Erika
Sasser/
RTP/
USEPA/
US
07/
14/
2006
03:
04
PM
To
"
Suskauer,
Gary"
<
gsuskauer@
nahb.
com>
cc
"
Mittelholzer,
Michael"
<
mmittelholzer@
nahb.
com>
Subject
Re:
Revised
PM
NAAQS
Mr.
Suskauer­­

You
are
correct
that
the
interim
RIA
(
completed
in
January
2006)
does
not
evaluate
the
proposed
revisions
to
the
coarse
PM
NAAQS.
Our
RIA
analysis
focuses
only
on
fine
particles,
and
no
assessment
has
been
conducted
regarding
the
projected
costs
and
benefits
of
any
revised
coarse
particle
standard.
The
reasons
for
this
are
explained
in
the
interim
RIA,
which
states
that
the
RIA
"
does
not
contain
an
analysis
of
the
proposed
revisions
[
to
the
PM10
standards].
In
general,
EPA
expects
that
significantly
fewer
areas
would
violate
these
proposed
standards
as
compared
to
the
current
PM10
standards....
[
Furthermore]
Implementation
of
the
proposed
new
coarse
standards
will
occur
over
a
longer
time
horizon
than
for
the
fine
particles,
and
current
emissions
inventory
information,
air
quality
data
controls,
air
modeling
and
benefits
analyses
are
incomplete.
In
addition,
EPA
is
still
considering
implementation
issues
associated
with
any
PM10­
2.5
standard;
all
of
these
factors
complicate
the
analysis."

Regarding
your
second
question,
we
have
not
issued
any
additional
clarification
or
guidance
regarding
which
specific
source
types
would
be
excluded
under
the
exemption
for
"
agricultural
sources,
mining
sources,
and
other
similar
sources
of
crustal
material"
described
in
the
preamble
to
the
proposed
rule.
In
the
proposal,
EPA
requested
comment
on
this
issue,
and
we
are
currently
in
the
process
of
reviewing
all
the
public
comments
received.

Thank
you
for
your
interest
in
the
proposal,
and
please
let
me
know
if
I
can
be
of
further
assistance.

Erika
Sasser
_______________
Erika
N.
Sasser,
Ph.
D.
U.
S.
EPA
Office
of
Air
Quality
Planning
and
Standards
HEID/
OD
C504­
02
Research
Triangle
Park,
NC
27711
Phone
(
919)
541­
3889
Fax
(
919)
541­
0804
sasser.
erika@
epa.
gov
"
Suskauer,
Gary"
<
gsuskauer@
nahb.
com>

07/
14/
2006
12:
16
PM
To
Erika
Sasser/
RTP/
USEPA/
US@
EPA
cc
"
Mittelholzer,
Michael"
<
mmittelholzer@
nahb.
com>
Subject
Revised
PM
NAAQS
Dr.
Sasser,
I
apologize
in
advance
for
the
double
message
(
I
left
a
voice
mail
as
well),
but
I
was
not
sure
which
contact
method
was
best
to
reach
you.
The
National
Association
of
Home
Builders
was
one
of
the
groups
that
met
with
Administrator
Johnson
this
week
regarding
the
proposed
revision
for
the
PM
NAAQS.
Following
that
meeting,
we
have
some
additional
follow­
up
questions.
First,
is
there
a
revised
Regulatory
Impact
Analysis
that
accounts
for
the
cost
of
the
course
PM
rules?
We
have
been
unable
to
locate
that
at
this
point.
Second,
we
were
wondering,
has
there
has
been
any
additional
clarification
or
guidance
on
the
exemption
for
agriculture,
mining
and
"
other
similar
sources
of
crustal
material?"
It
is
our
opinion
that
residential
construction,
especially
those
activities
taking
place
on
former
farmland,
would
qualify
as
a
similar
source
of
crustal
material.

Any
information
you
can
share
would
be
most
appreciated.
Thank
you
for
your
help.

­
Gary
Gary
Suskauer
Policy
Analyst,
Environmental
Policy
Advocacy
Group
National
Association
of
Home
Builders
1201
15th
Street,
NW
Washington,
DC
20005
800­
368­
5242
x8327
gsuskauer@
nahb.
com
