DEFERRAL
OF
EFFECTIVE
DATE
OF
NONATTAINMENT
DESIGNATION
FOR
8­
HOUR
OZONE
NATIONAL
AMBIENT
AIR
QUALITY
STANDARDS
FOR
EARLY
ACTION
COMPACTS
(
EAC)

Proposed
Rule
published
June
8,
2005
(
70
FR
33409)

Docket
#
OAR­
2003­
0090
Public
Comment
Summary
­­
August
15,
2005
1
Docket
No.

OAR­
2003­
0090
Comment
Date
Organization
City,
State
Commenter
Name
Text
of
Comment
Support
for
the
EAC
Program
and
Extension
of
the
Effective
Deferral
Date
0383
July
6,
2005
The
Texas
Commission
on
Environmental
Quality
Austin,
TX
Glenn
Shankle,
Executive
Director
The
Texas
Commission
on
Environmental
Quality
(
TCEQ)
supports
the
U.
S.
Environmental
Protection
Agency's
(
EPA)
proposed
action
to
extend
deferred
effective
dates
for
the
8­
hour
ozone
national
ambient
air
quality
standards
(
NAAQS)
in
certain
Early
Action
Compact
(
EAC)
areas.
Texas
and
the
San
Antonio
EAC
area
have
worked
hard
to
meet
their
obligations
and
are
pleased
to
see
the
EPA
recognize
that
accomplishment.
(
p.
1)

As
a
developer
of
the
EAC
protocol,
Texas
hopes
that
the
EPA
will
continue
to
develop
programs
like
the
EAC
process
that
allow
local
areas
to
pursue
proactive,
flexible
solutions
to
air
quality
issues
that
meet
the
needs
of
local
communities.
(
p.
1)

0385
July
8,
2005
Commonwealth
of
Virginia,

Department
of
Environmental
Quality
Richmond,
VA
John
M.
Daniel,
Jr.,
Air
Division
Director
The
Virginia
Department
of
Environmental
Quality
(
VADEQ)
fully
supports
the
early
action
compact
process
and
this
specific
action
by
EPA.
The
two
EAC
areas
in
Virginia,
Roanoke
and
the
Northern
Shenandoah
Valley,
have
continued
to
meet
all
applicable
requirements
of
the
EAC
program
and
have
made
substantial
progress
in
implementing
proactive
programs
designed
to
improve
air
quality
in
these
areas.
In
fact,
both
these
areas
are
now
in
compliance
with
the
8­
hour
ozone
standard.
(
p.
1)

0386
July
7,
2005
North
Carolina
Department
of
Environment
and
Natural
Resources
Raleigh,
NC
B.
Keith
Overcash,
P.
E.,

Division
of
Air
Quality
The
North
Carolina
Division
of
Air
Quality
(
NCDAQ)
supports
the
decision
to
extend
the
effective
deferral
date
to
December
31,
2006.
As
a
state
agency,
NCDAQ
has
worked
with
both
local
governments,
local
air
agencies
and
private
industry
to
ensure
the
success
of
the
Early
Action
Compact
(
EAC)
program
but
more
importantly,
improve
the
air
quality
in
North
Carolina
as
expeditiously
as
possible.
(
p.
1)

An
example
of
this
collaboration
is
the
support
of
Duke
Power
in
this
effort.
In
compliance
with
the
DEFERRAL
OF
EFFECTIVE
DATE
OF
NONATTAINMENT
DESIGNATION
FOR
8­
HOUR
OZONE
NATIONAL
AMBIENT
AIR
QUALITY
STANDARDS
FOR
EARLY
ACTION
COMPACTS
(
EAC)

Proposed
Rule
published
June
8,
2005
(
70
FR
33409)

Docket
#
OAR­
2003­
0090
Public
Comment
Summary
­­
August
15,
2005
Docket
No.

OAR­
2003­
0090
Comment
Date
Organization
City,
State
Commenter
Name
Text
of
Comment
2
Clean
Smokestacks
Act,
which
requires
coal
fired
power
plants
to
reduce
NOx
emissions
by
78%
by
2009
and
SO2
emissions
by
49%
by
2009
and
74%
by
2013,
Duke
Power
has
agreed
to
accelerate
the
installation
of
Selective
Non­
Catalytic
Reduction
emissions
control
technology
at
the
Marshall
Steam
Station
in
Catawba
County
by
the
2007
ozone
season,
which
will
allow
the
Triad
EAC
area
to
attain
the
National
Ambient
Air
Quality
Standards
sooner.
(
p.
1)

Other
examples
of
ongoing
efforts
to
aid
in
the
improvement
of
air
quality
are
the
Open
Burning
Ban
Rule
&
Outreach,
On­
Board
Diagnostics
(
OBD)
Inspection
and
Maintenance
(
I/
M)
Program,
NC
Ozone
Forecasting
and
Air
Awareness
in
the
EAC
Areas.
On
June
1,
2004,
the
NC
Environmental
Management
Commission
approved
a
rule
to
ban
open
burning
in
NC
during
ozone
season
on
code
orange
and
above
days
for
areas
that
forecast
ozone
levels.
The
majority
of
the
EAC
areas,
as
well
as
surrounding
counties,
are
covered
by
the
no
open
burning
rule.
Additionally,
an
Open
Burning
Outreach
Taskforce
has
been
established
to
educate
the
public
on
the
adverse
effects
of
open
burning
on
air
quality.
(
p.
1)

The
vehicle
I/
M
program
tests
vehicles
using
their
OBD
system
that
indicates
whether
equipment
to
reduce
NOx
and
other
pollutants
are
operating
properly.
Beginning
July
1,
2005,
five
additional
EAC
counties
will
be
subject
to
the
I/
M
program.
By
2006,
48
counties
across
the
state
will
be
subject
to
I/
M
and
many
of
these
counties
are
in
EAC
areas
and
their
surrounding
counties.
(
pp.
1­
2)

In
an
effort
to
inform
and
educate
North
Carolina
citizens
about
air
quality,
NCDAQ
has
a
comprehensive
Air
Awareness
Outreach
Program
and
forecasts
ozone
concentration
levels
in
various
areas
across
the
state.
NCDAQ
forecasts
ozone
concentrations
in
six
areas
including
the
Fayetteville,

Mountain
and
Hickory
EAC
areas.
The
Forsyth
County
Environmental
Affairs
Division,
a
local
air
agency,
forecasts
in
the
Triad
EAC
area.
The
ozone
forecasts
are
issued
daily
from
May
1
through
DEFERRAL
OF
EFFECTIVE
DATE
OF
NONATTAINMENT
DESIGNATION
FOR
8­
HOUR
OZONE
NATIONAL
AMBIENT
AIR
QUALITY
STANDARDS
FOR
EARLY
ACTION
COMPACTS
(
EAC)

Proposed
Rule
published
June
8,
2005
(
70
FR
33409)

Docket
#
OAR­
2003­
0090
Public
Comment
Summary
­­
August
15,
2005
Docket
No.

OAR­
2003­
0090
Comment
Date
Organization
City,
State
Commenter
Name
Text
of
Comment
3
September
30.
During
high
ozone
concentration
days,
citizens
are
encouraged
to
modify
their
outdoor
activities
to
protect
their
health
and
to
take
measures
to
reduce
activities
that
contribute
to
ozone
forming
emissions.
The
Air
Awareness
Program
in
the
EAC
areas
is
a
conduit
for
public
education
and
outreach.
The
main
focus
of
the
program
is
on
educational
outreach
to
understand
and
respond
to
the
ozone
forecast
and
to
utilize
the
media
for
public
service
announcements
so
that
a
broader
audience
can
be
reached.
(
p.
2)

As
shown
in
the
table
below
[
see
docket
number
0386,
p.
2
for
Design
Value
table],
the
design
values
in
these
areas
have
decreased
because
of
the
effectiveness
of
the
various
rules,
programs
and
initiatives
that
have
been
implemented.
All
of
the
monitors
in
the
EAC
areas
except
two
are
currently
attaining
the
8­
hour
ozone
standard.
Those
remaining
two
monitors
show
values
just
over
the
standard,
with
2002­

2004
design
values
of
0.086
and
0.087
ppm.
(
p.
2)

All
of
the
efforts
in
the
EAC
areas
are
benefitting
the
citizens
of
North
Carolina
by
improving
air
quality
sooner.
Therefore,
by
extending
the
deferral
of
the
effective
date
to
December
31,
2005,
the
EAC
areas
will
be
allowed
to
continue
their
efforts
toward
successfully
achieving
attainment
of
the
National
Ambient
Air
Quality
Standards.
(
p.
2)

NCDAQ
is
committed
to
continuing
the
efforts
of
the
EAC
programs
and
ensuring
attainment
and
maintenance
of
the
8­
hour
ozone
standard.
We
applaud
the
Environmental
Protection
Agency's
support
of
the
EAC
program
and
encourage
continued
support
of
the
EAC
efforts.
(
p.
2)

Comments
on
Sufficiency
of
South
Carolina's
EAC
SIP
0381
Southern
Environmental
Law
Center
These
comments
relate
to
EPA's
proposed
deferral
of
the
effective
date
of
nonattainment
designation
for
South
Carolina's
two
nonattainment/
EAC
areas
­
the
Appalachian
area
(
Greenville­
Spartanburg­
DEFERRAL
OF
EFFECTIVE
DATE
OF
NONATTAINMENT
DESIGNATION
FOR
8­
HOUR
OZONE
NATIONAL
AMBIENT
AIR
QUALITY
STANDARDS
FOR
EARLY
ACTION
COMPACTS
(
EAC)

Proposed
Rule
published
June
8,
2005
(
70
FR
33409)

Docket
#
OAR­
2003­
0090
Public
Comment
Summary
­­
August
15,
2005
Docket
No.

OAR­
2003­
0090
Comment
Date
Organization
City,
State
Commenter
Name
Text
of
Comment
4
June
28,
2005
Chapel
Hill,
NC
J.
David
Farren,
Senior
Attorney
Marily
Nixon,
Senior
Attorney
Anderson
counties)
and
the
Central
Midlands
area
(
parts
of
Richland
and
Lexington
counties).
South
Carolina
submitted
an
Early
Action
Compact
State
Implementation
Plan
(
the
"
EAC
SIP")
on
December
29,
2004,
and
submitted
a
proposed
amendment
to
the
EAC
SIP
on
April
20,
2005.
The
EAC
SIP
relies
heavily
on
statewide
measures,
rather
than
enforceable
local
measures,
to
project
attainment
with
the
8­

hour
ozone
maintenance
and
growth
tracking
measure,
discussed
below.
The
State
of
South
Carolina
is
currently
taking
public
comment
on
the
proposed
amendment,
and
SELC
has
submitted
written
comments
to
the
State
docket.
Additionally,
we
are
submitting
these
comments
to
you
because
they
bear
on
EPA's
proposed
finding
that
the
South
Carolina
nonattainment/
EAC
areas
are
making
satisfactory
progress
toward
meeting
the
EAC
milestones.
We
believe
that
South
Carolina
needs
to
do
more
to
show
satisfactory
progress
and
thereby
qualify
for
deferral
of
the
effective
date
of
the
nonattainment
designation
for
its
nonattainment/
EAC
areas
until
December
31,
2006.
(
pp.
1­
2)

SELC
has
commented
repeatedly
to
EPA
and
the
State
of
South
Carolina
on
the
sufficiency
of
South
Carolina's
EAC
SIP,
each
time
renewing
our
call
for
the
inclusion
of
meaningful
air
quality
protection
measures.
One
of
the
measures
SELC
recommended
that
South
Carolina
include
in
its
SIP
is
a
maintenance
and
growth
tracking
provision
comparable
to
the
20­
year
maintenance
requirements
in
the
CAA
§
175A.
The
State
of
North
Carolina
has
such
a
provision
in
its
EAC
SIP,
and
we
pointed
to
the
North
Carolina
provision
as
a
model
for
South
Carolina.
South
Carolina
did
include
a
maintenance
and
growth
tracking
provision
in
its
December
29,
2004
EAC
SIP;
however,
South
Carolina's
version
of
the
maintenance
and
growth
provision
deleted
all
language
containing
a
commitment
to
take
action
to
improve
air
quality.
(
p.
2)

The
proposed
amendment
adds
back
in
some
of
the
"
commitment"­
type
language
­
referred
to
by
the
South
Carolina
Department
of
Health
and
Environmental
Control
("
DHEC")
as
the
"
action
triggers."
DEFERRAL
OF
EFFECTIVE
DATE
OF
NONATTAINMENT
DESIGNATION
FOR
8­
HOUR
OZONE
NATIONAL
AMBIENT
AIR
QUALITY
STANDARDS
FOR
EARLY
ACTION
COMPACTS
(
EAC)

Proposed
Rule
published
June
8,
2005
(
70
FR
33409)

Docket
#
OAR­
2003­
0090
Public
Comment
Summary
­­
August
15,
2005
Docket
No.

OAR­
2003­
0090
Comment
Date
Organization
City,
State
Commenter
Name
Text
of
Comment
5
Again,
however,
important
aspects
of
the
North
Carolina
language
have
been
deleted
or
revised,

rendering
the
maintenance
and
growth
tracking
provision
essentially
nugatory.
For
example,
the
"
action
trigger"
is
not
tripped
until
the
3­
year
design
value
for
8­
hour
ozone
exceeds
0.084
ppm,
which
is
the
applicable
NAAQS.
In
comparison,
the
North
Carolina
action
trigger
is
a
one­
year
design
value
of
0.080
ppm.
The
point
of
including
the
"
action
trigger"
­
indeed,
the
point
of
including
a
maintenance
and
growth
tracking
provision
at
all
­
is
to
provide
an
early
warning
to
the
State
of
high
ozone
levels
that,
while
substantially
below
the
NAAQS
could,
if
unaddressed,
eventually
result
in
failure
to
maintain
the
NAAQS.
Instead,
the
South
Carolina
provision
requires
no
action
at
all
until
the
area
violates
the
NAAQS.
Under
the
Clean
Air
Act,
when
an
area
violates
the
NAAQS
the
proper
procedure
is
for
EPA
to
designate
the
area
nonattainment
for
that
pollutant
and
for
the
area
to
implement
strict
controls,

including
nonattainment
New
Source
Review
and
transportation
conformity,
to
bring
the
area
into
attainment
with
the
NAAQS.
By
delaying
any
action
at
all
until
the
area
violates
the
NAAQS,
the
South
Carolina
provision
provides
nothing
of
substance
for
air
quality
protection
in
the
State.
(
p.
2)

The
South
Carolina
provision
includes
several
other
revision
to
the
North
Carolina
language
that
undercut
the
effectiveness
of
the
provision.
For
example,
South
Carolina's
growth
review
is
not
triggered
until
2008.
Also,
the
State
commits
only
to
"
analyze
the
data"
and
implement
additional
controls
"
as
necessary"
­
both
phrases
obviate
any
real
commitment
to
act,
and
the
commitment
to
adopt
any
new
control
measures
"
as
part
of
the
SIP"
has
been
deleted
from
the
North
Carolina
language.

Further,
in
the
case
of
mobile
source
controls,
there
is
no
commitment
to
implement
controls
on
mobile
sources
to
address
unexpectedly
high
emissions
or
growth.
(
p.
2)

As
we
have
stated
before,
the
EAC
program
is
not
authorized
by
the
Clean
Air
Act.
However,
EAC
proponents
claim
that
the
program
will
lead
to
cleaner
air
faster
than
the
statutory
nonattainment
DEFERRAL
OF
EFFECTIVE
DATE
OF
NONATTAINMENT
DESIGNATION
FOR
8­
HOUR
OZONE
NATIONAL
AMBIENT
AIR
QUALITY
STANDARDS
FOR
EARLY
ACTION
COMPACTS
(
EAC)

Proposed
Rule
published
June
8,
2005
(
70
FR
33409)

Docket
#
OAR­
2003­
0090
Public
Comment
Summary
­­
August
15,
2005
Docket
No.

OAR­
2003­
0090
Comment
Date
Organization
City,
State
Commenter
Name
Text
of
Comment
6
process.
In
response,
over
the
past
two
years
SELC
has
attempted
to
work
cooperatively
and
positively
with
EPA,
the
State
of
South
Carolina,
and
local
EAC
groups
to
improve
South
Carolina's
EAC
program.
We
have
met
with
representatives
of
DHEC
and
EPA
and
have
offered
to
meet
with
the
EAC
groups,
we
have
filed
a
series
of
letters
containing
recommendations
for
strengthening
the
State's
EAC
program
­
we
have
even
identified
specific
provisions
and
suggested
specific
language
to
include
in
the
EACs
to
make
them
as
robust
as
possible.
Many
of
our
suggestions
have
not
been
incorporated
into
South
Carolina's
EAC
SIP
or
­
like
the
20­
year
maintenance
provision
­
have
been
watered
down
so
that
they
are
largely
ineffective.
(
Several
of
our
previous
letters
addressing
improvements
to
South
Carolina's
EACs
are
attached
to
this
letter
as
Attachment
A
and
are
incorporated
herein
by
reference.)

[
see
docket
number
0381,
pp.
5­
58
for
Attachment
A]
Additionally,
we
note
that
the
State
has
resisted
including
in
its
EAC
SIP
certain
of
the
statewide
measures
and
the
full
suite
of
local
measures.
Even
in
the
final
version
of
the
EAC
SIP,
it
is
unclear
whether
the
local
control
measures
are
actually
included
as
enforceable
measures
in
the
EAC
SIP.
DHEC
notes
that
it
is
"
including"
the
local
measures,
and
attaches
them
to
the
EAC
SIP,
but
does
not
expressly
state
that
they
are
part
of
the
enforceable
SIP.
(
pp.

2­
3)

We
still
believe
that
South
Carolina's
EAC
program
needs
strengthening,
as
laid
out
in
our
previous
correspondence
with
EPA
and
the
State.
The
maintenance
and
growth
provision
in
South
Carolina's
EAC
SIP
should
be
revised
to
be
substantially
similar
to
North
Carolina's
EAC
SIP.
We
are
troubled
that
in
response
to
our
recommendation
to
include
the
maintenance
and
growth
tracking
language,
the
State
first
chose
to
delete
the
"
action
triggers"
and
now,
while
purporting
to
add
the
"
action
triggers"

back
in,
proposes
to
weaken
them
so
substantially
as
to
render
them
ineffective.
The
"
action
triggers"

are
critical
to
South
Carolina's
efforts
to
control
emissions
­
particularly
those
from
mobile
sources,
for
which
the
State
included
no
specific,
enforceable
measures
in
its
EAC
SIP,
but
also
for
stationary
DEFERRAL
OF
EFFECTIVE
DATE
OF
NONATTAINMENT
DESIGNATION
FOR
8­
HOUR
OZONE
NATIONAL
AMBIENT
AIR
QUALITY
STANDARDS
FOR
EARLY
ACTION
COMPACTS
(
EAC)

Proposed
Rule
published
June
8,
2005
(
70
FR
33409)

Docket
#
OAR­
2003­
0090
Public
Comment
Summary
­­
August
15,
2005
Docket
No.

OAR­
2003­
0090
Comment
Date
Organization
City,
State
Commenter
Name
Text
of
Comment
7
sources.
(
p.
3)

We
urge
EPA
to
require
South
Carolina
to
make
further
improvements
to
its
EAC
SIP,
including
revising
its
maintenance
and
growth
tracking
provision
as
described
above,
as
a
condition
of
deferral
of
the
nonattainment
designation
for
the
8­
hour
ozone
NAAQS
for
South
Carolina's
two
nonattainment/
EAC
areas.
(
p.
3)

Comments
on
EPA's
Legal
Authority
0382
July
5,
2005
New
York
State
Department
of
Environmental
Conservation,
Division
of
Air
Resources
Albany,
NY
John
T.
Higgins,
P.
E.,

Assistant
Director
The
Department
is
opposed
to
the
proposed
revision
to
40
CFR
Part
81
because
it
does
not
believe
that
EPA
has
legal
authority
to
(
1)
defer
effective
dates
of
designations;
(
2)
enter
into
Early
Action
Compacts
with
areas;
and
(
3)
allow
areas
to
be
relieved
of
obligations
under
Title
I,
Part
D
of
the
Clean
Air
Act
while
they
are
violating
the
8­
hour
ozone
standard
or
are
designated
nonattainment
for
that
standard.
The
Department
notified
EPA
of
its
objection
to
the
EAC
process
in
its
January
15,
2004
letter
(
enclosed)
[
see
docket
number
0382,
pp.
3­
5
for
January
15,
2004
letter)
to
the
EPA
Docket
Administrator.
According
to
Title
I,
Part
D
of
the
CAA,
if
an
area
meets
the
technical
criteria
for
nonattainment
status,
then
it
must
be
subject
to
the
requirements
prescribed
within
the
CAA.
Early
Action
Compacts
do
not
meet
the
requirements
prescribed
within
the
CAA
for
nonattainment
areas.
(
p.

1)

0384
July
6,
2005
The
Northeast
States
for
Coordinated
Air
Use
Management
(
NESCAUM)

Boston,
MA
Arthur
N.
Marin,
Executive
Director
While
the
NESCAUM
states
support
EPA's
efforts
to
afford
nonattainment
areas
flexibility
in
achieving
the
8­
hour
ozone
standard,
we
believe
that
the
specific
mechanism
that
EPA
has
developed
to
provide
such
flexibility,
i.
e.,
the
Early
Action
Compact
framework,
conflicts
with
existing
obligations
under
the
Act.
We
do
not
believe
EPA
has
the
authority
to:
(
1)
defer
effective
dates
of
designations;
(
2)
enter
into
Early
Action
Compacts
with
areas;
or
(
3)
allow
areas
to
be
relieved
of
obligations
under
Title
I,
Part
D
of
the
Clean
Air
Act
while
they
are
violating
the
8­
ozone
standard
or
are
designated
nonattainment
of
that
standard.
We
believe
that
Congress
was
clear
in
prescribing
requirements
for
states
to
ensure
DEFERRAL
OF
EFFECTIVE
DATE
OF
NONATTAINMENT
DESIGNATION
FOR
8­
HOUR
OZONE
NATIONAL
AMBIENT
AIR
QUALITY
STANDARDS
FOR
EARLY
ACTION
COMPACTS
(
EAC)

Proposed
Rule
published
June
8,
2005
(
70
FR
33409)

Docket
#
OAR­
2003­
0090
Public
Comment
Summary
­­
August
15,
2005
Docket
No.

OAR­
2003­
0090
Comment
Date
Organization
City,
State
Commenter
Name
Text
of
Comment
8
progress
toward
attaining
and
maintaining
the
ozone
standard,
and
that
EPA's
memoranda
describing
the
Early
Action
Compact
approach
do
not
meet
those
requirements
and
are,
in
fact,
inconsistent
with
them.
(
pp.
1­
2)

0387
July
8,
2005
American
Lung
Association
Janice
Nolen,
Director
Clean
Air
Task
Force,
Ann
B.

Weeks,
Litigation
Director
Environmental
Defense,
Janea
Scott,
Staff
Attorney
Natural
Resources
Defense
Council,
John
Walke,
Clean
Air
Director
Sierra
Club,
Nat
Mund,
Senior
Washington
Rep.

U.
S.
Public
Interest
Research
Group,
Emily
Figdor,
Clean
Air
Advocate
Previously
filed
comments
demonstrate
that
the
extension
of
effective
dates
until
September
30,
2005,
is
unlawful.
See,
e.
g.,
Letter
to
Air
and
Radiation
Docket
from
Joseph
Bergen
of
ALA
(
January
15,
2004),

Doc
#
OAR­
2003­
0090­
0106,
attached
hereto
as
Ex.
A.
[
see
docket
number
0387,
pp.
3­
8
for
previously
filed
comments]
For
those
same
reasons,
the
further
extensions
described
in
EPA's
June
8,
2005
notice
are
likewise
unlawful.
(
p.
1)

As
grounds
for
the
extensions,
EPA's
June
8
notice
cites
measures
undertaken
to
control
ozone
pollution.
70
Fed.
Reg.
33410.
While
the
undersigned
strongly
support
efforts
to
control
ozone
pollution,
such
efforts
can
be
expeditiously
achieved
without
jettisoning
the
statutory
requirements
for
attaining
and
maintaining
the
NAAQS.
(
p.
2)

Comments
on
"
Significant
Regulatory
Action"

0382
July
5,
2005
New
York
State
Department
of
Environmental
Conservation,
Division
of
Air
Resources
Albany,
NY
In
addition,
the
Department
does
not
concur
with
EPA's
assessment
that
the
proposed
rule
does
not
constitute
a
"
significant
regulatory
action"
(
see
70
FR
33412),
as
the
Department
believes
that
condition
4
of
that
finding
has
been
met
(
raise
novel
legal
or
policy
issues
arising
out
of
legal
mandates,
the
President's
priorities,
or
the
principles
set
forth
in
the
Executive
Order.)
(
p.
1)
DEFERRAL
OF
EFFECTIVE
DATE
OF
NONATTAINMENT
DESIGNATION
FOR
8­
HOUR
OZONE
NATIONAL
AMBIENT
AIR
QUALITY
STANDARDS
FOR
EARLY
ACTION
COMPACTS
(
EAC)

Proposed
Rule
published
June
8,
2005
(
70
FR
33409)

Docket
#
OAR­
2003­
0090
Public
Comment
Summary
­­
August
15,
2005
Docket
No.

OAR­
2003­
0090
Comment
Date
Organization
City,
State
Commenter
Name
Text
of
Comment
9
John
T.
Higgins,
P.
E.,

Assistant
Director
