On October 8, 2019, NRECA
submitted comments in support of EPA’s New Source Review (NSR) proposal
for project emissions accounting under Step I of the NSR evaluation for
determining NSR applicability for new and modified sources. The current rule
prevents project emission decreases from being considered under Step I or Step
II of the NSR process. The proposal, if
finalized, in some cases allows a regulated entity to avoid the Step II
evaluation all together if it can be shown that the project as a whole,
considering all emissions decrease and increase, under Step I would result in
no significant emissions increase.