Declaration in Support of Final EPA Good Neighbor Plan
This project for Environmental Defense Fund had three components. Two were written statements intended for submission to circuit courts in support of EPA's Final Good Neighbor Plan to achieve the 2015 Ozone National Ambient Air Quality Standards. The first statement focused on presenting analysis in support of the rule's structure and goals across all affected states. The second focused specifically on Utah and was intended to provide deeper analysis. The final component of this project was separate analysis of EPA's proposed greenhouse gas emission standards for new and existing power plants. This analysis, which focused on how different standards in the proposed rule will affect gas units, was filed as an attachment to EDF's comments in the proposed rule's regulatory docket in 2023.