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OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

134) IV-C-48 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:24 AM Sheet 134 of 142 
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A-90-37 

IV-C-48 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

JUN 1 4 2002 

Mr. Ralph Paige 

The Federation of Southern Cooperatives 

Land Assistance Fund 

2769 Church Street 

East Point, Georgia 30344 

Dear Mr. Paige: 

Thank you for your letter dated April 9,2002, to President Bush, in which you expressed 

concerns regarding changes the Environmental Protection Agency (EPA) is considering for the 

New Source Review (NSR) program and its possible impact on farmers. Your letter was 

forwarded to me for a reply. I believe the concerns you raise deserve serious consideration, and I 

want to respond to the points you raised and to update you on our NSR efforts. 

In May 2001, the EPA initiated a review of the NSR program in response to a 

recommendation from the President's National Energy Policy Development Group. The EPA is 

examining the impact of the NSR regulations, including administrative interpretation and 

implementation, on investment in new utility and refinery generation capacity, energy efficiency 

and environmental protection. As part of this process, we have heard comments from over 

130,000 individuals and organizations. A significant number of these comments raise concerns 

very similar to those in your letter about how the EPA's interpretation of the "routine 

maintenance, repair and replacement" exclusion from NSR can impact electric generators and 

other sources. Your letter indicated that your members cannot afford increased electricity costs 

and uncertainty of service. You also pointed out that if peaking units are taken offline to 

comply with NSR requirements, then you have a concern that it will affect your access to 

electricity when your members need it most. Other commenters are very concerned that the 

environmental improvements associated with the NSR program not be lost as we consider ways 

to improve the program. I assure you we are considering these comments fully as we move 

forward. Soon, the EPA plans to report to the President on the impact of NSR on the three areas 

mentioned above. At that time, we will make recommendations on whether improvements to the 

NSR program are needed to provide more flexibility and certainty while ensuring protection of 

the environment. I believe we can meet the requirements of the Clean Air Act without 

jeopardizing farmers'- and the Nation's- reliable, affordable energy supplies. Thank you for 

sharing your views. 
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Again, thank you for your letter. I appreciate the opportunity to be of service and trust 

that the information provided is helpful to you. 

Sincerely, 

ThomaS C. Curran 

Office of Air Quality Planning 

and Standards 
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05/20/02 14:07 FAX 2024019505 

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OAR IMM OFF SHERRY RUSSELL Sl 005/006 

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$Q « K' fcfr\ The Federation of Southern Cooperatives 

Av-**~ Land Assistance Fund 

i ^ il(~***?t(-\ ? l /) Public Relations and Fundraising Office 

. (JQHP^M^ ' 2769 Church Srreet 

East Point, GA 30344 

RALPH PAIGE 

EXECUTIVE DIRECTOR 

Board of Directors 

President 

Woodro-A Keown 

ARKANSAS 

Telephone (<*0*) "JeS-tmi 

Facsimile (-KM) 76S-917S 

E-Mail fscgmind5pring.com 

w w . r<dcniien^ou(hrrncoop .com 

Vice-President 

Norwood Davis 

LOUISIANA 

Treasurer 

Curtis Inabinert 

April 9. 2002 

The Honorable George W. Bush 

President 

The White House 

1600 Pennsylvania Ave NW 

SOUTH CAROLIMfcLslungton, DC 20500 

Secretary 

Shirley Blakely 

MISSISSIPPI 

Satina James 

GEORGIA 

Pearl Long 

FLORIDA 

Martie Mack 

KENTUCKY 

MISSOURI 

Re: New Source Review 

Dear Presi dent Busru 

The Federation of Southern Cooperatives/Land Assistance Fund works with 

minority fanners in some of the most depressed areas of the country to try to slow 

the stream of minority landowners leaving their land. One of the major reasons for 

this loss of minority-owned land is the historically low prices and minimal service 

fanners are receiving for their commodities. The Federation of Southern • 

Cooperatives works on a variety of cooperative development programs to make life 

in rural Southeastern America a reliable endeavor. 

For that reason, I would like to urge vou to considecjhej±ftng^g >hf> Fnyjmnmenjal 

ProtectjorjAgencv is proposing forthe New Source Review progjarn.. Any changes 

that is going to have a negative impact on our Farmers in the Southeast should not 

Daniel Bust3mantebe acted upon with fully understanding the ramifications h will have. 

TEXAS 

Farmers all over this country are the best stewards of tiie land, with which, where 

would be grow our crops? We do not warn to pollute the environment just like the 

next person. Many of the activities, which would trigger a New Source Review, 

are no more than routine maintenance or replacing a faulty pan, not causing any 

increase in emissions. 

Eddie Avers 

ALABAMA 

Chaplain 

G.L. Twirty 

AT LARGE 

Edward Cline 

AT LARGE 

Robert S. Browne 

AT LARGE 

Rural Training 

and 

Research Center 

P.O. Box 95 

Epes. AL 35460 

The Federation of Southern Cooperative's main concern is who is ultimately going 

ro pay for these rules and regulations unnecessarily placed on routine maintenance? 

The end user! Our members cannot afford increased electricity costs and 

uncertainty of the service. We are the one's at the end of the line and if a peaking 

plant is taken off line for possibly months to comply with the New Source Review 

Combined Federal Campaign Number: J 607 
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05720/02 14:08 FAX 2024019505 

0-5.-J3.-02 WED 18:07 FAX 

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The Honorable George W Bush 

April 9,2002 

Page 2 

program, that is going 

most. 

to greatly affect our access to electricity when we need it the 

Agricultur The e is one of the most energy intensive industries in the country T 

Environmental Protection Agency needs to understand the implicanon their rales 

and regulations are going to cause. We, TOO, are environmental by trade, but do not 

understand The need to change a a.le that for all practical purposed, worked 

reasonable well. 

Coop 

Ralph Parge ' ? 

Executive Director