Comment submitted by Shumaker Loop & Kendrick, LLP on the Proposed Approval of the Ohio Air Nuisance Rule Removal

Summary: The Ohio Utilities and Generation (OUG), a trade association representing electric utilities, supports the proposed removal of the Air Nuisance Rule from Ohio's State Implementation Plan. They argue that the rule serves no purpose for meeting air quality standards and that its removal is both legally required by state law and long overdue.