Midwest Ozone Group Comments Regarding Maryland’s Petition to the Ozone
Transport Commission for Additional Control Measures Pursuant  to Section 184(c) of
the CAA dated August 14, 2019  
pdf

Midwest Ozone Group Comments Regarding EPA’s Proposal to Deny the State of New
York’s Clean Air Act §126 Petition dated July 11, 2019  
pdf

Illinois' Infrastructure State Implementation Plan for the 2015 Ozone NAAQS  
May 16, 2019 and Response to Comment Document  
pdf

Midwest Ozone Group comments on Missouri Proposed Infrastructure State
Implementation Plan for 2015 Ozone NAAQS April 3, 2019  
pdf

Scientific modeling and legal observations regarding additional steps EPA and states
should take to continue to assess and improve air quality; A Clean Air Act Briefing
Paper prepared by the Midwest Ozone Group.” February, 2019  
pdf

Midwest Ozone Group Additional Comments on New York CAA Section 126 Petition
December 17, 2018  
pdf

Midwest Ozone Group Comments on Illinois' Proposed Infrastructure State
Implementation Plan Related to 2015 Ozone NAAQS dated December 12, 2018  
pdf

Midwest Ozone Group Supplemental Comments on Ohio's Proposed Infrastructure
State Implementation Plan Related to 2015 Ozone NAAQS dated December 11, 2018  
pdf

Midwest Ozone Group Supplemental Comments on West Virginia's Proposed
Infrastructure State Implementation Plan Related to 2015 Ozone NAAQS dated
December 11, 2018  
pdf

Midwest Ozone Group Supplemental Comments on Indiana's Proposed Infrastructure
State Implementation Plan Related to 2015 Ozone NAAQS dated December 11, 2018  
pdf

Midwest Ozone Group Supplemental Comments on Kentucky's Proposed Infrastructure
State Implementation Plan Related to the 2015 Ozone NAAQS dated
December 11, 2018  
pdf

Midwest Ozone Group Supplemental Comments on New York 126 Petition
October 19, 2018  
pdf

Midwest Ozone Group comments on West Virginia Proposed Infrastructure State
Implementation Plan Related to the 2015 Ozone NAAQS   September 28, 2018  
pdf

Midwest Ozone Group comments on Indiana Proposed Infrastructure State
Implementation Plan Related to 2015 Ozone NAAQS dated September 24, 2018  
pdf

Midwest Ozone Group comments on Kentucky's Proposed Infrastructure State
Implementation Plan Related to the 2015 Ozone NAAQS dated September 21, 2018  
pdf

Midwest Ozone Group comments on Ohio EPA Proposed Infrastructure State
Implementation Plan Related to the 2015 Ozone NAAQS dated September 18, 2018  
pdf

Midwest Ozone Group comments on Proposed Determination Regarding Good
Neighbor Obligations for the 2008 Ozone NAAQS (Docket ID No. EPA-HQ-OAR-2018-
0225)
dated August 31, 2018  
pdf

UARG comments on EPA Notice of Proposed Action on Delaware and Maryland Section
126 Petitions dated July 23, 2018  
pdf

Kentucky Energy and Environment Cabinet comments Supporting EPA's Proposed
Action and Response to Clean Air Act Section 126(b) Petitions from Delaware and
Maryland (Docket ID No. EPA-HQ-OAR-2018-0295 dated July 23, 2018  
pdf

Midwest Ozone Group comments on EPA's Proposed Denial of Maryland and Delaware
Clean Air Act §126 Petitions; Docket ID No. EPA-HQ-OAR-2018-0295 dated July 23,
2018   
pdf

Midwest Ozone Group Initial Comments on New York 126 Petition filed with US EPA
dated May 31, 2018   
pdf

Midwest Ozone Group comments on EPA's April 18, 2018 Proposed Approval of
Kentucky 2008 Ozone NAAQS Interstate Transport SIP  dated May 16, 2018  
pdf

Midwest Ozone Group comments on EPA's March 27, 2018 Memorandum Entitled
"Information on the Interstate Transport State Implementation Plan Submissions for the
2015 Ozone National Ambient Air Quality Standards under the Clean Air Act Section
110(a)(2)(D)(i)(l)" dated April 30, 2018  
pdf

Midwest Ozone Group Updated Comments Regarding State of New York, Clean Air Act
§126 Petition, March 29, 2018
pdf

Midwest Ozone Group Initial Identification of Deficiencies in the New York 126 Petition,
March 23, 2018   
pdf

New York State Petition for a Finding Pursuant to Clean Air Act Section 126(b),
March 12, 2018   
pdf

Midwest Ozone Group Outlook For Future Ozone Transport Program Design  
February 21, 2018  
pdf

Midwest Ozone Group comments on EPA's Response to Certain State Designation
Recommendations for the 2015 Ozone NAAQS, January 31, 2018    
pdf

Good Neighbor SIP Analyses Related to 2008 and 2015 Ozone NAAQS, Midwest Ozone
Group Meeting January 11, 2018  
pdf

Petition for Review of 176A Denial (State of New York, State of Connecticut, State of
Delaware, State of Maryland, Commonwealth of Massachusetts, Commonwealth of
Pennsylvania, State of Rhode Island, and State of Vermont), December 22, 2017  
pdf

Atlantic States, Tad Aburn, Air Director, MDE, December 11, 2017  pdf

Midwest Ozone Group Comments on West Virginia Good Neighbor SIP,
December 5, 2017  
pdf

Midwest Ozone Group Statement in Support of Repeal of the Clean Power Plan,
November 28, 2017   
pdf

Good Neighbor SIP Development, Modeling Results, and Next Steps - Midwest Ozone
Group Presentation November 17, 2017  
pdf

Final Section 176A Petition Denial Action November 3, 2017   pdf

Maryland Compliant against U.S. EPA regarding its 126 Petition filed
September 29, 2017   
pdf

Midwest Ozone Group Comments on MANE-VU MEMO Entitled "Wintertime SCR/SNCR
Optimization on Visibility Impairing Nitrate Precursor Emissions"  September 29, 2017   
pdf

Impact of Wintertime SCR/SNCR Optimization on Visibility Impairing Nitrate Precursor
Emissions, MANE-VU Technical Support Committee August, 29, 2017  
doc

Sierra Club CSAPR Update Initial Brief filed on September 18, 2017  pdf

States CSAPR Update Initial Brief filed on September 18, 2017    pdf

Industry Petitioners CSAPR Update Initial Brief filed on September 18, 2017   pdf

AAPCA Principles for Addressing Interstate and International Ozone Transport
September 15, 2017  
pdf

Connecticut Final RACT SIP Revision July 17, 2017 pdf

New York Department of Environmental Conservation Ozone Modeling Analysis of
Peaking Units   
ppt

Assessment of International Transport and Improved Ozone Air Quality Prepared by the
Midwest Ozone Group June 22, 2017     
docx

Midwest Ozone Group Comments on Delaware CAA Section 126 Petition Conemaugh
Power Station June 20, 2017  
pdf

Midwest Ozone Group Comments on Maryland CAA Section 126 Petition Docket ID No.
EPA-HQ-OAR-2016-0691 May 17, 2017  
pdf

Midwest Ozone Group Comments in Support of Proposed Denial of 176A Petition
Docket ID No. EPA-HQ-OAR-2016-0596  May 15, 2017
pdf

Midwest Ozone Group Comments to Scott Pruitt, Administrator of US EPA - Evaluation
of Existing Regulations - Docket ID No. EPA-HQ-OA-2017-0190  May 15, 2017
pdf
Exhibit A  pdf
Exhibit B  pdf
Exhibit C  pdf
Exhibit D  pdf
Exhibit E  pdf

Memorandum Study Examining Electricity Markets and Reliability by Rick Perry
Secretary of Energy April 14, 2017  
pdf

Midwest Ozone Group Comments on the Notice of Availability of the Environmental
Protection Agency's Preliminary Interstate Ozone Transport Modeling Data for the 2015
Ozone NAAQS, April 6, 2017  
pdf

Midwest Ozone Group Statement Regarding CSAPR Update Rule February 10, 2017  
pdf

Midwest Ozone Group letter and comments on Implementation of  the 2015 National
Ambient Air Quality Standards for Ozone: Nonattainment Area Classifications and State
Implementation Plan Requirements  February 13, 2017  
pdf

Midwest Ozone Group Petition for Administrative Review of CSAPR Update Rule
December 21, 2016  
pdf

Grand River Dam Authority and Oklahoma Department of Environmental Quality
Petition for Reconsideration of CSAPR December 22, 2016  
pdf

Indiana Utility Group and the Indiana Energy Association Petition for Reconsideration of
CSAPR March 1, 2017  
pdf

Oklahoma Co-Generation, LLC Petition for Reconsideration of CSAPR
December 22, 2016  
pdf

Oklahoma Gas and Electric Petition for Reconsideration of CSAPR December 23,
2016   
pdf

Prairie State Generating Company Petition for Administrative Review of CSAPR Update
Rule December 23, 2016  
pdf

UARG Petition for Reconsideration of CSAPR December 23, 2016 pdf

Western Farmers Electric Cooperative Petition for Reconsideration of CSAPR
December 22, 2016   
pdf

White Stallion Energy Petition for Reconsideration of CSAPR December 23, 2016  pdf

Midwest Ozone Group Petition for Judical Review of CSAPR Update Rule -
December 23, 2016   
pdf

Charles G. Snavely, Secretary Kentucky Energy and Environment Cabinet letter to
Gina McCarthy, Administrator U.S. EPA on Maryland's Section 126(b) petition under the
Clean Air Act December 2, 2016.   
pdf

Petition of the State of Maryland  Pursuant to Section 126 of the Clean Air Act, Ben
Grumbles Secretary Maryland Department of the Environment, November 16, 2016.  
Transmittal Letter
pdf
Petition pdf  
Maryland 126 Petition Appendices
pdf

David S. Small, Secretary Delaware Department of Natural Resources and
Environmental Control,letter to Gina McCarthy, Administrator U.S. EPA petition under
126 of the Clean Air Act Homer City (Indiana County Pennsylvania) Generating Station
November 10, 2016  
pdf

Midwest Ozone Group Comments to David S. Small, Secretary, State of Delaware on
Harrison Power Station Section 126 Petition, August 29, 2016   
pdf

Midwest Ozone Group Comments to Gina McCarthy, Administrator, US EPA on State of
Delaware Clean Air Act Section 126 Petition Harrison Power Station Petition
August 29, 2016   
pdf

Petition of the State of Delaware Pursuant to Section 126 of the Clean Air Act,  David S.
Small Secretary Department of Natural Resources and Environmental Control
August 8, 2016,
 pdf

Petition of the State of Delaware Pursuant to Section 126 of the Clean Air Act,  David S.
Small Secretary Department of Natural Resources and Environmental Control
July 7, 2016  
pdf

Petition of the State of Connecticut Pursuant to Section 126 of the Clean Air Act,
Robert J. Klee Commissioner Connecticut Department of Energy & Environmental
Protection
June 1, 2016
pdf

Letter to Gina McCarthy, Administrator, US EPA on Ozone Transport Region (OTR) -
176A Petition from the states of Ohio, Kentucky, Indiana, West Virginia and Michigan
May 16, 2016  
pdf

Letter to Gina McCarthy, Administrator, US EPA, on 176A Petition from the states of
Connecticut, Delaware, Maryland, Massachusetts, New Hampshire, New York,
Pennsylvania, Rhode Island, and Vermont April 6, 2016  
pdf

Indiana Energy Association comments on Proposed Disapproval of Indiana
Infrastructure SIP  pdf
- Exhibit A - CT DEEP letter dated September 17, 2013  pdf
- Exhibit B – CT DEEP Presentation April 14, 2015  pdf
- Exhibit C – CT DEEP paper July 17, 2014  pdf
- Exhibit D – CT DEEP letter dated June 15, 2015  pdf
- Exhibit E – CT DEEP Notice of Decision April 6, 2016  pdf
- Exhibit F -  CT DEEP Hearing Officer Report dated
April 6, 2016  
pdf
- Exhibit. G – Alpine Geophysics “Alternative Design” Report
dated January 2016  
pdf
- Exhibit H - Alpine Geophysics “Model Performance” Report
dated January 2016  
pdf
- Exhibit I - Alpine Geophysics “PA RACT II” Report dated
January 2016  
pdf
- Exhibit. J – MDE presentation May 7, 2015  pdf

Ohio Utility Group comments on Proposed Disapproval of Ohio Infrastructure SIP, April
14,2016   
pdf

Midwest Ozone Group comments on EPA's Proposed Cross-State Air Pollution Rule for
the 2008 Ozone NAAQS (80 Federal Register 75706, December 3, 2015) February 1,
2016
 pdf

Indiana Deparment of Environmental Management comments on  EPA's Proposed
Cross-State Air Pollution Rule for the 2008 Ozone NAAQS (80 Federal Register 75706,
December 3, 2015) February 1, 2016
pdf

Kentucky Division of Air Quality Division of Air Qualit comments on EPA's Proposed
Cross-State Air Pollution Rule for the 2008 Ozone NAAQS (80 Federal Register 75706,
December 3, 2015) February 1, 2016
pdf

North Carolina Division of Air Quality comments on EPA's Proposed Cross-State Air
Pollution Rule for the 2008 Ozone NAAQS (80 Federal Register 75706, December 3,
2015) February 1, 2016  
pdf

Ohio Environmental Protection Agency comments on EPA's Proposed Cross-State Air
Pollution Rule for the 2008 Ozone NAAQS (80 Federal Register 75706, December 3,
2015) February 1, 2016  
pdf

National Ambient Air Quality Standards Implementation Coalition comments on EPA's
Cross-State Air Pollution Rule Update for the 2008 Ozone NAAQS (80 Federal Register
75706, December 3, 2015) Docket No. EPA-HQ-OAR-2015-0500 February 1, 2016  
pdf

Pennsylvania Legislature comments on EPA's Proposed Cross-State Air Pollution Rule
for the 2008 Ozone NAAQS (80 Federal Register 75706, December 3, 2015) January
28, 2016
pdf

Pennsylvania Department of Environmental Protection comments on EPA's Proposed
Cross-State Air Pollution Rule for the 2008 Ozone NAAQS (80 Federal Register 75706,
December 3, 2015) February 1, 2016
pdf

West Virginia Department of Environmental Protection comments on EPA's Proposed
Cross-State Air Pollution Rule for the 2008 Ozone NAAQS (80 Federal Register 75706,
December 3, 2015) February 1, 2016  
pdf

Olympus Power LLC comments on Cross State Air Pollution Rule Update for 2008
NAAQS EPA-HQ-OAR-2015-0500 February 1, 2016
pdf

Anthracite Region Independent Power Producers Association (ARIPPA) comments on
Cross State Air Pollution Rule Update EPA-HQ-OAR-2015-0500 February 1, 2016  
pdf


Midwest Ozone Group comments on EPA's Ozone NAAQS Transport Modeling NODA
EPA-HQ-OAR-2015-0500  October 23, 2015   
pdf

Connecticut State Implementation Plan for Clean Air Act Section 110(a) Infrastructure
Elements:  Prohibition on Interstate Air Pollution June 15, 2015  
pdf

Midwest Ozone Group letter to Janet McCabe, Assistant Administrator, Office of Air and
Radiation U.S. EPA dated May 29, 2015, regarding ozone transport.  
pdf

Midwest Ozone Group letter to Joseph Constance, Chairman, New Jersey Clean Air
Council dated May 29, 2015, regarding ozone transport.  
pdf

Midwest Ozone Group letter to Dave Foerter, Executive Director Northeast Ozone
Transport Commission dated May 29, 2015, regarding ozone transport.  
pdf

Presentation by Tad Aburn, Air Director, Maryland Department of Environment, entitled
"Maryland Analysis of Good Neighbor SIPs - Who Might Owe What and Will it Work?"
presented at the meeting of the Midwest Ozone Group held on May 7, 2015 Cincinnati,
OH
ppt    pdf

Presentation by Gregory Stella, Alpine Geophysics "Incremental Measures Available to
Download States to Reduce VOC and NOx" presented at the meeting of the Midwest
Ozone Group held on May 7, 2015 Cincinnati, OH
ppt  pfd

Presentation by David M. Flannery, Steptoe & Johnson PLLC and Gregory Stella Alpine
Geophysics LLC for the Midwest Ozone Group, entitled "Is There Need for a 75 ppb
Ozone Transport Rule?" presented at the meeting of the Midwest Ozone Group held on
May 7, 2015 Cincinnati, OH
ppt   pdf

Presentation by David M. Flannery, Steptoe & Johnson PLLC for the Midwest Ozone
Group entitled "The Role of Interstate Transport of Air Pollutants in Achieving Ozone
NAAQS Attainment" presented at New Jersey Clean Air Council "Air Pollution Knows No
Bounds" on April 14, 2015.
ptt  pdf

Midwest Ozone Group (MOG) comments on the November 26, 2014 proposal to revise
the 2008 primary National Ambient Air Quality Standard for ozone. (Docket ID: EPA-HQ-
OAR-2008-0699). March 17, 2015.
pdf

Midwest Ozone Group (MOG) comments on the Notice of Proposed Rulemaking
(NPRM) Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric
Utility Generating Units (EGUs) (Docket ID: EPA-HQ-OAR-2013-0602). November 26,
2014
pdf

Presentation by Tad Aburn, Air Director, Maryland Department of Environment, entitled
"Good Neighbor Partnerships" presented at the meeting of the Midwest Ozone group
held on October 24, 2014
ppt    pdf

Presentation by Rob Kaleel, Executive Director, Lake Michigan Air Directors
Consortium, entitled "Discussion on Good Neighbor SIPs" presented at the meeting of
the Midwest Ozone Group held on October 24, 2014
ppt    pdf

Presentation by Gregory Stella, Alpine Geophysics, entitled " Good Neighbor SIP
Discussion"  presented at the meeting of the Midwest Ozone Group held on October
24, 2014
ppt   pdf

§176A Petition by the Ozone Transport Commission December 9, 2013 pdf

WV Chamber of Commerce comments on Standards of Performance for Greenhouse
Gas Emissions from New Stationary Sources:  Electric Utility Generating Units; Docket I.
D. No. EPA-HQ-OAR-2013-0495 filed on March 20, 2014 (Including An Overview of
2013 CCS Update - A State-by-State Survey of Existing Statutes and Rules Related to
the Transportation and Geologic Storage of Carbon Dioxide)   
pdf

Midwest Ozone Group Assessment of  §176A Petition by David M. Flannery - Steptoe
and Johnson PLLC and Gregory Stella - Alpine Geophysics LLC February 2014.
pdf

Target States Response to §176A Petition - February 2014, pdf

The Dominant Role of Air Pollution Transport - Science, Control Programs and
Challenges by Tad Aburn - Air Director, Maryland Department of Environment, June 21,
2012, AWMA Meeting San Anto nio, TX
pdf

Elements of a "Good Neighbor" Ozone SIP by David M. Flannery and Gene Trisko,
March 12, 2014.  
pdf

Midwest Ozone Group Position Statement with Respect to CSAPR Remand "Red Lines"
Analysis - April 24, 2013 updated on July 26, 2013
pdf

David Flannery presentation at the November 28, 2012 American Legislative Exchange
Council (ALEC) meeting held in Washington, D.C.
ppt file pdf

Commissioner Thomas Easterly (IDEM) presentation at the November 28, 2012
American Legislative Exchange Council (ALEC) meeting held in Washington, D.C.  
pptx
file
pdf

Gene Trisko Handout at September 13, 2012 Meeting of the NE Ozone Transport
Commission (file updated on September 18, 2012)
Comparison of CAIR and CSAPR
NOx Bu
dgets

Unions for Jobs and the Environment, Inc. Board Presentation on CSAPR and MACT
January 24, 2012 revised January 31, 2012
UJAE Board Presentation on CSAPR and MACT