Comment submitted by Great Lakes Environmental Law Center on the Proposed Approval of the Detroit, Michigan 2015 8-Hour Ozone Determination of Attainment by the Attainment Date

Summary: The Great Lakes Environmental Law Center, Sierra Club, and Air Law for All, Ltd. are submitting comments on behalf of several organizations and residents who oppose the EPA's proposed approval of Michigan's ozone attainment. They argue that the EPA is improperly using a belated "exceptional event" demonstration to retroactively revise ozone design values and bypass the Clean Air Act's strict statutory deadlines.