RHODE ISLAND 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

235 Promenade Street, Providence, RI 02908-5767 TDD 401-222-4462 

24 May 2016 

David Conroy 

U.S. EPA - Region 1 

5 Post Office Square, 

Suite 100 (OEP05-02) 

Boston, MA 02109-3912 

Re: Withdrawal of Regulations from State Implementation Plan Submission 

Dear Mr. Conroy: 

By letter dated September 22, 2008, the Rhode Island Department of Environmental 

Management (DEM) submitted thirty-two (32) of its Air Pollution Control Regulations as formal 

revisions to the Rhode Island State Implementation Plan (SIP). I am requesting that the following 

regulations be withdrawn from the September 22, 2008 submittal. 

Air Pollution Control Regulation No. 5 "Fugitive Dust" 

Reason: Contains Director discretion provisions. 

Air Pollution Control Regulation No. 8 "Sulfur Content of Fuels" 

Reason: A more recent version of this regulation has been approved into the SIP 

Air Pollution Control Regulation No. 13 "Particulate Emissions from Fossil Fuel Fired 

Steam or Hot Water Generating Units" 

Reason: Contains Director discretion provisions. 

Air Pollution Control Regulation No. 16 "Operation of Air Pollution Control Systems" 

Reason: This regulation was included in Startup/Shutdown/Malfunction SIP Call. 

Air Pollution Control Regulation No. 20 "Burning of Alternative Fuels" 

Reason: Department's decision 

Air Pollution Control Regulation No. 25 "Control of Volatile Organic Compound 

Emissions from Cutback and Emulsified Asphalt" 

Reason: A more recent version of this regulation has been approved into the SIP 

Air Pollution Control Regulation No. 28 "Operating Permit Fees" 

Reason: Title V operating permit programs are not part of the SIP. 

A: \.J 30% post-consumer fibe r 
Air Pollution Control Regulation No. 29 "Operating Permits" 

Reason: Title V operating permit programs are not part of the SIP. 

Air Pollution Control Regulation No. 36 "Control of Emissions from Organic Solvent 

Cleaning" 

Reason: A more recent version of this regulation has been approved into the SIP 

Air Pollution Control Regulation No 37 "Rhode Island's Low Emission Vehicle 

Program" 

Reason: A more recent version of this regulation has been approved into the SIP 

Air Pollution Control Regulation No. 39 "Hospital/Medical/Infectious Waste 

Incinerators" 

Reason: 111 ( d) programs are not part of the SIP. 

Air Pollution Control Regulation No. 41 "NOx Budget Trading Program" 

Reason: This regulation was repealed in 2014. 

Air Pollution Control Regulation No. 42 "Heavy-Duty Diesel Engine Standards" 

Reason: This regulation was repealed in 2014. 

Additionally, I am requesting Air Pollution Control Regulation No. 17 "Odors" that was 

included in the September 22, 2008 SIP submission be withdrawn and further request that it be 

removed from the SIP entirely as EPA has determined that Rhode Island's odor regulations do 

not have a reasonable connection to the National Ambient Air Quality Standards and related air 

quality goals of the Clean Air Act. 

If you have any questions on this issue, please contact me at (401) 222-2808, x-7011. 

Sincerely, 

Office of Air Resources 

cc: Susan Lancey - EPA 

Ida McDonnell - EPA