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 of Environmental Quality 

602 North Fifth Street, #I 022 

Baton Rouge, Louisiana 70802 

Dear Ms. Hatch: 

APR 1 7 ZOlZ 

OFFICE OF THE SECRETARY 

OFFICE OF 

AIR AND RADIATION 

I am writing today to update you on the status of the U.S. Environmental Protection Agency's efforts to 

implement the !-hour primary 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 of concerns in response to the draft 

guidance the EPA published for comment last year. 

The S02 NAAQS will reduce human exposure to high short-term S02 concentrations and provide 

increased health protection to millions of Americans. Meeting the standard will reduce cases of 

aggravated asthma and chronic bronchitis and will cut down on hospital admissions, emergency room 

visits, and work days lost due to illness. 

The promulgation of the S02 NAAQS in 20 I 0 set in motion a series of steps required under the Clean 

Air Act (Act), including: (I) designating areas as meeting or not meeting the S02 standard, and (2) 

developing state implementation plans (SIPs) for implementation of the standard. The Act calls for 

states to submit two components of these SIPs. The first is a plan for implementation, maintenance and 

enforcement of the standard in all areas of the 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 of each area's nonattainment designation). 

To address each of the 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 

our work to analyze and respond to the recommendations you made last June and expect to 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 stakeholder outreach in the near future to help us refine our 

approach for detennining whether air quality in a given area is meeting the S02 NAAQS. 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 of the potential this process has to affect our recommendations for how to address the 

S02 NAAQS in areas initially designated "unclassifiable," we no longer expect your state's June 

2013 SIP submittals to contain modeling demonstrations showing attainment of the standard in 

unclassifiable areas, as was outlined in the final S02 NAAQS rule and described further in the 

draft implementation guidance. 

This parallel approach will ensure that we make progress toward cleaner air in areas with monitored 

violations of the 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 of the states, tribes and 

other stakeholders, and have an opportunity to discuss workable approaches to implementation of the 

20 I 0 standard. In particular, we believe it would be helpful to discuss two main topics: (I) how best to 

assess compliance with the S02 NAAQS (e.g., by defining and establishing a robust, representative 

monitoring network for S02 across the country and/or by applying the appropriate modeling approach), 

and (2) how to implement the new approach (e.g., implementation options and SIP timelines 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 organizing these 

stakeholder meetings and would welcome participation by the State of Louisiana. We will separately 

provide more details on this effort at: http://www.epa.gov/airquality/sulfurdioxide/implement.html. 

Following these meetings, we will proceed expeditiously to issue revised guidance and/or undertake 

rulemaking, as appropriate. 

State Implementation Plan Submittals: Regarding the SIP submittals due in June 2013, we expect that 

the EPA's discussions with stakeholders about how best to implement the NAAQS may result in 

changes to our previously described recommendations for implementing the so2 standard in 

unclassifiable areas. Therefore, we recommend for now that states focus their 2013 SIP submittals on 

the traditional infrastructure elements of Clean Air Act sections I lO(a)(l) and (2), rather than on 

modeling demonstrations showing future attainment of the 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. If your 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 our work to 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 of Louisiana 

in developing workable approaches to delivering the important public health benefits of reduced 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, DC 20460 

Olftcial Business 

Penalty for Private Use $300 

6301-A 

The Honorable Peggy Hatch 

Secretary 

Louisiana Department of Environmental Quality 

602 North Fifth Street, #I 022 

Baton Rouge, Louisiana 70802 

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