Comment submitted by South Coast Air Quality Management District (South Coast AQMD)

Summary: The South Coast Air Quality Management District (a regional air quality agency) opposes the proposed rule, arguing that it allows construction to proceed without a permit, thereby shifting regulatory uncertainty to a later, more costly stage of development. They contend that the revisions favor industry preferences over the "best reading" of the Clean Air Act and could undermine the effectiveness of Best Available Control Technology (BACT) reviews.