### Request for comment deadline extension - chemical sector proposal

Emma Cheuse to: Amy Branning, Wendy Blake, Katz, Adam (ENRD),

Chuck French, Nick Parsons, 'pepper.tavara@epa.gov' 03/02/2012 03:46 PM

Cc: James Pew History: This message has been forwarded.

* Confidential & Privileged Settlement Communication * Dear All, The deadline for public comment on EPA 's proposed rule for certain chemical sector sources, 77 Fed. Reg. 1268 (Dkt. EPA-HQ-OAR-2011-0435), is currently next Friday, March 9. Sierra Club would like to request that the agency extend the public comment period by 60 days. Due to other deadlines, key people whom Sierra Club needs information and assistance from in order to be able to submit effective comments have advised us that they require more time to be able to do so . We also believe this extension will assist other concerned citizen groups who have not yet been able to review the rule , and have advised us that it is unlikely that they will be able to do so effectively before the current deadline. Of course, it would equally provide more time to all other members of the public who may wish to have more time to comment on this rule . Aside from the problem with key people being unavailable , this rulemaking involves multiple source categories and multiple sub -categories, and many different emitted pollutants. Because EPA's proposals for these source categories are all combined in this rulemaking , it is particularly time-consuming to attempt to divide EPA's analyses for each source category in the docket, and find and consider each element of its proposal separately for each source category. We are aware that EPA has frequently extended public comment deadlines in response to requests from industry representatives who wished to comment on other RTR rules. We would greatly appreciate your willingness to provide us with the additional 60 days that we need to provide meaningful , informed comment on this rule proposal. Because the final rule is not due until November 30, 2012, we do not believe that this extension should delay the rule . If the comment deadline were extended from March 9 until May 9, that would still provide nearly 7 months for EPA to review and respond to comments . For other rules, EPA has found 5 months to be sufficient time between the comment deadline and the final rule deadline. We have consulted with the appropriate people whose help we need , and an extension shorter than 60 days would be helpful, but unlikely to provide sufficient time for us to comment effectively . This is in part because some of the same people are also working on other EPA rules that have deadlines in the meantime. Sierra Club would very much like the opportunity to fully evaluate the rule proposal and to provide sufficient information and comments that may be helpful to EPA as it considers what action to take on this rule proposal . Thank you very much for your consideration of this request . Please let usknow if there is a good time for us to discuss this by phone

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We would be grateful for your response as soon as possible . Best, Emma Cheuse

__________________________________ Emma Cheuse Senior Associate Attorney Earthjustice 1625 Massachusetts Avenue, N.W. Suite 702 Washington, DC 20036-2243 T: 202-745-5220 or 202-667-4500 ext. 5220 F: 202-667-2356 www.earthjustice.org The information contained in this email message may be privileged , confidential and protected from disclosure . If you are not the intended recipient, any dissemination, distribution or copying is strictly prohibited . If you think that you have received this email message in error , please notify the sender by reply email and delete the message and any attachments . *Please consider the environment before printing .