Mr.
Joe
J.
Mayhew
Vice
President,
Regulatory
and
Technical
Affairs
American
Chemistry
Council
1300
Wilson
Boulevard
Arlington,
VA
22209
Dear
Mr.
Mayhew:

Thank
you
for
your
August
12
letter
to
Assistant
Administrator
Jeff
Holmstead,
in
which
you
expressed
concern
over
Agency
policies
for
periodic
and
sufficiency
monitoring
required
under
the
part
70
operating
permits
regulations.
Your
letter
was
forwarded
to
me
for
a
reply.
I
appreciate
your
comments,
which
raise
important
policy
and
legal
issues.

I
recognize
the
impact
that
monitoring
requirements
can
have
on
companies
in
the
chemical
industry,
and
I
appreciate
your
continuing
recommendations
about
how
requirements
may
be
implemented
to
be
effective
while
minimizing
burdens
on
the
regulated
community.
You
also
outline
several
legal
issues
in
response
to
briefs
we
filed
on
litigation
related
to
these
issues.
While
I
can
not
at
this
time
respond
to
the
legal
points
you
raise,
I
am
following
this
litigation
with
interest.
I
want
to
emphasize
that
regardless
of
outcome
of
the
litigation,
we
are
committed
to
working
with
the
regulated
community
to
effectively
address
your
concerns
about
Title
V.

Also,
in
your
letter,
you
raised
concerns
that
the
Agency
is
trying
to
revise
its
operating
permits
rules
in
an
unlawful
manner;
rest
assured
that
any
future
action
we
undertake
on
these
requirements
will
conform
with
the
requirements
of
the
Administrative
Procedure
Act
and
the
Clean
Air
Act.
I
encourage
you
to
submit
written
comments
on
any
rules
we
might
propose
relating
to
these
requirements,
and
I
will
fully
consider
your
comments
in
that
context.

Again,
thank
you
for
your
letter.
I
appreciate
the
opportunity
to
be
of
service
and
trust
the
information
provided
is
helpful.

Sincerely,

Steve
Page,
Director
Office
of
Air
Qaulity
and
Planning
and
Standards
Enclosure
