Alliance for Green Heat, January 4, 2013 - A number of organizations have been formally weighing in with the EPA well ahead of the much anticipated 90 day comment period that starts when the New Source Performance Standards (NSPS) is finally published in the Federal Register. To be fair, the organizations are mostly calling on the EPA to move quicker and finalize the NSPS, but they also contain many substantive recommendations for the NSPS.
Letters from the American Lung Association (ALA), the Economic Council of States and NESCAUM and WESTAR can be publicly found on the internet, but far more detailed recommendations and lobbying between HPBA, ALA, NESCAUM, states and EPA is not very transparent. An enormous amount of communication, positioning, chest pounding and all other manner of persuasiveness has intensified this fall as the EPA has re-opened the door for changing the draft NSPS. The last we heard, the NSPS was going to OMB in January, and they would review it for 90 days before publishing it in the spring.