Amy_
L._
Farrell@
omb.
eop.
gov
08/
27/
2003
10:
07
AM
To:
Bill
Harnett/
RTP/
USEPA/
US@
EPA,
Bill
Wehrum/
DC/
USEPA/
US@
EPA
cc:
Phil_
Cooney@
ceq.
eop.
gov,
Arthur_
G._
Fraas@
omb.
eop.
gov,
Paul_
R._
Noe@
omb.
eop.
gov
Subject:
Preamble
footnote.

Bills
­

I
spoke
w/
Lee.
Footnote
7
was
missing
an
important
qualifier.
See
revised
last
sentence
below.

Phil
­
Here's
the
new
footnote.
Please
note
that
the
footnote
is
key
to
whether
the
examples
in
the
preamble
text
qualify
for
the
ERP
exclusion
under
this
rule.
The
examples
themselves
only
illustrate
activities
that
would
be
considered
functionally
equivalent.
I
can't
stress
the
importance
of
this
enough,
especially
since
you're
planning
to
use
the
examples
for
communication
purposes.

Thanks,

Amy
As
discussed
in
more
detail
below,
although
such
activities
would
be
functionally
equivalent,
they
would
still
need
to
meet
other
criteria
to
qualify
for
the
ERP.
For
example,
a
functionally
equivalent
replacement
does
not
qualify
for
the
ERP
if
it
results
in
a
change
to
a
basic
design
parameter
of
the
affected
unit.
If
an
activity
does
not
qualify
for
RMRR
under
the
ERP,
the
case­
by­
case
RMRR
approach
would
still
be
available
to
the
owner
or
operator
under
those
circumstances.
And,
of
course,
even
if
the
activity
does
not
qualify
for
the
RMRR
exclusion,
the
activity
will
not
be
a
modification
and,
hence,
will
not
trigger
NSR
unless
it
results
in
a
significant
emissions
increase.
