NRECA filed comments on July 15, 2019 supporting the Environmental Protection Agency (EPA) in the denial of a New York petition for more upwind emission reductions. Twelve G&T owned or co-owned units in five states are included in New York's regulatory petition that would require more emissions reductions considerations. Section 126 of the air act requires "upwind" states eliminate "significant contribution' to "downwind" states ambient standards "nonattainment." Like other ongoing Section 126 regulatory and judicial actions, the New York petition seeks to expand the upwind state emission reduction mandates heretofore not required under section 126. Specifically New York's petition seeks to require rapid reductions that are not cost effective as determined by this and past EPA administrations and to require reductions where downwind state nonattainment is not demonstrated to occur at a future date. Ultimately any judicial decision allowing a broader reading of section 126 authorities and mandates for upwind states will be utilized in future section 126 actions.