It is absolutely laughable that San Francisco would be involved since the prevailing winds there come off the Pacific Ocean. They thus do not get downwind pollution from a plant that would require new source review. Virtually all of the electrical power it uses comes from either natural gas or hydro. Neither is the Bay Area in a state of non attainment. I cannot fathom how the city could therefore demonstrate irreparable harm from the proposed change in rules.
My understanding is that areas in non-attainment would still be subject to new source review. So who gets harmed when a plant installs cleaner equipment without upgrading its emissions abatement equipment?
How does not upgrading a plant's pollution control equipment "increase" pollution? Is this the same logic whereby a 5% increase in spending becomes a "cut"?
One other thing. When courts stike down what the EPA is doing, the EPA only honors the decision in the district in which the decision was made.