Comment submitted by Harris County Attorney’s Office (HCAO)

Summary: The Harris County Attorney's Office opposes the proposed rule, arguing that the new interpretation of State Implementation Plan (SIP) requirements will disincentivize states from meeting ozone NAAQS deadlines and delay air quality improvements. They contend that the proposal allows states to avoid past obligations, which undermines the Clean Air Act's goal of protecting public health and achieving expeditious attainment.