Karen Feridun
100 signatures reached
To: EPA Administrator Lee Zeldin
EPA Administrator Zeldin, Don't Silence the Public
Since 1977's amendment to the Clean Air Act, the New Source Review (NSR) permitting process has served as a pre-construction environmental review of proposed plans for new or modified industrial facilities that would cause a "substantial increase" in emissions of regulated pollutants. The NSR has allowed regulators to determine what, if any, steps can to be taken to eliminate or mitigate the pollution before construction begins.
Administrator Zeldin, you are proposing a redefinition of the concept of "begin actual construction" to allow for construction of non-polluting parts of a facility before the project is permitted. You say you are "fixing the broken system of government interference," but you are really undermining the power of the Clean Air Act to protect the public.
Your proposal also effectively cuts the public out of the decision-making process. The public participation process is triggered by a project entering into its permitting phase. Allowing a project's owner to "begin actual construction" prior to that phase means the public would not have an opportunity to comment until much of the project is completed.
Although your proposal says that owners are assuming the risk that a project may ultimately be denied, owners would likely argue that their projects have come too far to stop them.
For these reasons, we, the undersigned, urge you to abandon your proposed changes to the Clean Air Act.
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Administrator Zeldin, you are proposing a redefinition of the concept of "begin actual construction" to allow for construction of non-polluting parts of a facility before the project is permitted. You say you are "fixing the broken system of government interference," but you are really undermining the power of the Clean Air Act to protect the public.
Your proposal also effectively cuts the public out of the decision-making process. The public participation process is triggered by a project entering into its permitting phase. Allowing a project's owner to "begin actual construction" prior to that phase means the public would not have an opportunity to comment until much of the project is completed.
Although your proposal says that owners are assuming the risk that a project may ultimately be denied, owners would likely argue that their projects have come too far to stop them.
For these reasons, we, the undersigned, urge you to abandon your proposed changes to the Clean Air Act.
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Why is this important?
The proposed changes to the Clean Air Act would apply to all industrial facilities, including data centers, the power plants that would serve them, chemical plants, and carbon, capture, and storage (CCS) facilites. While the proposed changes are considered a win for all industries, we mention CCS specifically because owners of those projects can qualify for 45Q tax credits if they begin construction by a deadline set by the IRS. Being able to begin construction before the permitting process guarantees that they would be able to meet the deadline.
We are submitting this petition to the EPA's docket and sending it to the Trump administration. We ask that you take a couple of extra minutes to submit a comment to the docket using our EZ form. Regulators generally count petitions as one comment, regardless of how many signatures they contain, so filling the docket with individual comments is important. Our form asks you to write opening and closing statements and, if you wish, select talking points we provide. We format your comments as PDF files and upload them to the docket for you. If you prefer, you can submit a comment directly to the docket by visiting Regulations.gov.
We are submitting this petition to the EPA's docket and sending it to the Trump administration. We ask that you take a couple of extra minutes to submit a comment to the docket using our EZ form. Regulators generally count petitions as one comment, regardless of how many signatures they contain, so filling the docket with individual comments is important. Our form asks you to write opening and closing statements and, if you wish, select talking points we provide. We format your comments as PDF files and upload them to the docket for you. If you prefer, you can submit a comment directly to the docket by visiting Regulations.gov.
How it will be delivered
Electronically on June 29th