We note that a number of groups are meeting with OMB on EPA’s NSPS standards, see this article from Inside Climate News.
Hopefully one of the meetings at OMB will include the Secretary of Energy. After all DOE has the most experience of any federal agency on the CCS technology. CRE issued a press release on this topic several months ago.
Significant points in the CRE press release include the point that if EPA were to adopt the “CRE Option” then the EPA rule would be nearly litigation proof and consequently the more significant rule dealing with existing sources would not be compromised.
The press release also contains a draft complaint which allows an affected party to initiate legal action against EPA before the rule is issued in final form. CRE provided the complaint as a public service and has no intention of filing it but it could be used by potential plaintiffs.