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OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

103)IV-C-17 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:22 AM Sheet 103 of 142 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY A " J 0 - 3 7 

RESEARCHTRIANGLEPARK.NC 27711 H f ~ £- — I 7 

JUL 2 6 I999 

Mr. W. Henson Moore 

President and Chief Executive Officer 

American Forest & Paper Association 

llll Nineteenth Street, NW, Suite 800 

Washington, DC 20036 

Dear Mr. Moore: 

OFFICE OF 

AIR QUALITY PLANNING 

ANBSTANDARDS 

This is in response to your letter of July 12,1999 to Robert Perciasepe in which you 

expressed your association's concerns regarding the recent developments of the New Source 

Review (NSR) Reform project. As your letter indicated, the U.S. Environmental Protection 

Agency (EPA) has recently received proposals from various industry groups and other 

stakeholders, and I can assure you that those proposals are being carefully reviewed and fully 

considered as we move forward to promulgation of the NSR Reform rules. 

The EPA remains committed to an appropriate exchange of ideas and to reaching 

workable solutions on the remaining NSR Reform issues. At the same time, we recognize a need 

to balance the time demands of reopening the dialogue with the need to stay on track and reach 

closure within the coming months. You may be pleased to learn that we are scheduling meetings 

with representatives from the major stakeholder groups to allow for an additional opportunity for 

dialogue. The meeting with the National Environmental Development Association's Clean Air 

Regulatory Project, of which the American Forest & Paper Association (AF&PA) is a member, 

is currently scheduled for August 18,1999. The results of these discussions will help inform our 

senior management as final decisions are made on this rulemaking. 

I truly appreciate the AF&PA's continued interest in this important environmental 

rulemaking and the time that you have invested toward offering ideas throughout its 

development. We are making every possible effort to understand and consider all stakeholder 

perspectives prior to issuing final regulations. 

Sincerely, 

iohi£sfSeitz 

JLpirector 

Office c^f Air Quality Planning 

and Standards 

Recycled/Recyclable .Printed with Vegetable OH Based Inks on 100% Recycled Paper (40% Postconsumer) 
Controlled Correspondence For 

OFFICE OF AIR AND RADIATION 

P.3 

CONTROL NO: OAR-9900936 

STATUS: 

ORIG. DUE DATE: 

CORRES. DATE: 

RECEIVED DATE: 

ASSIGNED DATE: 

CLOSED DATE: 

07/12/99 

07/15/99 

07/15/99 

FROM: 

ORG: 

SALUTATION: 

CONSTITUENT: 

W.HENSON MOORE 

AMERICAN FOREST & PAPER ASSOCIATION 

TO: 

TO ORG: 

SUBJECT: 

PERCIASEPE.ROBERT 

OAR 

PROPOSALS TO REFORM THE AGENCY'S NEW SOURCE REVIEW PROGRAM. 

ASSIGNED: Office of Air Quality Planning & Standards - RTP 

COPIES OF INCOMING PROVIDED TO: 

rp]Q 

SIGNATURE: 

OAR COMMENTS: 

ADDED ON: 07/15/99 FROM RUBY CONLEY/DC/USEPA/US -CC TO 

PRECIASEPE„BRENNER 

OAR INSTRUCTIONS: 

Lead 

Assigned 

OAQPS 

Date Assigned 

07/15/99 

Code/Status 

NECESSARY ACTION 

Date Completed by 

Assignee 

-

Date Returned to 

OAR: 

-

(Untitled) 2. 
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AMERICAN FOREST & PAPER ASSOCIATION Ju,y ,2 ]9g9 j_J_^J^ 

I ® Office of the President 

The Honorable Robert Perciasepe 

Assistant Administrator for Air and Radiation (6101) 

U.S. Environmental Protection Agency 

401 M Street SW 

Washington, DC 20460 

Dear Mr. Perciasel 

EPA has been engaged, since February of this year, in discussions with stakeholders in an effort to 

develop proposals to reform the Agency's New Source Review program.. All stakeholders, including regulated 

industries, have invested significant time and resources in this process believing that their concepts will be 

considered in good faith, reflecting the seriousness with which they were developed. AF&PA members and staff 

have met with you and other EPA representatives twice since last fall to discuss our major concerns with the 

existing program and to convey our desire to seek reforms which would encourage investment in new 

technologies. 

Therefore, AF&PA is very concerned to learn that EPA staff apparently have decided to recommend 

moving forward with the Agency's existing NSR proposals with little regard for the numerous ideas generated 

through the stakeholder process. This outcome is particularly troubling in light of the enormous impact the NSR 

regulations have on states and regulated industries alike. I am writing to urge you to allow stakeholder 

discussions to be completed prior to finalizing any NSR reform package. 

It is well known that EPA staff have acknowledged the need for reform of the NSR rules. The 

complexities of the current system impose enormous burdens on states and regulated industries is also well 

known. Perhaps less recognized is the level of effort recently put forth by industry representatives to develop 

what we believe are workable reform concepts. To have such efforts ignored at the end of the day seems 

inappropriate. It also could have a chilling effect on the willingness of stakeholders to contribute to the 

development of new rules and policies in the future. 

I understand your desire, as Assistant Administrator for Air, to ensure that the Agency does not become 

embroiled in months or even years of stakeholder discussions that, in the end, yield no measurable results. The 

forest products industry strongly believes, however, that there is a proper balance between allowing endless 

debate versus abruptly suspending discussions just when a workable solution is within reach. AF&PA members 

and staff are confident that, given a little more time, the stakeholder process will result in a set of reform 

concepts that can be supported by the many stakeholders involved, including EPA, states, regulated industries, 

and the environmental community. We urge you to allow stakeholder discussions to be completed so that such 

an outcome can, in fact, become a reality. 

With kindest personal regards, I remain, 

Sincerely yo 

3 W. Henson Moore 

President and Chief Executive Officer 

1111 Nineteenth Street. NW, Suite 800 • Washington, DC 20036 i 202 463-2700 Fax: 202 463-2040 

America's Forest & Paper Peoples-Improving Tomorrow's Environment Today*