STRONGER Air Guidelines Earthworks comments

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From the letter:

Earthworks especially appreciates three aspects of the AQG’s general approach. First, they recommend states implement the Environmental Protection Agency (EPA)’s 2016 methane rule (40 CFR Part 60, Subpart OOOOa or “methane rule”). The AQGs also recognize the methane rule’s limitations, especially as it applies to state-specific needs.

For this reason, we also commend STRONGER for emphasizing how each federal Clean Air Act regime provides the regulatory floor upon which states build a suitably tailored oil and gas air program (i.e., Title V (major sources), National Ambient Air Quality Standards (NAAQS), New Source Performance Standards (NSPS), etc.). To accomplish this, the public, agencies, and regulated community should have the best understanding of which sources pollute the most.

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