On March 25, 2024, WESTAR submitted a comment letter to EPA on their proposed rule regarding large municipal waste combustors. WESTAR commented specifically in favor of the proposal to exclude air curtain incinerators from Title V requirements when they are used to burn wood waste, yard waste, and clean lumber and are not located at a major source or subject to title V for other reasons.
On July 5, 2023, WESTAR submitted a comment letter to EPA on the proposed rule to reduce GHG and criteria pollutants from model year 2027 and later light-duty and medium-duty vehicles.
On February 13, 2023, WESTAR submitted comments to EPA on the supplemental notice of proposed rulemaking: “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review”, published in the Federal Register on December 6, 2022. This supplemental proposal is extensive and, if finalized, would update, strengthen, and expand the methane gas standards that affect oil and gas operations. WESTAR states shared their perspectives on how this proposed rule relates to and/or affects meaningful engagement, EPA’s ambitious regulatory agenda for 2022/2023, funding concerns, and resource constraints. The rule proposes several elements, including a “super-emitter response program” that western states, locals, and Tribes need further clarification on from EPA, knowing that this program, in particular, trends away from the usual delegation of authority to the state, local, or Tribal air agencies that the Clean Air Act is built on. For more information, see the rulemaking docket, found here.
WESTAR comment letter on EPA supplement to proposed Standards of Performance for Oil and Natural Gas–February 2023
WESTAR submitted two comment letters to EPA on IRA docket questions on January 19, 2023. The first responded to overall questions about the IRA funds. WESTAR encouraged EPA to utilize established pathways for regional coordination and communications between western state, Tribal, and local air agencies that exist at WESTAR. WESTAR also encouraged EPA to provide additional technical assistance and training, especially when most state agencies are understaffed. Finally, WESTAR encouraged EPA to consider the geographic obstacles to reaching communities in the west; there are additional costs for travel and time associated with reaching disadvantaged, rural communities in the west. These additional costs must be factored into funding. There are also communications challenges in areas of the west where broadband internet access is unavailable.
WESTAR’s second letter addressed IRA docket questions related to residential wood heating. WESTAR supports funding for independent testing of wood heating devices in certified laboratories using newer test methods. This independent testing would supplement EPA’s current certification program, which has relied on testing results that haven’t been reproducible in other labs. The need for transparency in test results is more important with EPA’s proposal for a more stringent PM2.5 NAAQS; additional counties in the west could be nonattainment for fine particulate matter if the proposal is finalized. This will lead states to analyze wood heating emissions possibly contributing to nonattainment in the rural west and needing data to determine the potential effectiveness of change-out programs.
Western States Air Resources Council
(WESTAR)
1925 Aspen Dr.
Suite 600A
Santa Fe, NM 87505
Phone: (505) 954-1160
Fax: (505) 954-1216
