RE: Step 3 rule - regulatory language added 

Juan Santiago to: Kymn, Christine J. 02/24/2012 03:44 PM

Cc: Anna Wood, Howard Hoffman, Kristi Smith, MichaelS Brooks, Lynn 

Hutchinson, Paul Balserak, "Ghorbi, Darian", Pam Long

From: Juan Santiago/RTP/USEPA/US

To: "Kymn, Christine J." <Christine_J._Kymn@omb.eop.gov>

Cc: Anna Wood/RTP/USEPA/US@EPA, Howard Hoffman/DC/USEPA/US@EPA, Kristi 

Smith/DC/USEPA/US@EPA, MichaelS Brooks/RTP/USEPA/US@EPA, Lynn 

Hutchinson/RTP/USEPA/US@EPA, Paul Balserak/DC/USEPA/US@EPA, "Ghorbi, Darian" 

Thanks Christine.

Please see our responses below in red and the attached file.

Juan 

Interagencycomments3 EO 1286613563 EPA NPRM Tailoring Step3 022412 Response to OMB.docx

"Kymn, Christine J." Thanks, Juan. We will let you know if there is... 02/24/2012 02:53:36 PM

From: "Kymn, Christine J." <Christine_J._Kymn@omb.eop.gov>

To: Juan Santiago/RTP/USEPA/US@EPA

Cc: Anna Wood/RTP/USEPA/US@EPA, Howard Hoffman/DC/USEPA/US@EPA, Kristi 

Smith/DC/USEPA/US@EPA, MichaelS Brooks/RTP/USEPA/US@EPA, Lynn 

Hutchinson/RTP/USEPA/US@EPA, Paul Balserak/DC/USEPA/US@EPA, Pam 

Long/RTP/USEPA/US@EPA, "Ghorbi, Darian" <Darian_E_Ghorbi@omb.eop.gov>

Date: 02/24/2012 02:53 PM

Subject: RE: Step 3 rule - regulatory language added

Thanks, Juan. We will let you know if there is any follow up on this most 

recent draft. In the interest of time, I've attached follow up comments 

received thus far. These comments are based on the draft distributed 

yesterday evening. Because of the comment consolidation process, it will be 

difficult to discern what's new in the attached. As such, I'm providing this 

reference list of follow up comments/suggested edits as a legend:

1) Comment A8, P. 11. Reviewer has requested that EPA address prior comment 

that appears to lack response.

We are not prepared to say this. Although this rule is specific to GHG

emissions and the streamlining techniques included are focused on GHGs, we 

believe streamlining is a useful tool for other pollutants as well (i.e., pals 

are available for other pollutants). We may be required to do streamlining

for other pollutants as part of streamlining for GHGs (i.e., GPs).

2) A12, p. 13. Suggested fn edit.

We could take this out but want to point out that the text of the footnote you 

recommend striking was already published as part of the SIP call published Dec 

2011.

3) A59, p. 31. Section V.A. Suggested edit in second to last para.

See proposed edits in text.

4) A60-62, p. 31. Multiple reviewers suggested edits to economics conditions 

discussion.

A60: We don't really know what the reason is for these business decisions. 
There are many possibilities such as market demands and revenue. Unless the

commenter can provide for a reference for this language, we think it is too 

speculative and should not be added.

A61: OK

A62: Resolved by edits from A61.

5) A67, p. 40. Suggested further clarification for para. Starting 

"Importantly"

A67: Ok.

6) A79, p. 42. Placeholder comment re: removing TSD reference

This was addressed in the later version we sent you.

7) A143-144, p. 58-59. Multiple reviewers suggested edit to provide further 

CFR cross-reference cites on proposed PALs amendments in order to provide 

notice to the public. 

We can't do this since we are taking comment on a variety of possible 

approaches that could potentially affect which sections of the existing 

regulations would be modified.

8) A 148-49, p. 76. Placeholder comment re: removing TSD reference and 

increased specificity of on proposed CFR changes for notice purposes. 

Please refer to changes made to the version including regulatory text.

9) p. 84 - correction of typo to "intall"

Ok.

Please let me know if you have any questions.

Thank you,

Christine 

-----Original Message-----

From: Juan Santiago [mailto:Santiago.Juan@epamail.epa.gov] 

Sent: Friday, February 24, 2012 1:30 PM

To: Kymn, Christine J.

Cc: Anna Wood; Howard Hoffman; Kristi Smith; MichaelS Brooks; Lynn Hutchinson; 

Paul Balserak; Pam Long

Subject: Step 3 rule - regulatory language added

Christine,

Per our conversation earlier today, attached is a complete version of the Step 

3 rule that incorporates the regulatory text that was originally going to be 

in the docket. The references in the text to the docket item have been 

removed. In addition, we have added language to comply with the January 4, 

2012 memorandum on "Clarifying Regulatory

Requirements: Executive Summaries".

Please contact me if you have any questions.

Thanks!

Juan E. Santiago

(See attached file: Revised Step 3 Draft - OMB comment response plus reg text 

2-24-12.docx)

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022412.docx" deleted by Juan Santiago/RTP/USEPA/US]