if the flood of comments that slowed down the proposed change to the Endangered Species Act could do the same here.

On the Sierra Club Blog Carl Pope notes that the speed of the rule-making is effectively shutting out public comments and giving the basis for a legal challenge to void Bush's changes.

While vigilance is certainly warranted, it bears keeping in mind that NSR is hopelessly broken (and the initial CAIR proposals that have been thrown out by the courts weren't such a bad fix, stereotypes of this administration notwithstanding.)

The crux of the issue is that in a permitting regime based on grandfathered permit rights - which the Clean Air Act most definitely is - you need some protection to make sure that you can't build an ever-bigger plant with a grandfathered permit.  To take an obvious example, suppose you have a 500 MW coal plant that is permitted under 15-year old emissions limits.  In the ensuring 15 years, emissions standards for new plants have fallen dramatically, giving you an economic advantage against newer, cleaner plants.  The intent of NSR is to prevent that plant from building an adjacent 500 MW coal plant under the same permit, doubling plant output and gaming the regime.  (I'm using an extreme case to illustrate, but the issue applies no less to a 10% power increase as a 100%.)

That seems sensible.  The problem is that NSR has been written so broadly that it not only blocks new construction but also blocks efficiency enhancements.  (After all, there's a big difference on the margin between boosting power output by burning more coal and boosting power output without burning any more coal.)  But in the current framework, since both trigger new source review, both are discouraged, and so we have lots of existing generators that are actively discouraged from boosting plant efficiency.

That said, there is a clear political challenge here, as the existing generators would love to expand NSR overhaul well beyond efficiency considerations.  That would be bad - but that doesn't mean that NSR overhaul isn't critically important.

In other words, while we ought to be careful with how NSR is overhauled, we shouldn't get caught up in knee-jerk opposition to critically needed reform.

...the problem has always been that once NSR is opened up for changes, the lobbyists descend on the Administration (and Congress) to load the deal with goodies, or to kill good revisions.  

In 1996 a pretty good overhaul package was killed at the last minute -- Carol Browner was strong-armed into deep-sixing it after several years of effort on EPA's part to develop the rules.
And the sordid history under the Bush Administration is well-known -- routine maintenance rules that were huge loopholes and were eventually struck down in court, and more recently the changes mentioned above.

That said, if the next Administration could pull off a switch to output-based standards, rewarding efficiency (as you always point out), that would be huge, as would carbon cap-and-trade.