E­
Mail
TO:
"
Otis,
Lee"
<
Lee.
Otis@
hq.
doe.
gov>
06/
25/
2004
07:
38
AM
To:
"'
Belton,
Keith
B.
'"
<
KBelton@
OMB.
eop.
gov>,
"'
Fraas,
Arthur
G.
'"
<
afraas@
OMB.
eop.
gov>,
"'
Noe,
Paul
R.
'"
<
pnoe@
OMB.
eop.
gov>,
Bill
Wehrum/
DC/
USEPA/
US@
EPA,
"'
O'Donovan,
Kevin
M.
'"
<
Kevin_
O'Donovan@
ovp.
eop.
gov>,
"
Hill,
David
R."
<
David.
Hill@
hq.
doe.
gov>,
"'
Indur_
Goklany@
ios.
doi.
gov
'"
<
Indur_
Goklany@
ios.
doi.
gov>,
"'
Joseffer,
Daryl
L.
'"
<
Daryl_
L._
Joseffer@
OMB.
eop.
gov>,
"'
Gayer,
Ted
'"
<
Ted_
Gayer@
cea.
eop.
gov>,
"'
Boyd,
Allison
'"
<
Allison_
Boyd@
opd.
eop.
gov>,
Chet
Thompson/
DC/
USEPA/
US@
EPA,
Bill
Harnett/
RTP/
USEPA/
US@
EPA,
Jessica
Furey/
DC/
USEPA/
US@
EPA
cc:

Subject:
RE:
language
for
ERP
reconsideration
package
I've
edited
this
to
shorten
it
further.
I
also
would
put
it
right
before
the
sentence
"
petitioners
ask
that
EPA
reconsider"
on
p.
18,
rather
than
after
that.

­­­­­
Original
Message­­­­­
From:
Belton,
Keith
B.
To:
Fraas,
Arthur
G.;
Noe,
Paul
R.;
Wehrum.
Bill@
epamail.
epa.
gov;
O'Donovan,
Kevin
M.;
Otis,
Lee;
Hill,
David
R.;
Indur_
Goklany@
ios.
doi.
gov;
Joseffer,
Daryl
L.;
Gayer,
Ted;
Boyd,
Allison;
Thompson.
Chet@
epamail.
epa.
gov;
Harnett.
Bill@
epamail.
epa.
gov;
furey.
jessica@
epa.
gov;
Belton,
Keith
B.
Sent:
6/
24/
2004
5:
34
PM
Subject:
language
for
ERP
reconsideration
package
FYI:
In
case
you
don't
have
it,
here
is
the
language
suggested
for
the
reconsideration
package.

In
the
course
of
considering
how
to
proceed
with
respect
to
the
reconsideration
petition
on
this
point,
we
also
thought
it
might
be
of
some
interest
to
examine
whether
jurisdictions
administering
construction
building
codes
use
a
percentage
cost
threshold
for
determining
applicability
of
different
requirements
and
if
so,
what
that
threshold
might
be.
Our
cursory
review
indicates
that
at
least
some
jurisdictions
specify
a
percentage
cost
threshold
for
determining
what
constitutes
a
building
"
improvement,"
and
require
such
improvements
to
comply
with
the
current
code.
A
common
threshold
is
50
percent,
based
on
cost
of
the
improvement
as
compared
to
the
market
value
of
the
pre­
existing
structure.
We
have
placed
further
information
on
what
we
learned
from
our
review
on
this
topic
in
our
docket.
See
Docket
OAR­
2002­
0068;
Document
No.
_____.
