WESTAR Comments on EPA’s Regional Haze Advanced Notice of Proposed Rulemaking

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On November 24, 2025 WESTAR submitted comments to the docket for EPA’s Advanced Notice of Proposed Rulemaking (ANPRM). The comments addressed each of EPA’s eighteen main questions within the ANPRM from questions about a potential reasonable progress metric to interstate and Federal Land Manager consultation. WESTAR also encouraged EPA to continue working with the states to craft the regional haze rule revisions and to delay the start of the third planning period. You can read the full letter here.

WESTAR Comments on AERR ICR

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On August 4th, 2025, WESTAR submitted comments on EPA’s renewal information collection request (ICR) for the Air Emissions Reporting Rule (AERR). EPA is seeking approval to renew its authority to collect emissions inventory data from state, local, and Tribal air agencies, and this renewal ICR estimates the burden in time and cost of collecting emissions inventory information.

WESTAR’s comments focused on the reasonableness of EPA’s updated cost assumptions, voluntary reporting of certain data elements, and the practical challenges states face in meeting the requirements. We also acknowledged and appreciated EPA’s efforts to update labor rates and cost estimates using recent federal data, as this conservative approach better reflects the resources needed by agencies to fulfill their obligations. The comment letter can be found here.

WESTAR Comments on Potential Revisions to Regional Haze Rule

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On July 9, 2025 WESTAR sent comments to EPA related to anticipated revisions to the Regional Haze Rule. While there is no draft rule to review or comment on, we asked EPA to consider several core principles to the regional haze program as they draft the rule. WESTAR also reiterated the importance of cooperative federalism when undertaking such impactful rulemaking. You can read the full letter here.

WESTAR Comments on EPA’s QAPP and QMP Directives

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WESTAR submitted comments on EPA’s Quality Management Plan (QMP) Standard and Quality Assurance Project Plan (QAPP) Standard Directives (Nos: CIO 2105-S-01.0 – and CIO 2105-S-02.1). These Directives expanded QAPP and QMP requirements, creating a strain on state, local, and Tribal air agency resources. In the letter, WESTAR member agencies request that EPA reevaluate QAPP applicability, reexamine the Directives, and work with EPA regions and the air agencies in the West to effectively align QA requirements. Read WESTAR’s letter here.

Comments on EPA’s proposal to extend the third round Regional Haze deadline

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In a Federal Register notice, EPA proposed to extend the SIP submittal deadline for the third implementation period from July 2028, to July 2031. WESTAR commented on the proposal in the Federal Register. WESTAR agrees with EPA’s proposal and additionally, requested that EPA extend the fourth, and subsequent implementation period deadlines so that they are all ten to fifteen years long. This is consistent with Section 169A of the Clean Air Act. You can read WESTAR’s comments here.

Arizona, Colorado, Utah, and Wyoming send letter to President Biden on Ozone

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On April 23rd, 2024 the governors from Arizona, Colorado, Utah, and Wyoming sent a letter to President Biden to raise concerns about attaining the 2015 8-hour Ozone National Ambient Air Quality Standard.

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WESTAR Comments – Large Municipal Waste Combustors

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On March 25, 2024, WESTAR submitted a comment letter to EPA on their proposed rule regarding large municipal waste combustors. WESTAR commented specifically in favor of the proposal to exclude air curtain incinerators from Title V requirements when they are used to burn wood waste, yard waste, and clean lumber and are not located at a major source or subject to title V for other reasons.

WESTAR Comment Letter – Multi-Pollutant Emissions Standards for Light-Duty and Medium-Duty Vehicles

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On July 5, 2023, WESTAR submitted a comment letter to EPA on the proposed rule to reduce GHG and criteria pollutants from model year 2027 and later light-duty and medium-duty vehicles.

WESTAR Comments on EPA’s Supplemental Proposal on Methane

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On February 13, 2023, WESTAR submitted comments to EPA on the supplemental notice of proposed rulemaking: “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review”, published in the Federal Register on December 6, 2022. This supplemental proposal is extensive and, if finalized, would update, strengthen, and expand the methane gas standards that affect oil and gas operations. WESTAR states shared their perspectives on how this proposed rule relates to and/or affects meaningful engagement, EPA’s ambitious regulatory agenda for 2022/2023, funding concerns, and resource constraints. The rule proposes several elements, including a “super-emitter response program” that western states, locals, and Tribes need further clarification on from EPA, knowing that this program, in particular, trends away from the usual delegation of authority to the state, local, or Tribal air agencies that the Clean Air Act is built on. For more information, see the rulemaking docket, found here.

WESTAR comment letter on EPA supplement to proposed Standards of Performance for Oil and Natural Gas–February 2023