Ozone Reclassification State Implementation Plan Rule

The Prime Mover Institute, a public interest organization, supports the proposed rule because it correctly interprets the Clean Air Act to mean that reclassified ozone nonattainment areas are governed by their current classification's requirements. They also argue that the EPA should explicitly confirm that these reclassified-area plans can incorporate Section 179B to provide relief for areas affected by international emissions.

The Indiana Department of Environmental Management (IDEM) supports the proposed Ozone Reclassification Rule as it provides regulatory flexibility and a more consistent landscape for states. However, they request a 30-day comment period extension and urge the EPA to also rescind previous "bump ups" for the 2015 ozone NAAQS.

A coalition of environmental and public health advocacy organizations opposes the EPA's Ozone Reclassification State Implementation Plan Rule. They argue the proposal is unlawful, undermines the Clean Air Act's public health protections, and allows states to indefinitely delay meeting ozone standards by effectively erasing missed deadlines through reclassification.

A coalition of public interest organizations is opposing the EPA's Ozone Reclassification State Implementation Plan Rule, arguing it is legally deficient and unlawfully allows states to defer air pollution controls. They contend that the Clean Air Act requires a cumulative, graduated classification scheme where lower-level requirements serve as a mandatory baseline for all nonattainment areas.

A coalition of public interest organizations submitted legal and technical comments opposing the EPA's proposal. The submission includes a scientific study demonstrating that even low-level ozone exposure during exercise can cause significant declines in pulmonary function.

The Oregon Department of Environmental Quality (DEQ) opposes the proposed rule, arguing that it fails to adequately address Clean Air Act anti-backsliding requirements and could lead to worsened air quality. The agency contends that the proposal does not actually reduce administrative burdens but instead forces states to rework emissions control strategies due to other federal deregulatory actions.

The Maryland Department of the Environment opposes the proposed rule, arguing it creates a loophole that allows states to avoid sanctions and FIPs for delinquent SIP submissions by seeking reclassification. They also contend that the proposal fails to account for the increased stringency of requirements associated with higher nonattainment classifications.

The California Air Resources Board (CARB) opposes the proposed Ozone Reclassification State Implementation Plan Rule, arguing that it relaxes Clean Air Act requirements and could lead to delayed emission reductions and backsliding in air quality. They contend that the proposal is vague, exceeds agency authority, and prioritizes administrative efficiency over significant public health benefits.

The Wyoming Department of Environmental Quality (WDEQ) supports the proposed rule to streamline nonattainment area planning for outdated ozone standards. They request that the EPA also explore similar streamlining approaches for areas that meet current, more-stringent standards but remain designated as nonattainment under older, less-stringent standards.

The American Lung Association opposes the EPA's proposed reconsideration of state implementation plan (SIP) requirements for reclassified nonattainment areas. They argue that allowing states to skip "leftover" requirements from previous classifications would weaken the Clean Air Act's progressive framework, delay emission reductions, and undermine public health protections.