Comment submitted by Malin Moench

Summary: Malin Moench opposes the proposed rule to redefine "begin actual construction," arguing that it undermines the Clean Air Act by allowing developers to commit significant capital before environmental reviews are complete. The commenter contends that this change creates "sunk-cost bias," pressures regulators to approve permits for already-built structures, and unfairly favors fossil-fuel infrastructure over faster, cheaper renewable energy solutions.