The US Environmental Protection Agency (EPA) is currently accepting comments on its recently proposed Transport Rule. The rule is designed to limit the amounts of sulfur dioxide (SO2) and nitrogen oxides (NOX) that can be emitted by power plants in 31 states east of the Rocky Mountains plus the District of Columbia. Both sulfur and nitrogen are the main causes of acid rain, which has been devastating the Adirondack Park for decades.

The History
In 2004, EPA proposed the Clean Air Interstate Rule or CAIR. CAIR was finalized by EPA in early 2005 and was immediately challenged in court. In late 2008, the US District Court for the D.C. Circuit ruled that CAIR was flawed, but would remain in effect until EPA could come up with a new regulation to meet the court’s requirements. EPA proposed the Transport Rule in response to the 2008 court decision.

The Proposal
The new Transport Rule is based on the CAIR rule, but uses a different approach to ensure that each state does its part to reduce the impact it has on air quality of downwind states and their ability to meet federal air quality standards. The Transport Rule would go into effect in 2012 with three programs, one for SO2, one for annual NOX and another for ozone-season (summer months) NOX reductions. In addition, a second phase of SO2 reductions for 15 states that significantly impact the air quality of neighboring states will go into effect in 2014.

Unlike CAIR, the Transport Rule requires each state to cut its own emissions by a specific amount. This is accomplished by allowing very limited trading of emissions allowances between states. Unlimited trading of allowances will still be permitted within an individual state.

EPA Accepting Comments
It is important that EPA hear from you and that your comments are your own. Mass pre-formatted emails are simply counted as a single response sent in numerous times. In your own words, please make these three points:

• Thank EPA for proposing the Transport Rule. Let them know how important the Adirondack Park is to you and that you want to save the Park from further damage by acid rain.
  
  
• Urge the EPA to make deeper cuts to NOX emissions. For this rule, EPA is using old 1997 data for NOX reductions, instead of a better 2008 standard. While it is currently being revised and will require a future change to the Transport Rule, the newer, more stringent 2008 standard should be used to develop this rule.
  
  
• Tell EPA to keep the 2012 and 2014 deadlines as they have proposed. Industry representatives will be lobbying to weaken these deadlines by moving them farther out into the future. EPA needs to know we can’t delay getting cleaner air and a better environment.

Please be sure to send your comments as soon as possible. If you have any questions, please feel free to call or e-mail us. Also, please send or e-mail us a copy of your correspondence, if possible. Thank you for your help and support!