Jim
Ketcham­
Colwill/
DC/
USEPA/
US
08/
30/
2005
10:
04
AM
To
John
Silvasi/
RTP/
USEPA/
US@
EPA
cc
Amy_
E._
Flynn@
omb.
eop.
gov,
Arthur_
G._
Fraas@
omb.
eop.
gov,
Denise
Gerth/
RTP/
USEPA/
US@
EPA,
Jan
Tierney/
DC/
USEPA/
US@
EPA,
Kevin
McLean/
DC/
USEPA/
US@
EPA,
Lydia
Wegman/
RTP/
USEPA/
US@
EPA,
Robert
Meyers/
DC/
USEPA/
US@
EPA,
Tom
Helms/
RTP/
USEPA/
US@
EPA
Subject
Re:
Revised
RACT
section
(
8­
hr
O3
NAAQS
implementation
rule/
phase
2)
&
RFP
section
revisio
John,

Thanks
for
doing
this.

There
is
one
sentence
that
is
duplicated
­­
see
end
of
the
redline
paragraph:

However,
even
where
a
State
allows
opt­
ins
from
other
source
categories
to
meet
CAIR
emission
levels,
if
a
State
transitions
from
the
NOx
SIP
cal
level
of
control
to
CAIR
by
the
first
two
transition
options
for
non­
EGUs
discussed
above,
the
NOx
RACT
requirement
would
be
met
for
EGUs
(
and
the
State
would
not
need
to
conduct
RACT
analyses
for
these
EGUs)
if
the
Stat
retains
a
summer
season
EGU
budget
under
CAIR
that
is
at
least
as
restrictive
as
the
EGU
budget
that
was
set
in
the
State's
NOx
SIP
call
SIP.
Otherwise,
the
State
would
need
to
conduct
RACT
analyses
for
EGUs
(
either
on
an
individual
basis,
or
using
the
averaging
approach
within
th
nonattainment
area).
In
either
event,
the
State
would
need
to
conduct
RACT
analyses
for
EGUs
(
either
on
an
individual
basis,
or
using
the
averaging
approach
within
the
nonattainment
area).
[
zzz
DO
WE
KEEP
THIS
FOOTNOTE?]
