"
Newell,
Richard
G."
<
Richard_
G._
Newell@
cea.
eo
p.
gov>

12/
08/
2005
11:
42
AM
To
Jason
Burnett/
DC/
USEPA/
US@
EPA
cc
Subject
PM
Comments
As
we
discussed,
here
are
some
comments
on
the
PM
proposal.

(
1)
Should
we
distinguish
between
ag.
and
mining­
sourced­
PM?

(
2)
Words
such
as
"
dominated"
and
"
predominantly"
are
often
used.
Is
there
a
need
for
a
clearer
definition
of
what
is
meant
by
these
and
similar
terms?

(
3)
The
definition
of
the
terms
"
contaminated"
and
"
enriched"
could
be
beefed
up.

(
4)
On
page
(
19)
of
the
monitoring
rule
it
states
that
"
nearly
all
coarse
particles
are
primary
in
origin
(
i.
e.,
are
deposited
in
the
form
emitted
rather
than
being
created
as
a
result
of
atmospheric
chemical
reactions...).
This
is
not
central,
but
this
would
appear
to
be
inconsistent
with
the
idea
of
"
contaminated"
coarse
particles
which
are
indeed
created
at
least
in
the
case
of
resuspended
dust.

(
5)
Technical
terms
should
be
defined
briefly
when
first
used.
Also,
frequently
used
terms
that
are
particular
to
the
rule
(
e.
g.,
"
contaminated")
should
be
defined
up
front,
perhaps
even
in
a
single
definitions
section.

(
6)
I
think
the
powers
that
be
should
propose
to
change
the
system
of
outlining
regulations
(
i.
e.,
the
section
numbering
system)
so
that
it
is
easier
to
follow
and
more
in
keeping
with
the
"
plain
language"
requirements
of
EO12866.
This
is
my
Section
1.1.1.2.3.
instead
of
II.
A(
1)(
a)(
iii)
suggestion.
Or
at
a
minimum,
the
prefix
(
II.
A(
1)(
a))
should
be
carried
around
so
that
you
do
not
just
have
a
(
iii)
telling
you
where
you
are.

­
Richard
Richard
Newell
Council
of
Economic
Advisers
(
202)
395­
1455
rnewell@
cea.
eop.
gov
