Lydia Wegman/RTP/USEPA/US 

06/04/2008 03:24 PM

	

To

hking@omb.eop.gov, afraas@omb.eop.gov

cc

evans.ron@epa.gov, Orlin.David@epamail.epa.gov, kaufman.kathy@epa.gov,
rodriguez.rosalina@epa.gov, Tricia Crabtree/RTP/USEPA/US@EPA

Subject

A suggestion for moving forward on the lead NAAQS RIA and timing for
issuance of the final RIA



Hi Heidi and Art,

I've just returned from being away for nearly two weeks and as far as I
can tell, Bob Meyers and Art have not yet discussed the question of
whether we include additional analyses based on different C-R functions
in the proposed lead NAAQS RIA.  In light of the continuing delay in
resolving this question and thereby moving forward on the proposed RIA,
I would like to suggest that we simply decide not to issue a proposed
RIA for lead.   We have already begun work on the final RIA and hope to
brief you within about two weeks on the changes we plan to make in the
final, compared to the draft proposed RIA that you've reviewed.   At
this point, given the incredibly tight schedule for completing the lead
rule, I see little virtue in our spending time drafting and your
spending time reviewing, and all of us spending time discussing, the
characterization of the results of the additional C-R analyses.

In addition, I understand from Ron that Heidi has noted that Art has
some other changes he wanted us to making concerning the
characterizations of costs and benefits in the proposed RIA, though we
have not yet heard what those are.  Again, rather than spinning our
wheels further on the proposed RIA, I think we would do best to move on
to the final RIA and determine how to address Art's concerns in the
context of the document.  As you know, we have already committed to
including the additional C-R functions and air-to-blood ratio analyses
in the final RIA, so we can include a discussion of how to characterize
those results in our discussions in a couple of weeks about the final
RIA. 

Please let me know if you think this approach will work.  I have not yet
discussed it with my management or OPEI as I wanted to get your reaction
before proceeding further. 

I also want to note again what I explained to Heidi concerning the
timing for completion of the RIA.  The court order requires us to
complete the lead rule and all tasks necessary for implementation by
September 15.   Our lawyers at both DOJ and OGC have told us that they
interpret this aspect of the court order to include the RIA.   Thus,
they have told us that the RIA, as well as the rule and  the
implementation and monitoring provisions, must all be completed by
September 15.   I wanted to ensure that you were aware of that so that
we can avoid any last minute discussions of that issue.  Please let me
know that you concur with this plan, or, if not, the basis for your
difference of opinion.   

Thanks very much. 

Lydia





