Comment submitted by Natural Resources Defense Council et al. (Part IV)

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Summary: A coalition of environmental and public health organizations argues that the EPA's proposal to allow construction of non-pollutant-emitting components before obtaining a permit is illegal, arbitrary, and contrary to the Clean Air Act. They contend that such a rule would undermine the New Source Review (NSR) program by allowing facilities to bypass rigorous preconstruction reviews of site impacts and by physically or economically foreclosing the feasibility of required Best Available Control Technology (BACT).
Part IV of joint comments of Natural Resources Defense Council, Clean Air Task Force, Clean Air Council, Earthjustice, Environmental Defense Fund, Environmental Integrity Project, Kentucky Resources Council, Southern Environmental Law Center, Sierra Club, Environmental Protection Network, and Food & Water Watch. Additional exhibits follow.

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