API's stance on EPA draft guidance clarifying what facilities should be considered adjacent for Clean Air Act permitting purposes

The Associations included below respectfully submit the attached comments on the Environmental Protection Agency’s (EPA’s) draft guidance, “Interpreting ‘Adjacent’ for New Source Review and Title V Source Determinations in All Industries Other Than Oil and Gas.” (“draft guidance”). We support EPA’s efforts to restore the major NSR regulations and other air regulations to their proper scope, and greatly appreciate the opportunity to provide comment on the draft guidance before EPA issues a final version. We believe upfront engagement can improve the final product.

• American Chemistry Council (ACC)
• American Coke and Coal Chemicals Institute (ACCCI)
• American Forest & Paper Association (AF&PA) American Fuel & Petrochemical Manufacturers (AFPM)
• American Petroleum Institute (API) Council of Industrial Boiler Owners (CIBO)
• National Mining Association (NMA)
• Portland Cement Association (PCA)
• The Fertilizer Institute (TFI)
• Tile Council of North America (TCNA)

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Inquiry regarding API's stance on EPA draft guidance clarifying what facilities should be considered adjacent for Clean Air Act permitting purposes

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