p.1 

OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

115) IV-C-29 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:23 AM Sheet 115 of 142 
p 

OT. 

* t PRO^° 

P.2 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

AJG 3 0 1999 

A- 96-3"? 

OFFICE OF 

AIR AND RADIATION 

Mr. Henson Moore 

American Forest & Paper Association 

llll Nineteenth Street, N.W., Suite 800 

Washington, DC 20036 

Dear Mr. Moore: 

FEB £ nnr. 2 

EPA AIR DOCKET 

Thank you for your letter of August 4,1999, regarding our efforts to simplify and 

streamline the new source review (NSR) program. You highlighted the considerable energy that 

all the stakeholders have recently invested in crafting proposals that seek to reduce the 

complexity and uncertainty of the NSR program. However, you expressed skepticism at the 

ability of the stakeholders to reach consensus by September and encouraged us to continue the 

dialogue'with the participating stakeholder groups until the end of this year. 

We have made a special effort over the past year to seek further input from all 

stakeholders on new approaches that will help achieve our goals of providing more flexibility for 

industry, streamlining the permitting process where possible, while preserving the environmental 

protection called for by the Clean Air Act. The meetings with stakeholders in August have been 

constructive, and we believe the follow-up meetings will enable us to come to a widely accepted 

set of program reforms by late fall. 

Again, thank you for your concern and comments. If I can be of further service, please do 

not hesitate to contact me. 

Sincerely, 

Robert Perciasepe 

Assistant Administrator 

Printed on Recycled Paper 
P.3 

Controlled Correspondence For 

OFFICE OF AIR QUALITY, PLANNING AND STANDARDS - RTP 

CONTROL NO: OAR-9901049 ORIG. DUE DATE: 08/24/99 

STATUS: PENDING CORRES. DATE: 

RECEIVED DATE: 

ASSIGNED DATE: 

CLOSED DATE: 

08/04/99 

08/13/99 

08/13/99 life" 

FROM: 

ORG: 

SALUTATION: 

CONSTITUENT 

TO: 

TO ORG: 

SUBJECT: 

ASSIGNED: 

W. HENSON MOORE; PRESIDENT AND CHIEF EXECUTIVE OFFICER

 r> ^ $W)ft' V

S 

AMERICAN FOREST & P.APER ASSOCIATION __>! )•*. V**5*^ 

DEAR MR. MOORE:

 S -V° J U 0 \JSv*\\ 

ROBERT PERCIASEPE ^(SLd^ V 

AA.OAR °^Kr^T 

TIME TABLE FOR POSSIBLE REFORM OF NEW SOURCE REVffiW (>.SRWj|>>0 [^ V ^ 

PROGRAM ' fx^i^* ^ 

Information Transfer and Program Integration Division .tv ^ ^ VY - r*Jt 

COPIES OF INCOMING PROVIDED TO: PERCIASEPE, BRENNER, NOFERI, PYLES -><vS^ V 

SIGNATURE: ASSISTANT ADMINISTRATOR J^f J Af*** 

OAQPS COMMENTS: "^T 

Added on: 08/13/99 From Sherry Russell/RTP/USEPA/US -For Perciasepe's Sign! 

OAR INSTRUCTIONS: 

OAQPS INSTRUCTIONS: 

|Lead 

Assigned 

ITPID 

Date Assigned 

08/13/99 

Code/Status 

ACTION 

Date Completed by 

Assignee 

-

Date Returned to A 

OAQPS:

 v 

-

(Untitled) 
08/13/99 FRI 10:00 FAX 

P.4 

@002 

Controlled Correspondence For 

OFFICE OF AIR AND RADIATION 

CONTROL NO : OAR-9901049 

STATUS: PENDING 

ORIG. DUE DATE: 08/27/99 

CORRES. DATE: 08/04/99 

RECEIVED DATE: 08/13/99 

ASSIGNED DATE: 08/13/99 

CLOSED DATE: 

FROM: 

ORG: 

SALUTATION: 

CONSTITUENT: 

W. HENSON MOORE; PRESIDENT AND CHIEF EXECUTIVE OFFICER 

AMERICAN FOREST & PAPER ASSOCIATION 

DEAR MR MOORE: 

TO: 

TO ORG: 

SUBJECT: 

ASSIGNED: 

ROBERT PERCIASEPE 

A A, OAR 

TIME TABLE FOR POSSIBLE REFORM OF NEW SOURCE REVIEW (NSR) 

PROGRAM 

Office of Air Quality Planning & Standards - RTP 

COPIES OF INCOMING PROVIDED TO: PERCIASEPE, BRENNER, NOFERI, PYLES 

SIGNATURE: ASSISTANT ADMINISTRATOR 

OAR COMMENTS: 

OAR INSTRUCTIONS: 

|Lead 

Assigned 

OAQPS 

Date Assigned 

08/13/99 

Code/Status 

ACTION 

Date Completed by 

Assignee 

-

Date Returned to 

OAR: 

• 

(Untitled) 3 
""" 'T?—-f -fy1

 'ig i n «-w y- a-na-p-iiiip-ip ,i —--•—-v P-^^^TM 

a 08/13/99 FRI 10:00 FAX . • * (gioo3 f 

AFIP**'' bh^^^ ^ 

AMERICAN FOREST & PAPER ASSOCIATION 

• • Office of the President 

August 4, 1999 

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. Perciasepe: 

I was very pleased to read, in a letter from John Seitz of your staff, that the Agency plans to continue its 

stakeholder dialogue on possible reform of the New Source Review (NSR) program. The American Forest & Paper 

Association will have a representative at the August 18 meeting on the "complex manufacturing" proposal. 

Based on comments from your staff and remarks you made at the Clean Air Act Advisory Committee meeting, 

we understand that similar sessions will be held with the other stakeholders in August, and a decision will be made 

shortly after you have been briefed in September. I have to admit that 1 am skeptical of this (still) very tight schedule. 

We all understand your desire to "fix" this overly complicated, increasingly contentious program during your 

remaining tenure as Assistant Administrator, and we are aware of the other high profile issues that also merit your full 

attention (Tier II tailpipe standards, fuel sulfur content, life NAAQS Court decision). We are convinced that the three 

closely-linked strawman proposals have moved us much closer to the goal ofa simpler, more understandable NSR 

program. However, the process that is now laid out does-not fully recognize the hurdles that remain. 

We have not yet seen the discussion points your staff has promised to provide each of the stakeholders groups in 

advance of the stakeholder meetings. Issues that your staff will raise between now and August 18, as well as issues raised 

by the states, simply cannot be vetted by a large, multi-irfdustry group in the next 2 to 4 weeks so that thoughtful 

comments can be provided during the stakeholder meetirigs. It has taken the various industry segments, working 

together, a full 6 months to achieve general consensus on our proposals. More work remains before other stakeholders, 

especially the states responsible for running the NSR program, are fully comfortable with all reform concepts. 

We urge you to continue, at least until the end of the year, the stakeholder discussions. This will give us time to 

go back to our members, make them comfortable with what we will give up as well as gain, and continue our ongoing 

dialogue with the states and other stakeholders. A more reasoned schedule like this could well address the current 

program's complexities while minimizing the possibility of legal challenges. The forest products industry is absolutely 

committed to working with you to make this effort a success. 

With kindest personal regards, I remain, 

Sincerely yours, 

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 People^—Improving Tomorrow's Environment Today*