On August 20, 2026, Environmental Protection Network submitted formal comments opposing EPA’s proposed revisions to minor New Source Review (NSR) public participation requirements, arguing that eliminating the federal minimum requirement for public notice and comment would weaken transparency, public oversight, and Clean Air Act protections. EPN argues that “minor” sources can still have significant localized and cumulative air quality impacts, particularly synthetic minor sources, and that public participation helps identify errors in emissions calculations, permit limitations, and source classifications. EPN also contends that EPA’s proposal lacks sufficient data and analysis, creates inconsistent protections across states, undermines EPA’s own commitments to transparency and public participation, and fails to adequately consider the public’s legitimate reliance interests. EPN urges EPA to retain a federal floor for public participation, particularly for synthetic minors and other consequential permits, while pursuing targeted reforms for genuinely low-impact activities rather than eliminating the requirement wholesale.
EPN Comments on Minor New Source Review Program Air Permitting Public Participation Requirements for State Implementation Plans
