1 

State of Rhode Island 

Department of Environmental Management 

Office of Air Resources 

 

In Re: Adoption of the “Rhode Island Attainment Plan for the 8-Hour Ozone National 

Ambient Air Quality Standard” and the “Revision of the Rhode Island State 

Implementation Plan to Address Interstate Transport of Pollutants Affecting Attainment 

and Maintenance of the 8-Hour Ozone and Fine Particulate Matter (PM2.5) National 

Ambient Air Quality Standards” 

DECISION 

Introduction

On 14 February 2008 a notice was published in the Providence Journal-Bulletin and was mailed 

to interested parties announcing a public hearing and comment period to accept comments on the 

proposed adoption of the “Rhode Island Attainment Plan for the 8-Hour Ozone National 

Ambient Air Quality Standard” and the “Revision of the Rhode Island State Implementation Plan 

to Address Interstate Transport of Pollutants Affecting Attainment and Maintenance of the 8-

Hour Ozone and Fine Particulate Matter (PM2.5) National Ambient Air Quality Standards.” The 

public hearing was held on 20 March 2008 in Room 300 of the Department of Environmental 

Management Building, 235 Promenade Street, Providence, Rhode Island. The public comment 

period closed at 4:00 PM on 20 March 2008. 

In fulfillment of Federal Clean Air Act (CAA) requirements, the attainment plan uses modeling 

and other technical analyses to demonstrate that Rhode Island will attain the 8-hour National 

Ambient Air Quality Standard (NAAQS) by the end of the 2009 ozone season. The attainment 

plan also includes the following elements required by the CAA: 

• The 2002 Base Year Emissions Inventory for Rhode Island, 

• A Reasonable Further Progress (RFP) demonstration that VOC and/or NOx emissions in the 

State will be reduced by at least 15% by 2008, 

• An analysis showing that Rhode Island’s regulatory requirements will be consistent with 

Reasonably Available Control Technology (RACT) for major sources of VOC and NOx and 

for sources with Control Technique Guidelines by 2009, 

• A Reasonably Available Control Measures (RACM) analysis showing there are no additional 

emissions control requirements for point and nonpoint sources that could be adopted in 

Rhode Island that would advance the State’s attainment year, 
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• A commitment to adopt additional control measures for the asphalt paving, industrial solvent 

cleaning, flat wood paneling and adhesives source categories before 2009 consistent with 

RACT, 

• Contingency measures to be implemented upon failure to meet RFP or attainment milestones, 

and 

• A mobile source emissions budget for the years 2008 and 2009, which will be used for 

Transportation Conformity purposes. 

The transport plan demonstrates that emissions in Rhode Island do not contribute significantly to 

elevated levels of ozone and fine particulate matter in areas in other states that are not in 

attainment of the NAAQS for those pollutants. 

Response to Comments

This section will present the Rhode Island Department of Environmental Management’s (RI 

DEM’s) response to the comments received at the public hearing and during the public comment 

period. Each comment has been paraphrased and is followed by RI DEM’s response. 

Comments on the Attainment Demonstration 

Comment: The American Lung Association of RI (ALARI) generally supports the attainment 

plans submitted, particularly the commitment to adopt additional control measures consistent 

with EPA guidelines. The ALARI supports the adoption of ozone standards even more stringent 

than the recently finalized amended standard, but believes that it is moving in the right direction. 

 (ALARI) 

Response: RI DEM appreciates ALARI’s support and will implement the emissions control 

programs indicated in the attainment demonstration. 

The following comments are from the United States Environmental Protection Agency 

(USEPA), Region I: 

Comment: Growth factors are listed in Appendix 2B that Rhode Island used to project its 

2002 emission estimates to 2008 for the RFP. In the sheet labeled “point data,” a number of 

facilities have 0.0 as their growth multiplier, and therefore have zero emissions reported for 

2008. Does that mean these facilities closed between 2002 and 2008? If so, a note should be 

added to this sheet explaining this fact. Additionally, if Rhode Island intends to take emission 

reduction credit from these facility closures within its 15% emission reduction plan, the emission 

reductions from these facilities can not be used within any banking or trading programs. 

Response: The facilities with the 0.0 growth factor were permanently closed between 2002 

and 2008, as is explained in Section 2.2 of the attainment SIP document. A note was added to 

the point source spreadsheet in Appendix 2B to further clarify this issue. The facilities identified 
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have not requested that the emissions reductions generated by the closures be banked or traded. 

Comment: The sheet labeled “state summary np” in Appendix 2B indicates that Rhode Island 

will use emission reduction credit generated from federal control measures for AIM coatings and 

consumer products within its 15% plan. As noted in Section 3.3 on page 18, EPA issued a memo 

on May 30, 2007 committing to adopt federal rules with requirements for these categories 

effective January 1, 2009. This memo also provided guidance on calculating reductions from 

these measures for 2008 and 2009. Rhode Island should confirm that it followed this guidance in 

calculating the reductions assumed for these measures within its 15% plan. 

Response: Since updated emissions limits for Consumer Products and AIM will not be 

effective in Rhode Island until 2009, RI DEM has removed the emissions reductions associated 

with those measures from the 2008 projected inventory, as presented in Appendix 2B and 

discussed in Sections 2.4, 4.5 and 4.6. Since the limits on those products will be in effect during 

the 2009 ozone season, the reductions associated with those measures can be used to help fulfill 

contingency requirements, as discussed in Section 8.3. Calculations of the predicted emissions 

reductions for 2009 associated with regulation of Consumer Products and AIM are shown in 

Appendix 8A and were calculated according the EPA guidance cited in the comment. 

Comment: In Section 5, EPA requests that a Table be included to clearly identify the 

“Beyond On the Way” (BOTW) Control Measures assumed for Rhode Island in the 8-hour 

attainment modeling and the status of these measures in Rhode Island. 

Response: A BOTW measure status table has been added as Table 5-3A. 

Comment: EPA would like to see more information about the emissions that were used in the 

Ozone Transport Commission (OTC) modeling that is part of Rhode Island’s attainment 

demonstration. Specifically, we are interested in information on daily emissions by sector for 

both the base case and future years. It is our understanding that in the OTC modeling, the 

month-by-month point source NOx emissions were allocated to a daily basis, with some 

variation between weekdays and weekends, but no variation based on actual emissions. Actual 

daily emissions from electric generating units (EGUs) can, however, vary greatly based on the 

ambient temperature. 

Response: The 2002 and 2009 ozone precursor emission inputs (pre-SMOKE and postSMOKE processed files) used for the CMAQ SIP modeling runs are available in electronic 

format upon request to NYS DEC. RI DEM does not have the resources to construct the daily 

2002 and 2009 emission files requested. The NYS DEC, which served as the lead OTC 

Modeling Center, may be able to extract detailed daily emission files by state, source sector and 

time of year from CMAQ input files. However, it is not clear that inspection of these daily 

emission files is needed to determine if the EGU control program is being accurately quantified 
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in the CMAQ SIP–quality modeling runs. Future year EGU emission inventory documentation is 

contained in Appendix 5M to Section 5, “Attainment Demonstration.” 

The CMAQ SIP-quality modeling runs performed on behalf of the OTC and used by RI DEM 

did not incorporate daily variations in EGU emissions associated with weather-induced 

electricity demand. The OTC approach was to use the SMOKE model to apportion annual 

emissions (based on annual CEM data) provided by the states in order to prepare consistent 

emission files using month-of-year, day-of-week, and hour-of-day temporal profiles. No 

adjustments for ozone or non-ozone episodes were attempted; none of the control strategies are 

day-specific or aimed specifically at high ozone episodes. 

RI DEM recognizes that on some days actual hourly emissions may be higher than CMAQ 

model run emissions and that on other days actual hourly emissions may be lower than CMAQ 

model run emissions. However, using the CMAQ model in a relative way (as recommended by 

EPA guidance) helps minimize the effects of any under-estimated or over-estimated emissions in 

the base case (2002) that are grown out to and controlled in the future case (2009). 

Future case emissions projections for the energy sector were estimated using the IPM model 

which was considered to be the best available tool at the time the OTC CMAQ SIP-quality 

modeling runs were performed (2006). The IPM model produced summer season and annual 

emissions, reflecting the CAIR program, the national control strategy for this sector. For 

consistency, the same month-of-year, day-of-week, and hour-of-day temporal profiles used to 

prepare 2002 hourly emission files were also used to prepare 2009 hourly emission files. To 

apply temporal files based upon actual 2002 hourly emission rates was considered to be 

guesswork since IPM does not assume that the same sources in 2002 would be operating in the 

same way in future-case years. 

In summary, RI DEM believes that the use of consistent temporal files for 2002 and 2009 and 

using the CMAQ model in a relative way (calculating the percent reduction in ozone levels 

instead of using the actual predicted 2009 ozone levels) is the most appropriate way of assessing 

the effectiveness of ozone control strategies in the OTC at this time. The 2002 and 2009 ozone 

precursor emission inputs (pre-SMOKE and post-SMOKE processed files) used for the CMAQ 

SIP modeling runs are available in electronic form upon request to NYS DEC (contact Gopal 

Sistla at gsistla@dec.state.ny.us). 

Comment: Section 6.1 indicates that Rhode Island DEM has analyzed its existing RACT 

rules and determined that they are sufficient to meet RACT under the 8-hour ozone standard with 

the exceptions of the state’s rules on solvent metal degreasing and asphalt paving. Section 6.6 

contains a commitment from Rhode Island to submit to EPA amended rules for these two source 

categories by January 1, 2009, as revisions to the state’s SIP, and also commits to these rules 

having effective dates of no later than April 1, 2009. Rhode Island will need to meet these 

commitments in order for EPA to approve the State’s 8-hour ozone RACT submittal. 
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Response: RI DEM is in the process of drafting amendments to the solvent metal degreasing 

requirements in APC Regulation No. 36 and the asphalt paving requirements in APC Regulation 

No. 25 and fully intends to adopt and submit the updated regulations as SIP revisions by the 

commitment dates specified in Table 3-2. RI DEM understands that the RACT SIP will not be 

approved until those regulations are promulgated and submitted as SIP revisions. 

Comment: Section 6.4.2 contains a discussion of Rhode Island DEM’s evaluation of the 

source categories covered by the CTGs adopted by EPA in October, 2006. This section indicates 

that there may be one source in the state covered by the flat wood paneling CTG, that the state’s 

solvent cleaning rule (APC No. 36) will be amended to conform with the EPA’s industrial 

cleaning solvents CTG, and that RI-DEM has not yet determined whether its existing rules for 

printers are as stringent as EPA’s new CTGs for the three printing categories. For all of the 

above, RI DEM commits to adopt rules (if necessary) and submit them to EPA by January 1, 

2009, and further commits that these rules will become effective no later than April 1, 2009. 

Rhode Island will need to meet these commitments in order for EPA to approve the state’s 8-

hour ozone RACT submittal. Similarly, RI DEM will need to meet its commitment to analyze 

the need for new or amended rules in light of the new CTGs EPA promulgated in October, 2007, 

and make any necessary SIP submittals to EPA that stem from that review. 

Response: RI DEM fully intends to submit amendments to the flat wood paneling requirements 

in APC Regulations No. 19 and 35 and to the cleaning solvents requirements in APC Regulation 

No. 36 consistent with the CTGs by the dates specified in Table 3-2. RI DEM understands that 

the RACT SIP will not be approved until those regulations are promulgated and submitted as SIP 

revisions. Similarly, RI DEM will amend the requirements for printers in Regulation No. 21 and 

the requirements for surface coaters in Regulation 19 if necessary to be consistent with the 2007 

CTG for those categories by the dates specified in Table 3-2. 

Comment: On page 73, within Table 6-1, it is noted with regards to the Shipbuilding and 

Repair CTG that, "2 possibly applicable sources, Senesco and General Dynamics, both are 

subject to permit limits consistent with the CTG." Rhode Island’s final submittal to EPA should 

include a final determination as to whether these sources are subject to the Shipbuilding and 

Repair CTG, and if so, verification that the permits for these sources include emission limits that 

are at least as stringent as those found in the CTG, and confirmation that the permits are 

federally enforceable. 

Response: RI DEM has determined that both Senesco and General Dynamics are subject to 

the Shipbuilding and Repair CTG and that both are operating under federally enforceable permit 

requirements consistent with the CTG. Senesco was issued preconstruction permits (Approval 

Nos. 1991-1993) in July 2007 pursuant to APC Regulation No. 9, “Air Pollution Control 

Permits,” which is a federally enforceable regulation. Those approvals contain the emission 

limits specified in the CTG for the shipbuilding and repair operations conducted at the facility. 

General Dynamics’ shipbuilding and repair operations are subject to Regulation No. 9 Approval 
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No. 1882, issued in Feb. 2006, and Title V Operating Permit No.RI-32-03, issued in Oct. 2003, 

both of which contain the shipbuilding and repair operations emission limits that are specified in 

the CTG. The requirements in Approval No.1882, which was issued for new operations 

conducted at the facility including shipbuilding and repair, will be incorporated into General 

Dynamics Title V permit at the time of renewal, which is due in Oct. 2008. Table 6-1 was 

modified to include this information. 

Comment: Section 6.5, NOx RACT Analysis, should be expanded to include additional 

details on how Rhode Island DEM determined that its existing NOx RACT rule, APC regulation 

No. 27, meets RACT under the 8-hour ozone standard. This is particularly important in light of 

the fact that the state’s NOx Budget rule, APC No. 41, expires at the end of the 2008 ozone 

season and a replacement for that program has not been identified. 

For example, EPA recommends that RI DEM give further consideration to adoption of more 

stringent regulations for industrial, commercial, and institutional (ICI) boilers as part of meeting 

the NOx RACT obligation. As mentioned on page 39 of Rhode Island’s proposed attainment 

demonstration, further regulation of this sector is one of the control options that the Ozone 

Transport Commission (OTC) states agreed to explore as they develop SIPs to address the 8-

hour ozone standard. Rhode Island indicates, on page 40 of the proposed attainment 

demonstration, that it does not believe adoption of a more stringent rule will yield significant 

emission reductions. EPA requests that Rhode Island reexamine this issue, and if adoption of 

more stringent limits for this sector is not pursued, include additional technical support justifying 

that position. 

Additionally, glass manufacturing is one of the categories that the OTC recommended, in 2006, 

states evaluate for possible additional controls. Rhode Island notes on page 40 of the proposed 

attainment demonstration that there is one glass manufacturing facility in the state, and that it is 

currently subject to emission limits that are more stringent than those found in the OTC 2006 

recommended control measure for this sector. Rhode Island should include documentation of 

this fact, and confirmation that the limits are federally enforceable, within its final attainment 

SIP submittal to EPA. 

Response: RI DEM has reexamined this issue and continues to maintain that adoption of 

more stringent requirements for ICI boilers would not yield significant emission reductions in 

the State. The February 2007 OTC document entitled “Identification and Evaluation of 

Candidate Control Measures, Final Technical Support Document,” which is Appendix 5k of 

Rhode Island’s attainment SIP, estimates that implementation of the ICI boiler control measures 

recommended in that document would reduce summer day NOx emissions in Rhode Island by 

0.5 tons. Almost all of the ICI boilers located at major sources in Rhode Island are currently 

equipped with low-NOx burners with flue gas recirculation. Replacing that equipment to meet 

the recommended OTC limits would be cost prohibitive to the sources, administratively 

burdensome fro RI DEM, and would only marginally reduce emissions. A paragraph has been 

added to Section 6.5 to address this issue. 
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Nitrogen oxides emissions from the one glass furnace in the state (Osram Sylvania Products, 

Inc.) are limited to 3.5 lbs per ton of glass produced in a federally enforceable Regulation No. 9 

minor source permit (Approval No. 1350) and in the facility’s federally enforceable Title V 

operating permit (RI-07). Table 7-1 was updated to include this information. Note also that, in a 

stack test conducted at the facility in July 2004, the actual emissions rate measured was 2.15 lbs 

per ton of glass produced. .

Comment: EPA New England was consulted regarding MOBILE6.2 files, assumptions, 

parameters, and development of the motor vehicle emissions budgets (MVEBs). A new 

development, however, is the Rhode Island Statewide Planning Program’s request of February 1, 

2008, that the on-road mobile source emission projections be increased by a half-ton of VOC and 

NOx when identifying the transportation conformity budgets for 2008 (the RFP MVEB) and 

2009 (the attainment year MVEB). The proposed MVEBs include this increase as shown below: 

Rhode Island State-wide On-Road Mobile Inventory (in tons per summer day, tpsd) 

VOC 

Inventory 

VOC Proposed 

MVEBs 

NOx 

Inventory 

NOx Proposed 

MVEBs 

2008 24.14 24.64 27.76 28.26 

2009 22.91 23.41 25.62 26.12 

For purposes of transportation conformity, motor vehicle emissions budgets must be the 

projected motor vehicle emissions, unless those emissions are less than the amount of emissions 

that satisfy the control strategy, in which case safety margins can be added. 

The RFP analysis in Section 4 adequately demonstrates excess emissions exist within the 2008 

total inventory (which are in excess of the 15 percent emission reduction required for achieving 

Rhode Island’s RFP milestones) to apply a half-ton of VOC and NOx safety margin to the 2008 

Motor Vehicle Emissions Budgets. 

In the Section 5 attainment demonstration, however, it is not clear if the 2009 increased 

(adjusted) on-road emission inventory was accurately reflected in the regional modeling 

demonstrating attainment in 2009 (although it is unlikely, due to the timing of the request vs. that 

of the modeling activities). Since it has not been demonstrated that the extra half-ton of VOC 

and NOx are in excess of that assumed in the modeling to demonstrate attainment, the motor 

vehicle emissions budgets for year 2009 must be restricted to the projected 22.91 tpsd of VOC 

and 25.62 tpsd of NOx for on-road mobile sources. 

Response: The mobile source budget for 2009 in Table 5.1 has been adjusted to remove the 

0.5 ton buffer and the discussion in Section 5.4 has been modified to discuss a buffer for 2008 

only. 
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Comment: The report titled, “Rhode Island 2008 And 2009 Mobile Source Emissions,” 

prepared by Vanasse Hangen Brustlin, Inc. (which was submitted as adobe acrobat file named: 

2008 2009 On-road Mobile Source Emissions Summary Document.pdf) has errors in the 2009 

MOBILE6.2 input file. 

On page twenty-nine of the air quality report, the first scenario record for average freeway speed 

of 60.7 miles per hour (92 percent freeway travel and 8 percent ramp travel) is correct as shown 

in the box below: 

SCENARIO RECORD : Scenario Title : RI speed 60.7 (= maximum allowed freeway speed) 

> 2009 Speed 60.7 mph (Freeway) 

* This text is for annotating this file and is otherwise ignored. 

CALENDAR YEAR : 2009 

EVALUATION MONTH : 7 

ALTITUDE : 1 

AVERAGE SPEED : 60.7 Freeway 92.0 0.0 0.0 8.0 

SCENARIO RECORD : Scenario Title : RI speed 60.7 (= maximum allowed freeway speed) 

However, four scenarios follow for the same 60.7 average freeway speed1 that use an incorrect 

calendar year of 2007 to generate emission factors. See text in box below: 

SCENARIO RECORD : Scenario Title : RI speed 60.7 (= maximum allowed freeway speed) 

> 2007 Speed 60.7 mph (Freeway) 

* This text is for annotating this file and is otherwise ignored. 

CALENDAR YEAR : 2007 

EVALUATION MONTH : 7 

ALTITUDE : 1 

AVERAGE SPEED : 60.7 Freeway 92.0 0.0 0.0 8.0 

SCENARIO RECORD : Scenario Title : RI speed 60.7 (= maximum allowed freeway speed) 

This error was also found in the original 09RIOZ.inp MOBILE6.2 input file supplied by RI 

DEM. This error may not have been carried over into the 2009 Motor Vehicle Emissions 

Budgets if there were no freeway speeds greater than 60.7 in the on-road inventory; or the 

emission factors from the first RI freeway speed of 60.7 was used for all 60.7 and greater 

freeway speeds. However, if this error was carried over into the calculation of the 2009 MVEB, 

then a slightly higher 2007 emission factor would have been used for freeway speeds greater 

than 60.7. 

Please confirm that the 2007 freeway emission factors were not used in developing the 2009 

MVEBs. If the 2007 emission factors were used, please re-run the 60.7 average freeway speeds 

 

1 While the MOBILE Program limits average “freeway and ramp” speed to 60.7 miles, (60.7 average freeway and 

ramp speed is used for all freeway speeds greater than 60.7 mph) users often run additional scenarios of 60.7 to 

represent speeds for 62 mph, 63 mph, 64 mph and 65 mph which may by utilized by macros in calculating emissions 

within a database. 
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for calendar year 2009, or use the emission factor from the first/correct 60.7 average freeway and 

ramp speed for all speeds greater than 60.7 mph, and re-calculate the 2009 MVEBs for volatile 

organic compounds (VOC) and oxides of nitrogen (NOx). 

Response: These errors have been corrected. The corrected 2009 emissions inventory is 

22.75 tons of VOC (a decrease of 0.16 tons from the amount in the proposed SIP) and 25.29 tons 

of NOx (a decrease of 0.33 tons). The 2009 emissions inventory and budget in Table 9-1 have 

been revised to reflect this correction. Note that this error did not affect the 2008 emissions. 

Comment: The on-road emission modeling for year 2008 and year 2009 does not include 

Rhode Island’s Low Emission Vehicle (LEV) Program, hence no credit for this program is 

assumed in the 2008 or 2009 on-road motor vehicle emissions budgets prepared for use in 

transportation conformity. 

Page 60 of the Attainment Demonstration, however, indicates that state LEV programs were 

included in the regional 8-hour ozone modeling for attainment. Before Rhode Island can take 

credit for the Rhode Island LEV program, this program must be submitted to, and approved by, 

EPA as a SIP revision. 

Therefore, Table 3-2 “RI DEM Control Technology Regulatory Action Commitments,” on page 

20, should be revised to include the Rhode Island LEV program and a date certain by which 

DEM will submit this program to EPA as a SIP revision. 

Response: Table 3-2 has been revised to include a commitment that RI DEM will submit the 

LEV program (Regulation No. 37) to the EPA as a SIP revision by 1 June 2008. 

Comment: After a hearing in March of 2007, the State of Rhode Island revised its regulations 

by which it is implementing its vehicle emission testing program. Additionally, the State of 

Rhode Island's vehicle testing is being implemented under a new contract. Therefore, Rhode 

Island should submit the revised program to EPA as a SIP revision and Table 3-2 should list this 

program and a date certain by which DEM will make this submittal to EPA. 

Response: Table 3-2 has been revised to include a commitment that RI DEM will finalize the 

amendments to the inspection/maintenance requirements in Regulation No. 34 and submit the 

amended regulation to EPA as a SIP revision by 1 June 2008. 

Comment: The text on page 17 of Appendix 2A indicates that rule effectiveness adjustments 

were made in accordance with an EPA guidance document from November, 1992. In future 

emission inventories (i.e., for the inventory years 2005 and beyond), Rhode Island DEM should 

use EPA’s updated guidance on rule effectiveness which is contained in the document available 

at the following web-site, as appendix B: 
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http://www.epa.gov/ttn/chief/eidocs/eiguid/eiguidfinal_nov2005.pdf

Response: The updated guidance will be used for future inventories. 

Comment: Section 5.0 of Appendix 2A indicates that due to resource constraints, a quality 

assurance program was not implemented for the 2002 inventory. Quality assurance, which is a 

system of review by personnel not actively involved in development of the inventory, is an 

important means of verifying the large number of calculations within the inventory. Rhode 

Island needs to address this shortcoming in its inventory program. 

Response: RI DEM plans to develop a Quality Assurance Project Plan for the emissions 

inventory to address this issue. 

Comment: On page 40 of the attainment plan, the last paragraph of Section 5.11 should be 

revised to reference “additional emissions reductions in the State in 2009.” On page 87, in the 

last paragraph, the reference to “Section 6.5, “Mobile Source RACM Analysis for Rhode 

Island,” appears to be incorrect. The correct reference is to Section 7.5. 

Response: These typographical errors have been corrected. 

Comments on the Transport SIP 

Comment: EPA previously reviewed an earlier draft version of this SIP and sent comments 

to the DEM in a letter dated September 14, 2007. We have reviewed the proposed SIP and have 

found that it is consistent with EPA’s guidance and that the DEM has adequately addressed our 

previous comments. 

Response: No response required. 

Decision

 

It is the decision of the Hearing Officer to adopt the proposed “Rhode Island Attainment Plan for 

the 8-Hour Ozone National Ambient Air Quality Standard” with the revisions noted above and 

the “Revision of the Rhode Island State Implementation Plan to Address Interstate Transport of 

Pollutants Affecting Attainment and Maintenance of the 8-Hour Ozone and Fine Particulate 

Matter (PM2.5) National Ambient Air Quality Standards” as proposed. The final Plans are 

appended to this Decision. 
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Date Stephen Majkut, 

Hearing Officer 
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