Comment submitted by American Public Power Association (APPA)
AnonymousSupportTrade association
Summary: The American Public Power Association (APPA), representing community-owned utilities, supports the EPA's proposed rule to allow construction of non-emitting components before an NSR permit is issued. They argue that the proposal reduces project delays and costs while maintaining environmental protections, and they recommend further clarifying specific definitions and providing more examples of permissible pre-permit activities.
Comments of the American Public Power Association on EPA’s Proposed Rule Begin Actual Construction in the New Source Review Preconstruction Permitting Program