​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.