The Colorado Chamber filed a rebuttal statement to the Air Quality Control Commission’s (AQCC) Procedural Rulemaking scheduled for November 20-21. There have been several lengthy stakeholder meetings with all parties to find consensus positions on the rules and only a handful of issues remain.
The rules create a longer upfront stakeholder process by which the parties are intended to communicate, file positions and redlines and hope to find consensus. The Chamber is generally in support of the rules; however, would like as much clarity of the Division’s initial proposal as possible and a clearly defined process and timeline by which alternative proposals are determined to be within the scope of the rulemaking.
Several parties also suggested that a written summary of comments and a Commission response to comments be filed prior to deliberations, and the Chamber is not in support of this concept. We also commented on order of rebuttal and surrebuttal for rule proponents (most often, but not always the Air Division), commented on a suggestion that a set time frame for cross examination be provided to all parties, and provided comments again with redline language on the process for Title V public comment and EPA review. The Rebuttal Statement as filed can be found here.
Please contact Christy Woodward, Regulatory Affairs Advisor, at [email protected] with any questions.