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OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

101) IV-C-15 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:22 AM Sheet 101 of 142 
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~ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

2 RESEARCH TRIANGLE PARK, NC 27711 JM ~ C - \S 

JUL 2 6 (999 

OFFICE OF 

AIR QUALITY PLANNING 

Mr. A. D. Correll AND.STANBARDS 

Chairman of the Board and Chief Executive Officer 

Georgia-Pacific Corporation 

133 Peachtree Street, NE 

P. 0. Box 105805 

Atlanta, GA 30348 

Dear Mr. Correll: 

This is in response to your letter of July 6,1999 to Robert Perciasepe in which you 

expressed your 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 Georgia-Pacific 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 Geogia-Pacific'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, 

i John q7 Seitz 

L Director 

Officetof Air Quality Planning 

Recycled/Recyclable . Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer) 
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07/13/99 TUE 10:46 FAX _005 

Georgia-fecific Corporation OMft :WK 

AD. Correll 

Chairman of the Board and 

Chief Executive OtHoer 

1331 

P.O.Box 10SOOS 

Atlanta, QA 30348 

Telephone (404) 65*4217 

r 

July 6,1999 

The Honorable Robert Perciasepe 

Assistant Administrator for Air 

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

Dear Bob: 

We are concerned about the actions that EPA may take on the reform of the New Source Review 

Program. EPA has been engaged, since February 1999, 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; and with the seriousness with which they were developed. We 

are very concerned to learn that EPA staff have decided to recommend moving forward with the 

Agency's existing NSR proposals with what appears to be no regard for the numerous ideas generated 

through the stakeholder process. This outcome is particularly concerning in light of die enormous 

impact the NSR regulations have on states and regulated industries alike. We are writing to urge you to 

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

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

known that the complexities of the current system impose enormous burdens on states and regulated 

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

develop what we believe are workable reform concepts. To have that effort ignored at the end of the day 

seems unreasonable. 

As chairman of the environment committee for AF&PA, we 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 die end, yield no measurable results. However, we strongly believe that 

there is a proper balance between allowing endless debate versus abruptly suspending discussions when 

a workable solution is within reach. We are confident mat, 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. 

Sincerely, 

ADC 

cc: Mr. J. E. Bostic 

Ms. A. Schaffer- AF&PA 

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