From:
John
Silvasi
To:
Art
Fraas,
Amy
Flynn
Subject:
*
8­
hour
Ozone
NAAQS
Implementation
Rule
Hello,
Art
and
Amy,

I'm
attaching
updated
sections
of
our
8­
hour
ozone
NAAQS
implementation
rulemaking
(
phase
2)
for
several
topics.
These
updates
are
intended
to
address
the
concerns
Art
had
mentioned
in
a
phone
call
to
Lydia
Wegman
around
April
27.
The
topics
and
concerns
were:

Long­
range
transport
­­
Address
the
fact
that
CAIR
has
been
issued
and
the
impact
of
CAIR
on
ozone
(
done)
Reasonable
Further
Progress
(
RFP)
Address
the
fact
that
CAIR
had
been
issued
(
done)
Express
support
for
the
100/
200
km
policy
and
indicate
what
the
likely
outcome
will
be
after
reconsidering
the
policy
in
light
of
Inspector
General
report
(
done)
Concern
about
the
final
increment
of
progress
being
more
than
needed
for
attainment
(
actually
we
don't
think
this
will
occur
and
the
revision
explains
why)
Concern
about
subpart
1
areas
with
attainment
dates
beyond
5
years
being
required
to
show
proportional
reductions
out
to
the
attainment
date.
We
are
not
exactly
sure
how
to
address
this
concern.
I
don't
believe
we
have
any
problem
with
requiring
some
form
of
"
non­
proportional"
reductions,
but
there
are
many
variations
on
how
to
do
this.
For
instance,
instead
of
proportional
(
e.
g.,
half
the
reductions
in
half
the
time
and
the
remaining
half
by
the
attainment
date),
we
could
require
1/
3
reductions
in
1/
2
the
time,
1/
4
reductions
in
half
the
time,
etc.
etc.)
A
conversation
with
you
might
help
us.
You
should
be
aware
that
we
did
not
receive
any
specific
comments
opposing
the
proportional
reduction
concept.
Additionally,
we
only
expect
one
area
in
the
East
(
possibly
one
or
a
few
in
the
West)
to
be
in
this
situation
(
subpart
1
area
with
attainment
date
beyond
2010).
Reasonably
Available
Control
Technology
(
RACT)
­­
Address
CAIR
and
RACT
(
done)

In
addition,
we
have
revised
the
RFP
section
to
say
we
are
making
the
clean
data
policy
a
final
rule;
as
part
of
that
set
of
revisions,
there
is
now
much
more
additional
discussion
with
legal
references,
and
revisions
to
some
of
the
responses
to
comments.

The
attachments
are
redline/
strikeout
versions
compared
to
the
2/
6/
05
version
under
review
at
OMB.
There
are
other
portions
of
the
rulemaking
notice
that
we
have
had
to
revise
for
corrections,
etc.,
and
we
will
be
sending
you
a
revised
version
with
a
description
of
any
significant
changes.

Please
let
us
know
whether
there
are
other
comments
that
you
wish
to
provide.

Best
wishes!

John
J.
Silvasi
Environmental
Engineer
Ozone
Policy
and
Strategies
Group
(
C539­
02)
Office
of
Air
Quality
Planning
and
Standards
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
919­
541­
5666
(
v);
919­
541­
0824
(
fax)
silvasi.
john@
epa.
gov
