing a good neighbor rule, and regulating these dirty corporations. I believe that the public is being silenced by the right wing owned media, and the only points of view being allowed onto the airwaves are views from the far right. The only tool the public has now is the open internet, and that now is in jeopardy, so I encourage you to look at points of view from the public, and not from corporate America. [EPA-HQ-OAR-2009-0491-1274, p.1]
Indiana Department of Environmental Management
Indiana feels that U.S. EPA has effectively addressed the court's ruling and fairly applied the applicable criteria. Furthermore, Indiana believes that the proposed rule adequately addresses obligations under Section 11 0(a)(2)(D) of the Clean Air Act for the states affected by this rulemaking. Additional emission reductions will be necessary at the local level for the few remaining nonattainment areas to comply with the 1997 National Ambient Air Quality Standards (NAAQS). [EPA-HQ-OAR-2009-0491-2645.1, p.1]
International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers and Helpers (AFL-CIO Boilermakers Union)
We applaud EPA's leadership in transitioning from the Clean Air Interstate Rule (CAIR) to a new framework to address interstate contributions to air quality degradation prohibited under Section 110(a)(2)(D)(i)(I) of the Clean Air Act (CAA). Improving air quality through cost-effective emissions reduction measures is crucial to protecting the public health and welfare and stimulating economic activity in this difficult recession. The capital that will be deployed by EGU owners to implement emissions control measures required under the proposed Transport Rule should create well-paying jobs for Boilermakers across the country. However, as described in detail below, the Boilermakers Union also has serious concerns about certain aspects of EPA's proposed implementation of the Transport Rule. We believe that changes are necessary to ensure the effective and efficient implementation of the emissions reduction requirements and achievement of the air quality goals of the Transport Rule. [EPA-HQ-OAR-2009-0491-2672.1, pp.1-2]
Although we have concerns about the timing of the proposed Transport Rule, the Boilermakers Union generally supports the proposed reduction requirements of the Transport Rule and believes that - if implemented on a realistic timetable - the rule would stimulate considerable new investment and job creation in the power sector. During the three years following the promulgation of CAIR, our members experienced a rapid increase in demand for labor as EGUs began installing FGD and SCR units to meet the new control requirements. We anticipate that the Transport Rule could precipitate a similar wave of construction, bringing jobs to areas of the country and to economic sectors that badly need them. [EPA-HQ-OAR-2009-0491-2672.1, p.2]
V. CONCLUSION
Despite the aforementioned concerns regarding the proposed Transport Rule, the Boilermakers Union believes that EPA has established, on balance, a strong and viable framework for reducing interstate pollution in the eastern United States. By equipping itself with more complete information about the economic impacts of the regulations it is proposing, and by ensuring that the manner in which these regulations are implemented along a feasible timeline, the Boilermakers Union is confident that EPA can maintain the environmental integrity of this program without unnecessarily imperiling American workers in this difficult economic period. [EPA-HQ-OAR-2009-0491-2672.1, p.11]
Iowa Department of Natural Resources (IDNR)
The IDNR supports EPA efforts to reduce emissions associated with interstate pollutant transport. We also commend EPA for considering the revised 2006 24-hour PM2.5 standard in addition to the 1997 O3 and PM2.5 standards in the proposed rule. Timely and effective regulations that generate adequate and equitable reductions in interstate pollutant transport are important components to protecting public health. Continued emphasis on reducing interstate pollutant transport will be needed to the extent the lowering of the National Ambient Air Quality Standards (NAAQS) exacerbates the degree to which out-of-state sources contribute to in-state air pollution.
Jones, Tiffini Eugene
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.24.]
And I'm here today to support the proposed Transport Rule.
I applaud EPA's proposed Transport Rule that will require 31 states and the District of Columbia to reduce power plant emissions. I want utilities in the eastern US, some of whose pollution reaches our state, to be required also to put pollution controls on their coal plants.
Kravitz, Gregg
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.221.]
This is not 50 or 100 years ago. We're at a time in our society right now where we know, we have the science to prove the damage that not passing the Transport Rule will do, what the consequences will mean.
Again, I don't think this is political. It's a global issue, simply, do you care about your family, your friends and future generations; and if you do, you very much need to support this.
Larson, Nancy
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.109, 110-111.]
I'm here today to express my support for the proposed Transport Rule as a concerned citizen and a parent.
So it's critical that the new Transport Rule be passed to protect our health and the health of our children.
The proposed rule has already shown to have significant health benefits as you mentioned and, like green building, this will save money and improve human health rather than harming human health.
Layer, Harrison
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.76.]
I am pleased with the EPA's mission to reduce pollution. I am here to advocate for cleaner air and some issues that intersect with this issue.
Lillstrom, Aatis
Thank you for taking an important step forward in the fight against pollution by proposing the Good Neighbor Rule. As you are aware, millions of people are currently breathing air that does not meet clean air standards. Soot and smog from dirty coal plants travels downwind and affects neighboring states. This pollution causes heart attacks, asthma and lung disease. [EPA-HQ-OAR-2009-0491-1126, p.1]
Cleaning up the dirtiest plants will reduce pollution from state to state and make our air safe. I urge you to take a step further to protect the environment and public health by adopting this rule. [EPA-HQ-OAR-2009-0491-1126,p.1]
Locker, Robert
I am pleased that the EPA is acting to help states be good neighbors by reducing air pollution escaping across state lines. [EPA-HQ-OAR-2009-0491-1050, p.2]
MacNeille, Jeanette
You should put in a strong clean air transport law. I live in Pennsylvania. I saw a map once that indicated that the majority of the particulate pollution we breathe here comes from Texas. As a resident of PA, do you think I have any 'say' with -- or even access to -- legislators in Texas? I don't. We need you to put in a decent law that will protect everyone from the health effects of the old fashioned, non-innovative approaches we now use to energy production. [EPA-HQ-OAR-2009-0491-3138, p.1]
If you could walk an hour in my shoes you'd do it in a blink. Please put in strong clean air transport rule for me and for the millions like me, especially the kids. [EPA-HQ-OAR-2009-0491-3138, p.1]
Maher, Jeff
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.219-220.]
So I think it's a no brainer that this Transport Rule is a fantastic idea.
So I think this rule will do a lot by helping to regulate things that I think should have been regulated long ago. I wanted to come out and voice my support for it.
Martin, Lee
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.124.]
Please make your rules for the health of citizens and not for the bottom line of huge economic engines and coal-fired power plant companies.
Maryanski, Joseph
Thank you for taking an important step forward in the fight against pollution by proposing the Good Neighbor Rule. As you are aware, millions of people are currently breathing air that does not meet clean air standards. Soot and smog from dirty coal plants travels downwind and affects neighboring states. This pollution causes heart attacks, asthma and lung disease. [EPA-HQ-OAR-2009-0491-0505, p.2]
Cleaning up the dirtiest plants will reduce pollution from state to state and make our air safe. I urge you to take a step further to protect the environment and public health by adopting this rule. [EPA-HQ-OAR-2009-0491-0505, p.2]
Maryland Department of Environment (MDE)
The Maryland Department of Environment (MDE) appreciates the opportunity to comment on the Environmental Protection Agency's (EPA) proposed rule, "Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone (40 CFR Parts 51, 52, 72, 78 and 97)," also referred to as the "Transport Rule." Transported ozone and particulate matter pollution endanger the health of Maryland's citizens, particularly the very young and elderly, and causes lung damage, respiratory illness and premature mortality. Individuals with pre-existing heart and lung disease are particularly at risk, and in the United States as a whole in 2008, 42 million people had heart disease or asthma. [EPA-HQ-OAR-2009-0491-2639.1, p.1]
Maryland commends EPA on the Transport Rule, which, rather than being a regional cap and trade program, is a long-awaited confirmation by the EPA of the regional nature of the ozone and PM2.5 problem in the Eastern United States. Maryland has been in the forefront of conducting research and taking measurements of how long-range transport affects our state. Maryland is at the crossroads of ozone, PM2.5, and precursor transport. The prevailing westerly winds bring in air pollutants from the Midwest and the nocturnal low-level jet brings in air pollutants from the Southeastern states. We have adopted tough State measures like the Healthy Air Act to reduce local emissions that produce ozone and fine particulates, but it has not been enough. We have controlled both VOC and NOx generated in Maryland through a multitude of regulations, but continue to struggle with transported pollution at levels that are 50-75% of the current standards. To finish the job, we have lobbied tirelessly for control of emissions transported to Maryland by other states (e.g., cement kilns, ICI boilers, mobile sources, marine engines, locomotives and EGUs) to help level the playing field and achieve healthy air for our citizens. [EPA-HQ-OAR-2009-0491-2639.1, p.1]
EPA should move aggressively to require all major source categories of NOx, SO2 and mercury to, as quickly as possible, install state-of-the-art, multi-pollutant air pollution controls. In Maryland, ozone and fine particle levels drop dramatically as regional control programs for NOx and SO2 including the NOx SIP Call, early CAIR and the Acid Rain Program have been implemented. We know that regional NOx and SO2 reduction programs work and result in significantly cleaner air. [EPA-HQ-OAR-2009-0491-2639.2, p.1]
Maryland's comments address what is positive and what needs improvement in the proposed Transport Rule. Overall, Maryland agrees with the comments of NACAA and OTC. In addition, MDE agrees with EPA's timing for implementation of controls; encourages EPA to consider all transported and local pollution affecting an area on an equal cost per ton of control basis; and encourages the continued use of CAMx and CMAQ to verify Air Quality Assessment Tool (AQAT) results. Since Maryland has applied binding controls to its largest electric generating units (EGUs), we feel qualified to comment on the proposed definitions and methodology used in defining cost-effectiveness and identifying an appropriate cost threshold for controls. As a leader in transport research, we use our experience to comment on 'significant contribution' and 'interference with maintenance' by upwind states. [EPA-HQ-OAR-2009-0491-2639.1, pp.2-3]
States like Maryland that have moved ahead aggressively to control power plants and other sources are at a disadvantage for trying to clean the air when other States are not implementing the same measures. We are depending on EPA to use the Transport Rule and other authorities like the MACT requirements of the Clean Air Act to level the playing field. [EPA-HQ-OAR-2009-0491-2639.1, p.3]
Mass Comment Campaign (7,793) (Environmental Defense Fund)
I strongly support the proposed clean air plan to cut sulfur dioxide and oxides of nitrogen from eastern smokestacks. And I urge the EPA to strengthen its standards to secure greater health and environmental benefits. [EPA-HQ-OAR-2009-0491-3617_Mass, p.1]
I support these rules and urge the EPA to strengthen its standards even more to secure greater health and environmental benefits.[EPA-HQ-OAR-2009-0491-3617_Mass, p.1]
Your proposed rules to cut pollution from fossil fuel-fired power plants would reduce power plant sulfur dioxide (SO2) emissions by 71% from 2005 levels and nitrogen oxide (NOx) by 52% from 2005 levels. [EPA-HQ-OAR-2009-0491-3617_Mass, p.1]
EPA's plan to clean up this smokestack pollution would protect public health by avoiding: 14,000 to 36,000 premature deaths, 21,000 cases of acute bronchitis, 23,000 nonfatal heart attacks, 26,000 hospital and emergency room visits, 1.9 million days when people miss work or school, 240,000 cases of aggravated asthma, and 440,000 upper and lower respiratory symptoms. [EPA-HQ-OAR-2009-0491-3617_Mass, p.1]
And EPA's Rule would yield benefits of more than $120 to $290 billion annually in 2014, compared to the estimated annual costs of $2.8 billion. [EPA-HQ-OAR-2009-0491-3617_Mass, p.1]
Mass Comment Campaign (1,817) (American Lung Association)
Coal-fired power plants are among the nation's biggest polluters. The risk of death and disease a caused by coal-fired power plant pollution threatens millions of people across the country. [EPA-HQ-OAR-2009-0491-0955_Mass,p.1]
The clean-up of power plants is long overdue. I am urging EPA to strengthen the requirements on these power plants to improve air quality and protect public health. [EPA-HQ-OAR-2009-0491-0955_Mass,p.1]
Children, teenagers, senior citizens, and people with lung diseases like asthma, cardiovascular disease and diabetes are particularly vulnerable to the health effects of the ozone and particle pollution that these plants help to spread. By 2014, this rule will help to save the lives of 14,000 to 36,000 people each year. And it can prevent 26,000 hospital and emergency room visits each year. We cannot wait any longer. [EPA-HQ-OAR-2009-0491-0955_Mass,p.1]
I support the proposed EPA 'Transport Rule' which will reduce sulfur dioxide and nitrogen oxide pollution that contribute to ozone smog and particle pollution. This will save lives and improve the health of millions of people at risk from these pollutants, especially seniors, children and people with chronic lung diseases. [EPA-HQ-OAR-2009-0491-0955_Mass,p.1]
Mass Comment Campaign (20,795) (Sierra Club)
I am pleased that the EPA is acting to help states be good neighbors by reducing air pollution escaping across state lines. [EPA-HQ-OAR-2009-0491-3819_Mass,p.1]
The proposed rule will produce at least $100 billion, and possibly up to $290 billion, in public health savings, and it will prevent at least 23,000 heart attacks, 26,000 hospital visits and 240,000 asthma attacks, according to EPA estimates. In contrast, delaying action could result in up to 36,000 deaths related to dirty air. Like the highly successful acid rain program, the rule sets final clean air requirements but gives coal plants flexible options to achieve those requirements. The areas with the most cleanup to do will also realize significant benefits so that no state will bear an unfair burden. [EPA-HQ-OAR-2009-0491-3819_Mass,p.1]
This is a national problem that needs a national solution, and I urge the EPA to quickly finalize this common sense approach to protect public health and help states efficiently and cost-effectively clean up their air. [EPA-HQ-OAR-2009-0491-3819_Mass,p.1]
Mass Comment Campaign (38) (unknown organization)
I'm writing to express support for U.S. EPA's Clean Air Transport Rule and to urge the agency to do more to clean up dirty coal-fired power plant pollution by strengthening the rule. [EPA-HQ-OAR-2009-0491-3616_Mass, p.1]
EPA's proposal is a long overdue step for clean air. For decades, polluters have refused to invest in modern pollution controls. As a result, coal-fired power plants continue to be the single largest sources of air pollution in the Midwest, Illinois and Chicago. [EPA-HQ-OAR-2009-0491-3616_Mass, p.1]
On Chicago's West Side, Fisk and Crawford power plants spew well over 10,000 tons of fine particle pollution each year, causing asthma attacks, heart attacks and early deaths throughout the Midwest. A dozen coal-fired power plants, most of which still lack modern pollution controls, ring the tri-state metropolitan Chicago region. [EPA-HQ-OAR-2009-0491-3616_Mass, p.1]
Mass Comment Campaign (409) (unknown organization)
I am a concerned citizen who is in support of the proposed 'Transport Rule.' This rule will require coal burning power plants to substantially reduce their emissions, limiting the amount of ozone and particulate matter pollution that goes into the air, thus protecting the environment and health.  Inhaling ozone and fine particulate mater has been linked to health problems such as heart disease, lung cancer, asthma, bronchitis and emphysema.  By enacting this proposed rule more children would be able to grown up asthma-free, fewer adults would feel the crippling effects of heart disease and emphysema, and more people would be able to breathe clean air.
Mass Comment Campaign (600) (Sierra Club)
Thank you for taking an important step forward in the fight against pollution by proposing the Good Neighbor Rule. As you are aware, millions of people are currently breathing air that does not meet clean air standards. Soot and smog from dirty coal plants travels downwind and affects neighboring states. This pollution causes heart attacks, asthma and lung disease.[EPA-HQ-OAR-2009-0491-0135_Mass,p.1]
 Cleaning up the dirtiest plants will reduce pollution from state to state and make our air safe. I urge you to take a step further to protect the environment and public health by adopting this rule. [EPA-HQ-OAR-2009-0491-0135_Mass,p.1]
Mass Comment Campaign (679) (Greenpeace)
I am writing to support the Clean Air Transport Rule as an essential and cost-effective means of protecting public health and the climate. [EPA-HQ-OAR-2009-0491-1710_Mass, p.1]
By helping to sharply reduce emissions of sulfur dioxide and nitrogen oxides, the EPA can reduce the amount of heart attacks, asthma attacks and early deaths associated with pollution from coal-fired power plants. In the absence of a Federal cap-and-trade system, the Transport Rule represents the best chance of reducing harmful carbon dioxide emissions without an act of Congress. [EPA-HQ-OAR-2009-0491-1710_Mass, p.1]
I encourage you to resist the pressure of industry to water down this important and life-saving regulation, and applaud your leadership on this issue and your ongoing advocacy for public health and climate protection. [EPA-HQ-OAR-2009-0491-1710_Mass, p.1]
Thank you, EPA, for all you do to protect human/environmental health. [EPA-HQ-OAR-2009-0491-1710_Mass, p.1]
Massachusetts Department of Environmental Protection
We commend EPA for taking a significant step towards reducing the polluting emissions from large electric generating units (EGUs) that are transported across state boundaries. The ozone and particulate matter pollution that is formed from Nitrogen Dioxide (NOx) and Sulfur Dioxide (S02) emissions from these sources endangers the health of Massachusetts residents. Ail' pollution causes lung damage, respiratory illness and premature morbidity, with young children and the elderly at greatest risk from these health impacts. The EGU sector that EPA addresses in the proposed Transport Rule accounted for 18 percent of total nationwide NOx emissions and 66 percent of total nationwide S02 emissions in 2008. 1 Addressing emissions from this source category is essential to meeting the National Ambient Ail' Quality Standards (NAAQS) for ozone and fine particles (PM 2.5) and protecting the health of our citizens and we are gratified that EPA acknowledges this in its proposal.   [EPA-HQ-OAR-2009-0491-2787.2 p.1]
McCloskey, Natalie
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.24.]
Though we support the Clean Air Transport Rule, we would love to see stricter standards put in place. The technology is there. Utilizing only a portion of the technology is like letting us only have a portion of a breathing treatment.
McKinley, Brad
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, pp.30-35.]
Reducing diesel emissions and smog in Georgia will make life better for school children, as well as for the rest of us who live and work here. Therefore, the Atlanta Faces of Homelessness Speakers Bureau supports a strong Transport Rule to reduce one of the main sources of air pollution causing harm to Georgia's children. Thank you.
Mellinger-Birdsong, Anne
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.72 and 75.]
I will start off by saying that I am speaking in support of the proposed rule on the transport of ozone and fine particle matter.
It is clear that the interstate transport of ozone and fine particulates and the precursors of nitrogen oxide and sulfer dioxide has public health impacts and that regulating and reducing interstate transport could have major public health benefits.
Therefore, I support this proposed rule and EPA's efforts to reduce interstate transport of both ozone and fine particulates.
Menkes, Larry
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.89-90.]
If we had the Clean Air Act Now, the air protected now, we would be up in arms that the EPA would allow this much pollution. But I do think it's necessary to get to this rule.
Metropolitan Washington Air Quality Committee
  MWAQC supports the proposal to provide a remedy to the challenges faced by states under Section 110 of the Clean Air Act in meeting requirements to limit emissions that impact downwind areas. Research conducted in this region continues to show that emissions transported into our region play a significant role in formation of air pollution in our metropolitan area, and unless abated will continue to hinder our efforts to meet National Ambient Air Quality Standards (NAAQS) now and into the future. [EPA-HQ-OAR-2009-0491-2618.1, p.1]
Michetti, Susan
I strongly support the proposed clean air plan to cut sulfur dioxide and oxides of nitrogen from eastern smokestacks. And I urge the EPA to strengthen its standards to secure greater health and environmental benefits. [EPA-HQ-OAR-2009-0491-3223, p.2]
Your proposed rules to cut pollution from fossil fuel-fired power plants would reduce power plant sulfur dioxide (SO2) emissions by 71% from 2005 levels and nitrogen oxide (NOx) by 52% from 2005 levels. [EPA-HQ-OAR-2009-0491-3223, p.2]
EPA's plan to clean up this smokestack pollution would protect public health by avoiding:
14,000 to 36,000 premature deaths,
21,000 cases of acute bronchitis,
23,000 nonfatal heart attacks,
26,000 hospital and emergency room visits,
1.9 million days when people miss work or school,
240,000 cases of aggravated asthma, and
440,000 upper and lower respiratory symptoms. [EPA-HQ-OAR-2009-0491-3223, p.2]
And EPA's Rule would yield benefits of more than $120 to $290 billion annually in 2014, compared to the estimated annual costs of $2.8 billion. [EPA-HQ-OAR-2009-0491-3223, p.2]
I support these rules and urge the EPA to strengthen its standards even more to secure greater health and environmental benefits. [EPA-HQ-OAR-2009-0491-3223, p.2]
Mid-America Regional Council (MARC) Air Quality Forum
  The Forum strongly supports the concept of regulating interstate transport of pollutants and agrees with the need to provide states with federal tools to deal with this issue. Interstate transport is a considerable source of ozone precursor emissions in the Kansas City area, which is itself a bi-state region. Based on local photochemical modeling, fully one-third of Kansas City's ozone precursor emissions are transported from other areas. [EPA-HQ-OAR-2009-0491-2613.1, p.1]
Mills, Mary
Thank you for taking an important step forward in the fight against pollution by proposing the Good Neighbor Rule. As you are aware, millions of people are currently breathing air that does not meet clean air standards. Soot and smog from dirty coal plants travels downwind and affects neighboring states. This pollution causes heart attacks, asthma and lung disease. [EPA-HQ-OAR-2009-0491-1088, p.1]
Cleaning up the dirtiest plants will reduce pollution from state to state and make our air safe. I urge you to take a step further to protect the environment and public health by adopting this rule. [EPA-HQ-OAR-2009-0491-1088, p.1]
Minnesota Pollution Control Agency (MPCA)
The MPCA would like to commend EPA for the way in which the proposed Transport Rule responds to the myriad concerns that the D.C. Circuit Court of Appeals raised over the Clean Air Interstate Rule (CAIR). The overall framework does an admirable job in ensuring that the rule will adequately address the specific state-to-state impacts of transported pollutants, so that covered states fulfill their obligations under 110(a)(2)(D), the Clean Air Act's 'good neighbor' provision. [EPA-HQ-OAR-2009-0491-2521.1, p.1]
Mothers and Others for Clean Air
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.18.]
We would like to commended EPA for its efforts to reevaluate clean air standards and develop new rules that will lead to reductions in harmful emissions. Georgia needs federal leadership to meet its clean air goals.
National Association of Clean of Air Agencies (NACAA)
Areas Where NACAA Generally Supports EPA's Approach in the Transport Rule
We appreciate EPA's efforts to thoughtfully address the court decision 1 that overturned the previous transport rule  -  the Clean Air Interstate Rule (CAIR)  -  and to quickly put in place a rule that limits NOx and SO2 emissions from power plants in the Northeast, Mid-Atlantic, Southeast and Midwest on a timeframe that helps states meet their attainment deadlines. We will highlight here several aspects of the proposed Transport Rule that we generally support:  [EPA-HQ-OAR-2009-0491-2771.1, p.2; For additional comments pertaining Areas Where NACAA Generally Supports EPA's Approach in the Transport Rule see page 2 of this comment]

Footnote:
1 North Carolina v. EPA 531 F.3d 896 (DC Cir. 2008) (court decision vacating CAIR) and North Carolina v. EPA, 550 F.3d 1176 (DC Cir. 2008) (court decision remanding CAIR in lieu of vacatur).
National Resources Defense Council (NRDC)
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, p.40.]
I am here today both to commend the EPA on its proposal to significantly reduce emissions of sulfur dioxide and nitrogen oxide for coal-fired power plants and also to encourage the EPA to go even further in reducing emissions in its final rule.
U.S. EPA's proposed regulations are both necessary and timely and should be strengthened in order to realize the enormous potential health benefits that will accrue from ensuring the nation's ambient air quality standards are achieved throughout the country.
Nederhand, Frank
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, pp.126-127.]
We're pleased that EPA is acting to help states be good neighbors by reducing air pollution that crosses state lines. We applaud this common-sense approach by Lisa Jackson and the EPA to effectively protect public health and help states clean up their air efficiently and cost effectively. We support the Transport Rule and ask that it be strengthened.
New Jersey Business and Industry Association
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.95-96.]
As we're looking at this rule and having businesses in nonattainment areas, which are downwind, we basically see our businesses paying a pollution tax. As we're already at a disadvantage because of the fact that our companies are subject to state regulations, that other states are not, we're incurring more costs.
So we see this as a way that we can control emissions in other states and help our states businesses be able to reduce some of their costs as well.
New Jersey Department of Environmental Protection (NJDEP)
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.156.]
I would like to first applaud USEPA for their effort to address the flaws in the Clean Air Interstate Rule, CAIR.
New York State Department of Environmental Conservation
This proposal makes many improvements over the Clean Air Interstate Rule (CAIR) that it is intended to replace. For example, we strongly support the retirement of allowance banks and EPA's decision to restrict interstate trading. In addition, we applaud EPA for its development of a framework for expeditiously addressing transport when EPA issues future NAAQS. [EPA-HQ-OAR-2009-0491-2730.1, p.1]
NextEra Energy, Inc.
Overall, NextEra Energy supports EPA's proposed Transport Rule because it will achieve important air quality and health benefits. In our view, it is critical that EPA implement the rule as expeditiously as practicable, and we are committed to supporting EPA's implementation of the Transport Rule by January 1, 2012. [EPA-HQ-OAR-2009-0491-2718.1, p.1]
The fundamental purpose of the Transport Rule is to address the Section 110(a)(2)(D)(i)(1) requirement that states do not contribute significantly to nonattainment in, 01' interfere with maintenance by, any other state with respect to any primary or secondary national ambient air quality standard (NAAQS). Several of NextEra Energy's power plants operate in downwind states where the transport of emissions from upwind states contribute significantly to nonattainment with the ozone and fine particulate (PM2.5) NAAQS. Our company has made substantial investments in clean energy technologies and advanced emission control technologies to improve the air quality in the areas in which we operate. Despite these efforts, however, transported pollution from upwind states prevents many of these areas from meeting air quality standards. [EPA-HQ-OAR-2009-0491-2718.1, pp.1-2]
Northeast States for Coordinated Air Use Management (NESCAUM)
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.8-9.]
NESCAUM congratulates EPA on issuing the proposed Clean Air Transport Rule. We support establishing a framework to address transported air pollution that will assist states in meeting national ambient air quality standards, or NAAQS. Transported air pollution continues to have a significant impact on NESCAUM states, as we strive to achieve clean air. Thus, a framework to address it is important to us.
Today, in 2010, we're discussing a proposal to address the 1997 ozone and annual PM 2.5 NAAQS, and 2006 24-hour PM 2.5 NAAQS. This proposal is welcomed, but it is long in coming. States are already well into planning to further improve air quality and build upon past successes that have integrated regional approaches with state-based planning.
Based on our past experiences, we urge EPA to promulgate future transport rules concurrent with finalizing new national air quality standards. This would provide states with the critical information they need up front to develop and submit approvable plans within the required three years after an air quality standard is promulgated. The result will be timely, effective pollution reductions that produce cleaner air sooner for the public and the environment.
We applaud several aspects of the proposed framework.
NRG Energy
NRG supports EPA's efforts to improve air quality, address the legal inadequacies of the Clean Air Interstate Rule (CAIR) and offer a degree of flexibility for the electric generating units (EGUs). We offer these comments to provide NRG's insight on options discussed in the proposed rule, recommended changes that could improve implementation while maintaining legal defensibility, and provide corrections to assumptions in the EPA database for NRG plants. [EPA-HQ-OAR-2009-0491-2749.1, p. 1]
NRG commends EPA's effort to release a proposed Transport Rule. The Transport Rule addresses the legal requirements established by the D.C. Circuit's decision North Carolina v. EPA, provides health benefits to the public, and a sense of certainty to companies as they plan for the future. [EPA-HQ-OAR-2009-0491-2749.1, p. 3]
Oren, Craig N.
This is an important rulemaking, particularly since the Carper/Alexander legislation to reduce interstate air pollution has been delayed until at least 2011. The health consequence of transport are horrific, as the proposed rule document. [EPA-HQ-OAR-2009-0491-2644-cp, p.1]
Ozone Transport Commission (OTC)
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.111 & 114.]
By controlling emissions from these sources under the Transport Rule, EPA is achieving badly needed public health benefits that are long overdue utilizing the most cost-effective reductions available.
We, therefore, urge EPA to strengthen this Transport Rule, particularly in the areas we will now discuss, to provide greater public health protection in a more timely manner.
Parrish, Jr., Joseph
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.14-15.]
Any additional EPA regulations to control SOX and ozone of carbon based power plants when finally put into effect will directly and immediately improve lung health on the eastside of Manhattan that I oversee and the westside of Queens.
Cleaning up power plants will save lives. EPA estimates that just the reductions in the proposed Transport Rule will save between 14,000 and 36,000 lives a year by the year 2014. I think that is a low-ball estimate. Particle pollution and ozone smog cause coughing and wheezing, trigger asthma attacks, send people to the emergency rooms and cause heart attacks and strokes, as well as premature death.
Pendleton, Mark
I encourage the EPA to reconsider the proposed rule related to the Interstate Transport of Fine Particulate Matter and Ozone. [EPA-HQ-OAR-2009-0491-1596, p.1]
I support the agency's efforts to reduce the amount of sulfur dioxide and nitrogen oxide in the atmosphere. [EPA-HQ-OAR-2009-0491-1596, p.1]
Pennsylvania Department of Environmental Protection
The Pennsylvania Department of Environmental Protection (DEP) appreciates the opportunity to submit comments on the U.S. Environmental Protection Agency's (EPA) proposed rule entitled the 'Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone, published in the Federal Register on August 2, 20I0, at 75 Fed. Reg. 45,210. The proposed rule, known as the 'Transport Rule' or 'TR,' requires electric generating units (EGUs) in 31 states including the Commonwealth of Pennsylvania and the District of Columbia to substantially improve air quality by reducing nitrogen oxide (NOx) and sulfur dioxide (SO2) emissions in downwind areas that contribute significantly to nonattainment or interfere with maintenance of the 1997 ozone and the annual fine particulate matter (PM2.5) national ambient air quality standards (NAAQS) and the revised 2006 24-hour PM2.5 NAAQS. EPA has proposed Federal Implementation Plans (FIPs) for the immediate implementation of the final Transport Rule. [EPA-HQ-OAR-2009-0491-2660, p.1]
According to EPA projections, 'the proposed TR and other state and EPA actions would reduce power plant SO2 emissions by 71 percent over 2005 levels. Power plant NOx emissions would drop by 52 percent.' The final TR will replace the 2005 Clean Air Interstate Rule ('CAIR') and FIPs promulgated by EPA on May 12,2005, and April 28, 2006, respectively. (70 Fed. Reg. 25,162; 71 Fed. Reg. 25,328). [EPA-HQ-OAR-2009-0491-2660, p.1]
The DEP commends EPA's efforts to remedy the flaws in the CAIR, vacated in its entirety (including the FIPs) by the U.S. Court of Appeals for the District of Columbia Circuit ('DC Circuit' or 'Court') on July 11, 2008.' The 'fundamentally flawed' CAIR was remanded to EPA on December 23, 2008, for revisions consistent with the DC Circuit's July 2008 opinion? Despite several major flaws in the CAIR, EPA approved the Commonwealth's CAIR as a revision to Pennsylvania's State Implementation Plan (SIP) on December 10, 2009 (74 Fed. Reg. 65,446). Under the CAIR, annual NOx emissions from EGUs in Pennsylvania decreased by approximately 64,000 tons in 2009. Prior to the 2010 compliance date, S02 emissions decreased by an estimated 249,000 tons. [EPA-HQ-OAR-2009-0491-2660, pp.1-2]
The DEP believes that the proposed Transport Rule, which establishes FIPs to reduce the transport of NOx and SO2 emissions, will allow the Commonwealth to continue to make great strides in protecting public health and the environment. The projected emission reductions are expected to result in significant annual health benefits in Pennsylvania and other states in the Transport Rule region. [EPA-HQ-OAR-2009-0491-2660, p.2]
[These comments were also submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.50.]
Pennsylvania Energy Alliance
Therefore, we strongly support the proposed Air Pollution Transport Rule requiring power plants to regulate the amount of harmful emissions released into the air. Doing so will help states like Pennsylvania meet their obligations to reduce transported pollution and maintain compliance with the national ambient air quality standards. Protecting Pennsylvania's environment and our citizens' public health from air pollution is of the utmost importance, and we believe the proposed improvements on the Clean Air Interstate Rule are necessary. The PA Energy Alliance urges the EPA to finalize and begin implementation of the Transport Rule. [EPA-HQ-OAR-2009-0491-0084,. p.2]
Peoria Families Against Toxic Waste
[These comments were submitted as testimony at the Chicago, Illinois public hearing on August 19, 2010.  See Docket Number EPA-HQ-OAR-0491-1746, p.111.]
And I am in favor, strongly in favor of this rule but think it needs to be stronger.
Pew Environment Group
More than a decade ago, EPA promulgated the 1997 air quality standards for fine particulate matter and 8-hour ozone. A more protective PM standard was established in 2006. Today, however, many areas throughout the East and Midwest continue to exceed these health-based standards. The problem would be much worse if many power plants had not reduced their emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx) over the past 5 years. In fact, national power plant emissions of sulfur dioxide were 10.3 million tons per year as recently as 2004. Last year, they had fallen to 5.7 million tons, a drop of nearly 50 percent in five years. This reduction is due to a number of factors, including New Source Review enforcement actions and state regulations, as well as EPA's 2005 Clean Air Interstate Rule. [EPA-HQ-OAR-2009-0491-2703.1 p.1]
While this success should be applauded, today's pollution levels still lead to over 13,000 premature deaths and there are still approximately 700 coal-fired units in the U.S. operating with no sulfur scrubber in place. At this point, every coal-fired plant in the U.S. should be well-controlled. That is why it is so important for EPA to strengthen and finalize the proposed Transport Rule. First, it will lock in the gains we have made in the last 5 years. Second, the Transport Rule goes farther than CAIR in 15 states and should allow many nonattainment areas in the East to reach attainment of federal air quality standards (mostly particulate matter, or PM). [EPA-HQ-OAR-2009-0491-2703.1 p.1]
The direct link between power plant emissions and human health has been documented extensively, and much of it has been reviewed and included in formal rulemakings and regulatory analysis by EPA. For the last decade, public health concerns have focused on very small airborne particles that have been found to cause or contribute to respiratory and cardiopulmonary diseases as well as the increased risk of premature death. Unfortunately, elevated levels of fine particles are persistently present and common across large portions of the country.  [EPA-HQ-OAR-2009-0491-2703.1 p.1]
Pietrzak, Karl
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.223.]
The only thing I want to say is I am supportive of the rule because it is not fair for different communities just to have the geographical disadvantage of shear existence.
Pilsen Environmental Rights and Reform Organization (PERRO)
[These comments were submitted as testimony at the Chicago, Illinois hearing.  See Docket Number EPA-HQ-OAR-0491-1746, pp.44 & 47.]
PERRO is our acronym, and we are here to support the Transport Rule as a first step in hopefully what will be a much more evolved process of reducing power plant pollution.
So, obviously, this Transport Rule is a good step in the overall process of dealing with these pollution sources.
Plumb, James
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, pp.172-173.]
It's my responsibility as a physician to advocate for my patients and my students by strongly supporting the Clean Air Transport Rule. Without this rule, an immediate and direct threat to the children, elderly, the poor and vulnerable citizens of Philadelphia remains. Not to implement this rule is a socially irresponsible action and will lead to numerous missed days of work and school, preventable illness and deaths.
Province of Ontario, Canada
We believe that the Transport Rule is sound environmental policy, and we commend the U.S. EPA for this proposed course of action.  [EPA-HQ-OAR-2009-0491-2610.1, p.1]
The Transport Rule will require significant reductions in the emission of nitrogen oxides (NOx) and sulphur dioxide (SO2) from electricity generating units (EGUs) in 31 states and the District of Columbia. The Transport Rule, intended to reduce the interstate transport of ozone and fine particulate matter in the eastern U.S., will also reduce the international transport of these pollutants to Ontario. Scientists at the Ontario Ministry of the Environment (MOE) believe that the reductions required by the Transport Rule will result in improved air quality in the Province of Ontario. The result will be better protection for human health and the environment on both sides of the border. [EPA-HQ-OAR-2009-0491-2610.1, p.1]
We fully support the u.s. EPA's proposed Transport Rule. The reductions required by the Transport Rule will reduce both the interstate transport of air pollution within the U.S. and the international transport of air pollution to Ontario. We urge the u.s. EPA to finalize and implement the Transport Rule as expeditiously as possible. If the U.S. EPA takes that action, citizens on both sides of the border will breathe a little easier. [EPA-HQ-OAR-2009-0491-2610.1, p.3]
Pryde, Coralie
The cost of installing equipment to reduce pollutants from smokestacks is very small compared to the vast cost of the health problems caused by ozone and particulate matter. But the owners of the coal-fired plants don't care because they don't pay for the health costs. They argue that the states shouldn't force them to 'clean up their act' because it will make their electricity uncompetitive with that from neighboring states. The only logical answer is to have federal regulation. I strongly support the Transport Rule. [EPA-HQ-OAR-2009-0491-0981, p.1]
PSEG Services Corporation
Overall, PSEG supports the proposed rule because it will achieve important air quality and health benefits. It is critical that EPA implement the rule as expeditiously as practicable, and we are committed to supporting EPA's implementation of the Transport Rule by January 1, 2012. [EPA-HQ-OAR-2009-0491-2726.1, p.2]
In conclusion, PSEG supports the implementation of this program and believes it can be accomplished by January 1, 2012 without negative impacts on electric system reliability. Although our preference would have been to incorporate the Acid Rain Title IV allowance system into this program, PSEG understands the constraints imposed. Thus, PSEG is supportive of the overall framework of preferred option for unlimited intra-state and limited interstate emission trading and the assurance provisions as proposed but strongly recommends that EPA modify the unit allocation methodology which in effect rewards higher emitting facilities at the expense of other companies, like PSEG, who have committed early investments to control emissions. [EPA-HQ-OAR-2009-0491-2726.1, pp.11-12]
Public Interest Law Center of Philadelphia
[These comments were submitted as testimony at the Philadelphia, Pennsylvania public hearing on August 26, 2010.  See Docket Number EPA-HQ-OAR-2009-0491-1938, p.124.]
These reductions would represent significant progress toward finally achieving attainment standards for PM 2.5 standard. Although these cuts could and should be deeper, particularly with respect to nitrogen oxide, and could and should cover more sources, the welcome public health and environmental benefits from the proposed reductions in these dangerous pollutants are unmistakable, and will far outweigh the costs of compliance with the Transport Rule.
Rennes, Beth
[These comments were submitted as testimony at the Atlanta, Georgia public hearing on September 1, 2010.  See Docket Number EPA-HQ-OAR-0491-1939, p.81.]
So I'm here to support the proposed Transport Rule.
Republicans for Environmental Protection
The job of securing cleaner air for America's families and communities, however, is not complete. A significant fraction of the coal-fired power plants that generate about half the electricity used in America lack equipment to control emissions of pollutants that create ozone smog and tiny particulates, which are known respiratory and cardiac health hazards. [EPA-HQ-OAR-2009-0491-1892.1, p. 1] The Environmental Protection Agency's proposed Clean Air Transport Rule, which would reduce emissions of sulfur dioxide and nitrogen oxides by 71 percent and 52 percent, respectively, in 31 states east of the Rocky Mountains and in the District of Columbia, would result in significant public health benefits. [EPA-HQ-OAR-2009-0491-1892.1, p. 1] The rule, scheduled to take effect in 2012, would deliver up to $290 billion worth of health and public welfare benefits in 2014 alone, including avoidance of 14,000 to 36,000 premature deaths. Compliance costs would total $2.8 billion annually, far less than the value of the benefits. [EPA-HQ-OAR-2009-0491-1892.1, p. 1]