Conference Call Documentation

Subject: EPA/National Association of Clean Air Agencies (NACAA)
Conference Call on ICR Renewal for New Source Review – Summary of
Questions and Comments Received.

Date of Call: January 9, 2008

Participants

EPA: Michael Ling, Associate Director, OAQPS; Juan Santiago, Group
Leader, OPG; Carrie Wheeler, Environmental Protection Specialist, OPG

National Association of Clean Air Agencies (NACAA) Permitting Committee
Monthly Conference Call Attendees

Background:

EPA revising the ICR for New Source Review (set to expire on January 31,
2008)

First FR notice asking for comments issued late November 2007

Active consultation required in addition to public comment

Purpose of call on January 9 – to clarify the burden estimate

Comments/Questions from NACAA and EPA Response

NACAA Comment:  A representative from Iowa mentioned that in the minor
NSR category in some cases one action may take multiple permits. It may
take only a fraction of the time estimated by the EPA for each permit
(5-6 hrs); however, the total of all the permits for one action may
equal the 30 hr estimate.

EPA Response:  The EPA is looking for a nationally representative
estimate of the average number of hours required to process a permit.
Requested input from other call participants across the country
regarding this issue.

NACAA Question:  A representative from Illinois asked if the burden
estimate took into account hearings.

EPA Response:  The burden estimate does take into account public
hearings during the permit process.

NACAA Question:  A representative from New Hampshire asked if the burden
would vary if air toxics are involved. For his example, the burden hours
will be very different if a source is strictly combustion (i.e. running
on natural gas) versus an operation operating utilizing something other
than a common fuel. Those in the latter category have a higher burden.

EPA Response:  We are focusing strictly on new source review, and that
we are looking for an average number for all varieties of permits within
the three categories of Part C, Part D, and Minor NSR permits

NACAA Comment:  The New Hampshire representative commented that some of
the items may not strictly be NSR-related, but that it can be reflective
of the problems in dealing with minor NSR permits

NACAA Question: A representative from Indiana asked whether to include
things such as attorney hours and appeals.

EPA Response:  While the estimate covers things such as public hearings
during the permit process, we will need to determine whether or not
actions taken (such as law suits or appeals) after the permit process
should also be factored into these burden estimates.

EPA Comment:  Any additional comments can be sent in the manner most
convenient for the Committee. 

NACAA:  Concluded by setting a due date of Friday, January 25 for
submittals.

