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Remarks of Lucas Minich for the Clean Air Task Force on Oil and Natural Gas Sector; Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, 82 Fed. Reg. 27,645 (June 16, 2017)
The Clean Air Task Force opposes the EPA's proposed stays on emission standards for new, reconstructed, and modified oil and gas sources, asserting that the agency lacks the legal authority under the Clean Air Act and the Administrative Procedure Act to postpone compliance dates for an already-effective rule. The organization highlights that staying leak detection and repair requirements would eliminate over half of the rule's methane reductions and nearly 90 percent of its toxic air emissions benefits, disproportionately impacting the health of children and vulnerable populations living near facilities.
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Document type: Statement
REQUEST FOR MEETING TO DISCUSS WAY FORWARD ON ESKOM’S NON-COMPLIANCE WITH EMISSION STANDARDS
The Centre for Environmental Rights (CER) is calling for a meeting with the Department of Environmental Affairs to address evidence of widespread non-compliance by Eskom power stations with their atmospheric emission licences (AELs). Based on a report by Professor Eugene Cairncross analyzing data from 1 April 2015 to 31 March 2016, the CER identifies multiple stations likely exceeding PM10, NOx, and SO2 limits. The CER argues that Eskom is the largest emitter in the Highveld Priority Area and recommends stricter reporting requirements, including the use of daily average concentrations rather than monthly aggregates, to accurately monitor compliance.
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Document type: Statement
OPEN LETTER TO THE MINISTERS OF PUBLIC ENTERPRISES, ENERGY, ENVIRONMENTAL AFFAIRS AND HEALTH
The document argues that Eskom is obstructing South Africa's transition to renewable energy and violating constitutional rights through the continued operation of polluting coal-fired power stations. The signatories call for the removal of barriers to small-scale renewable energy, the decommissioning of ageing coal plants, and greater transparency regarding emission compliance plans.
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Document type: Statement
Review of Light-duty Vehicle Fuel Economy and Emissions Standards
The document outlines several automotive technologies—including high-compression engines, cylinder deactivation, advanced transmissions, lightweight materials, and 48V stop-start systems—that allow manufacturers to surpass federal fuel economy projections for 2025.
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Document type: Fact sheet
Faster and cleaner decarbonisation in the power and transport sectors is happening
The document reports that decarbonization in the power and transport sectors is exceeding previous predictions. It highlights a faster-than-expected shift away from coal in the EU, US, and China, as well as wind and solar capacity growth that has surpassed forecasts. In transport, passenger vehicle fleets in key economies are less carbon-intense than in 2005, and the market penetration of electric drive vehicles is exceeding predictions.
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Document type: Executive summary
PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Petition for Listing and Rulemaking Under Section 112 of the Clean Air Act to Establish an Area Source Category for Oil and Gas Production Wells and Associated Equipment and to Set National Emission Standards for Hazardous Air Pollutant Emissions
Earthjustice and a coalition of nonprofit organizations petition the EPA to regulate oil and gas wells as area sources, arguing that the rapid expansion of drilling—particularly via hydraulic fracturing—in metropolitan areas poses a non-negligible risk to public health. The document details the emission of toxic air pollutants such as benzene and formaldehyde, highlights the vulnerability of children and overburdened communities, and identifies significant regulatory gaps in existing EPA rules. It concludes that available technologies, such as green completions and vapor recovery units, can substantially reduce these emissions.
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Document type: Report
WRI Response to the 2014 State of the Union Address
The World Resources Institute (WRI) endorses President Obama's commitment to enact new emissions standards for existing power plants as part of the Climate Action Plan. WRI argues that such standards can drive innovation and economic opportunity, noting that the average U.S. coal plant is nearly 40 years old. The statement emphasizes that U.S. domestic leadership is essential to meeting its international commitment to reduce emissions by 17% below 2005 levels by 2020 and to securing a universal climate agreement in Paris in 2015.
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Document type: Statement
Occupational Exposure to Diesel Exhaust
The document details the health risks associated with occupational exposure to diesel exhaust, specifically particulate matter, and advocates for the use of Diesel Particulate Filters (DPFs) to retrofit older engines.
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Document type: Fact sheet
Foundation Course on Air Quality Management in Asia
The Foundation Course on Air Quality Management in Asia is a six-module educational program for adult learners aimed at improving urban air quality. The document provides an overview of the course's goals and a comprehensive glossary of technical terms related to atmospheric chemistry, health effects, and regulatory standards. It highlights the severe impact of urban air pollution in Asia, noting it causes an estimated 537,000 premature deaths annually, with indoor air pollution causing more than double that amount.
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Document type: Guide
Governance and Policies
The document outlines a strategic approach to air quality management (AQM) specifically for Asian cities, emphasizing the integration of health-based guidelines, clean air implementation plans, and multi-stakeholder governance. It details various policy instruments—ranging from 'command and control' regulations to economic incentives and voluntary agreements—and provides specific strategies for reducing emissions from transport, industry, and area sources. Additionally, it explores the synergies between urban air quality improvements and climate change mitigation, particularly through the Clean Development Mechanism (CDM).
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Document type: Guide
The Health Risks of Construction Pollution in California
The report finds that diesel construction equipment in California causes over 1,100 premature deaths and more than $9 billion in annual public health costs. It identifies excavators, tractors/loaders/backhoes, and crawler tractors as the highest polluters and highlights the South Coast air basin as the most affected region. The authors advocate for a regulatory regime to retire old equipment and install retrofit technologies to reduce particulate matter and nitrogen oxides.
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Document type: Report
School Bus Pollution Report Card 2006
The report evaluates U.S. school bus emissions, finding that older diesel buses release significantly more soot than modern alternatives, posing health risks to children. It grades states on soot emissions, cleanup programs, and smog-forming pollution, noting wide performance gaps. The authors recommend a strategy of 'the five Rs'—retrofitting, refueling, replacement, repair, and reduced idling—and call for strengthened federal standards and increased funding to modernize fleets.
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Document type: Executive summary
Sick of Soot
The report finds that diesel pollution caused an estimated 3,000 premature deaths and $21.5 billion in health costs in California in 2004. While new engine standards will reduce emissions over time, the longevity of existing engines means significant health risks persist. The authors argue that full implementation of California's Diesel Risk Reduction Plan and increased funding for the Carl Moyer Memorial Air Standards Attainment Program could prevent 11,000 premature deaths and save between $48 billion and $70 billion by 2020.
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Document type: Report
Are Cars Still A Problem?
The report challenges claims by the American Automobile Manufacturers Association (AAMA) that modern cars are 90-96% cleaner than 1960s precontrol cars. It finds that real-world emissions are significantly higher than regulatory standards due to equipment malfunction and 'off-cycle' driving. Furthermore, a 2.7-fold increase in total vehicle miles traveled and a shift toward light trucks—which have less stringent standards—have offset per-vehicle gains. Consequently, while hydrocarbons decreased, nitrogen oxide emissions for the total passenger fleet actually increased by over 20% between 1965 and 1995. The author concludes that passenger vehicles remain a primary source of carbon monoxide and smog-forming pollutants, necessitating a shift toward intrinsically-clean vehicle technologies.
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Document type: Report
Microsoft Word - Chapter II.6.28.Final.doc
The Clean Air Task Force (CATF) contends that the EPA's proposed MACT standards for coal-fired utility units violate the Clean Air Act (CAA) by using arbitrary subcategories based on coal rank and flawed statistical methods to inflate emission floors. CATF argues that the EPA has ignored available, cost-effective technologies—such as activated carbon injection and fabric filters—that could achieve significantly higher mercury removal rates. The document further asserts that the EPA is legally obligated to regulate all HAPs emitted by these units, not just mercury and nickel, and that proposed compliance extensions are unauthorized and unnecessary given available labor and equipment resources.
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Document type: Statement
Putting Out the Fire: Reducing flaring in tight oil fields by improving utilization of associated gas
The document assesses the environmental and economic impacts of flaring associated gas in the Bakken and Eagle Ford formations, concluding that routine flaring is unnecessary due to the availability of mature alternatives like CNG trucking, NGL recovery, and gas-to-power generation. It argues that current regulations, such as those in North Dakota, are inadequate and calls for robust nationwide standards from the BLM and EPA to mandate gas capture.
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Document type: Executive summary
catf_whitepapers_draftnotificationonairemissionstandards_tables-92a15d24f44dd510.pdf
The document contains technical tables comparing proposed Indian coal power plant emission standards for SO2, NOx, and PM with standards from the EU, China, and the US. It also includes detailed performance data for numerous US coal units, specifically listing SO2 and NOx rates for 2014, as well as tested levels of filterable particulate matter and mercury across various plants.
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Document type: Report
sasol’s submission on the requirement fcr existing plants to meet new plant standards as well as other concerns reiating to the Listed Activities and Minimum Emission standards
Sasol argues that retrofitting old plants to meet new emission standards is often technically impossible due to space and configuration constraints, and economically unjustifiable given the negligible impact on ambient air quality in some areas. The company highlights conflicts between air quality standards and national energy efficiency and waste strategies, while calling for extended compliance timelines and greater regulatory certainty across national, provincial, and local government tiers.
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Document type: Statement
Sales and Sales Share
The document describes the application of Sales and Sales Share variables in stock-turnover analyses to model how new energy efficiency or emissions standards for new technologies impact the overall average values of a total stock as older devices are replaced. It outlines two analysis types—Transport Analysis for vehicles and standard Stock Analysis for other devices—and explains that data can be entered via bottom-up technology branches or a top-down approach using shares. It further notes that Sales variables operate from a specified First Sales Year and are paired with Survival Profiles to model device retirement.
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Document type: Guide
Stock and Stock Share
The document describes the functionality of the Stock variable in LEAP, which is used to model how new energy efficiency or emissions standards for new technology sales gradually improve the average values of a total device stock as older units are replaced. It details the two types of stock-turnover analysis—Transport Analysis for vehicles and standard Stock Analysis for other devices—and explains the choice between top-down and bottom-up data entry. The guide specifies that the Stock variable initializes calculations and works with the Stock Vintage Profile and First Sales Year to determine how stocks evolve through sales, retirement, and forced scrappage.
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Document type: Guide