UNITED STATES ENVIRONMENTAL PROTECTION**A-~~D!'::EP::::A::::Rf:;::M::;ENT~O:;cF,--,1** WASHINGTON, D.C. 20460**EN'JlRON:/EN~.~LOUALilY**

The Honorable Peggy Hatch Secretary 

# APR 12 2012

Louisiana Department ofEnvironmental Quality 602 North Fifth Street, #I022 Baton Rouge, Louisiana 70802 Dear Ms. Hatch: 

## APR 

## 1 7 ZOlZ
OFFICEOFTHE SECRETARY
OFFICE OF AIR AND RADIATION

I am writing today to update you on the status ofthe U.S. Environmental Protection Agency's efforts to implement the !-hourprimary National Ambient Air Quality Standard (NAAQS) for sulfur dioxide (S02 ) promulgated in June 2010. As you know, the EPA has not issued implementation guidance for the standard, and states and other stakeholders have identified a number ofconcerns in response to the draft guidance the EPA published for comment last year. The S02NAAQS will reduce human exposure to high short-term S02concentrations and provide increased health protection to millions ofAmericans. Meetingthe standard will reduce cases of aggravated asthma and chronic bronchitis and will cut down on hospital admissions, emergencyroom visits, and work days lost due to illness. The promulgation ofthe S02NAAQS in 20I0 set in motion a series ofsteps required under the Clean Air Act (Act), including: (I) designating areas as meeting ornot meeting the S02 standard, and (2) developing state implementationplans (SIPs) for implementation ofthe standard. The Act calls for states to submit two components ofthese SIPs. The first is a plan for implementation, maintenance and enforcement ofthe standard in all areas ofthe state (due by June 2013). The second is a plan for areas designated as not meeting the standard to reduce emissions necessary to attain the standard within the time period required by the Act (due within eighteen months ofeach area's nonattainment designation). To address each ofthe steps identified above, we intend to initiate the following actions:

• We will move forward with the area designations process as soon as possible. We are continuing ourworkto analyze and respond to the recommendations you made last June and expectto issue letters required by the statute to the Governors in the near future providing our intended area designations.

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper• Second, we will initiate focused stakeholderoutreach in the near future to help us refine our approach for detennining whether air quality in a given area is meetingthe S02NAAQS. In these discussions, we will ask stakeholders to provide the EPA with input on monitoring, modeling and implementation issues, particularly for areas that will be designated as "unclassifiable."

• In light ofthe potential this process has to affect ourrecommendations for howto address the S02NAAQS in areas initially designated "unclassifiable," we no longer expect your state'sJune 2013 SIP submittalsto contain modeling demonstrations showing attainment ofthe standard in unclassifiable areas, as was outlined in the final S02NAAQS rule and described further in the draft implementation guidance. Thisparallel approach will ensure that we make progress toward cleaner air in areas with monitored violations ofthe standard, while we take the time necessary to address significant concerns that state agencies and other stakeholders have raised concerning our previously recommended implementation approach for currently unmonitored areas. Stakeholder Outreach: We want to make sure we fully understand the views ofthe states, tribes and other stakeholders, and have an opportunityto discuss workable approaches to implementation ofthe 20I0 standard. In particular, we believe it would be helpful to discuss two maintopics: (I) howbest to assess compliance with the S02NAAQS (e.g., by defining and establishing a robust, representative monitoring network for S02 across the country and/orby applying the appropriate modeling approach), and (2) howto implementthe new approach (e.g., implementation options and SIPtimelines for areas in which violations are identified). We believe that holding additional discussions with states, tribes, and other stakeholders will result in an improved approach that better addresses the many concerns that were raised on the EPA's draft guidance. We intend to move forward quickly with organizingthese stakeholder meetings and would welcome participation by the State ofLouisiana. We will separately provide more details onthis effort at: http://www.epa.gov/airquality/sulfurdioxide/implement.html. Followingthese meetings, we will proceed expeditiouslyto issue revised guidance and/or undertake rulemaking, as appropriate. StateImplementation Plan Submittals: Regarding the SIP submittals due in June 2013, we expectthat the EPA's discussions with stakeholders about howbestto implementthe NAAQS may result in changes to ourpreviously described recommendations for implementing the so2 standard in unclassifiable areas. Therefore, we recommend for nowthat states focus their 2013 SIP submittals on the traditional infrastructure elements ofClean AirAct sections IlO(a)(l) and (2), rather than on modeling demonstrations showing future attainment ofthe standard by a fixed date for unclassifiable areas. Following the stakeholder discussions, we expect to describe in a future rulemaking any further SIP actions that would be necessary to implement the resulting approach. Ifyour state has begun modeling, however, and wishes to continue that work, we will be glad to work with you. Designations: Finally, regarding area designations, the EPA intends to move forward with the designations process currently in progress as quickly as possible, focusing on areas with sufficient ambient air quality data. We are continuing ourworkto analyze and respond to the recommendations you made last June.

### I appreciate your interest in this issue and welcome the opportunity to work with the State ofLouisiana in developing workable approaches to delivering the important public health benefits ofreduced

## so2 across the country. For further information, please contact Michael Ling at 919-541-4729 or at ling.michael@epa.gov.

ina McCarthy Assistant Administrator

# &EPA United States Environmental Protection Agency Washington, DC20460 Olftcial Business Penaltyfor Private Use $300 6301-A

The Honorable Peggy Hatch Secretary Louisiana Department ofEnvironmental Quality 602 North Fifth Street, #I022 Baton Rouge, Louisiana 70802 

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