EPA Northern Wasatch Front Reconsideration and Clean Air Act §179B(b) Determination

Prime Mover Institute respectfully submits these comments in support of EPA’s proposed determination, under Clean Air Act § 179B(b), that the Northern Wasatch Front would have attained the 2015 ozone NAAQS by its Moderate attainment date but for emissions emanating from outside the United States.1 The proposal correctly makes three changes to restore its evaluations under § 179B(b) to the text of the statute: it no longer requires a State to show that it could not attain even after adopting all reasonably available controls; it no longer treats a demonstration as more persuasive when international contributions exceed domestic ones; and it no longer treats an area’s distance from an…