IEPNJ submitted comments on the CSAPR Rule Update for the 2008 Ozone NAAQS to support cogeneration and a reasonable NOx allocation methodology.
On February 1, 2016, IEPNJ submitted comments on the proposed update to the Cross-State Air Pollution Rule (CSAPR) for the 2008 Ozone National Ambient Air Quality Standards (NAAQS).
Starting in 2017, this proposal would reduce summertime nitrogen oxides (NOx) emissions from power plants in 23 states in the eastern United States, including New Jersey.
In its comments, IEPNJ advocated for an allocation method that assures there is an even playing field among resources while recognizing those facilities that installed post-combustion control technologies. IEPNJ also urged the EPA to exhibit continued support for CHP generation in its proposed CSAPR changes since these facilities provide some of the most efficient use of fuel in the nation.