Comment submitted by Baker Botts LLP
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Summary: Matt Kuryla of BAKER BOTTS LLP supports the EPA's proposal to rescind the January 2025 reclassification rule, arguing it aligns with the Clean Air Act. However, the commenter requests that the EPA act separately to rescind past reclassifications, formally amend rules regarding sanctions clocks, and establish a default SIP submittal deadline of at least 18 months.
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