[
INSERT,
for
Bill
Harnett's
INSERT
FOR
RIA
(
bottom
of
p.
3,
in
last
full
paragraph,
after
1st
sentence),
and
for
INSERT
FOR
PREAMBLE
(
top
of
p.
4,
in
1st
full
paragraph,
after
1st
sentence)]

In
qualitative
terms,
the
Abt
analysis
supports
our
conclusion
that
the
old
case­
by­
case
approach
to
RMRR
is
having
perverse
effects
by
discouraging
projects
that
would
improve
efficiency,
or
that
would
increase
capacity
without
actually
increasing
pollutant
emissions,
or
that
would
even
discourage
projects
that
would
decrease
emissions.
As
the
Abt
Case
Study
on
the
Pulp
and
Paper
Industry
put
it:

"[
A]
s
[
safety,
reliability,
and
efficiency]
projects
begin
to
be
reviewed,
those
that
raise
questions
under
the
ambiguity
of
the
current
rules
may
be
postponed,
altered,
or
simply
cancelled.
Under
the
proposed
ERP
approach,
these
projects
can
be
tested
against
a
more
clear
and
reasonable
set
of
criteria,
that
will
allow
more
projects
to
be
executed.

.
.
.
The
new
approach
provides
the
regulatory
clarity
and
certainty
in
making
applicability
decisions
that
is
completely
absent
from
the
current
case­
by­
case
approach.
Thus,
the
manner
in
which
mills
will
handle
the
processing
of
equipment
replacement
projects,
with
regard
to
assessing
their
air
permit
applicability
assessments,
will
be
able
to
be
streamlined.
By
definition,
a
`
caseby
case'
approach
is
simply
unworkable
for
a
typical
pulp
and
paper
mill,
which
may
have
thousands
of
maintenance
and
repair
related
work
orders
involving
equipment
replacements
executed
each
year,
affecting
all
areas
of
mill
operations.
Clearly,
only
a
small
subset
of
these
equipment
replacement
projects
can
be
evaluated
using
the
complicated
and
vaguely
interpreted
multi­
factor
test
inherent
with
the
current
case­
by­
case
approach.
.
.
.
The
proposed
ERP
approach
helps
by
setting
criteria
for
the
routineness
determinations.
Under
the
proposed
approach,
a
mill
could
set
up
more
straight­
forward
guidelines
to
be
followed
throughout
an
organization
that
would
allow
quick
and
defensible
determinations
to
be
made
regarding
individual
maintenance
projects."

[
Abt
Associates,
Inc.,
Case
Study
on
the
Pulp
and
Paper
Industry,
at
p.
31.]
