Hi Nick, 

Below are interagency comments on the CMAS rule. Please let me know if you have any questions. 

 

Regards, 

Cortney 

 

Executive Summary

Before Section I.A., in a new “A” section, can you please add an executive summary? 

 

Guidance was given to agencies on 1/2/2012 on drafting an executive summary, which I’ve pasted in below. 

Suggested Template for Executive Summaries (generally 3-4 pages of a double-spaced Word document 

maximum, although unusually complex or lengthy regulatory actions may require longer executive summaries) 

I. Purpose of the Regulatory Action 

a. The need for the regulatory action and how the action will meet that need 

b. Succinct statement of legal authority for the regulatory action (explaining, in brief, the legal authority laid out 

later in the preamble) 

 

II. Summary of the Major Provisions of the Regulatory Action In Question 

(Each major provision should be described clearly and separately, along with a brief 

justification) 

III. Costs and Benefits 

Interagency Comments under EO 13563 on the Chemical Manufacturing Area Source rule

Higgins, Cortney 

to: 

Nick Parsons 

10/04/2012 10:18 AM 

Cc: 

Penny Lassiter, JohnB Chamberlin 

Hide Details 

From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov> 

To: Nick Parsons/RTP/USEPA/US@EPA 

Cc: Penny Lassiter/RTP/USEPA/US@EPA, JohnB Chamberlin/DC/USEPA/US@EPA 

History: This message has been forwarded. 

Page 1 of 2

file://C:\Documents and Settings\nparsons\Local Settings\Temp\notes87944B\~web2060.h... 10/4/2012
(For economically significant regulatory actions, please include a table summarizing the assessment of costs and 

benefits, both quantitative and qualitative I ) 

 

For an example of a sample executive summary that follows the above guidance, see: 

http://www.gpo.gov/fdsys/pkg/FR-2012-09-11/pdf/2012-20501.pdf

Title V

EPA was specifically asked by the petitioners to reconsider the requirement that certain major sources that 

installed air pollution controls to become area sources obtain a Title V permit. We are supportive of EPA’s 

efforts, in this final rule, to ensure greater consistency in public participation and to improve monitoring and 

compliance certification efforts. Interagency commenters would like to continue discussions with EPA to better 

understand the benefits of requiring Title V permits. 

 

Technical Correction – Concentration Thresholds

In its January 30, 2012, Proposed Rule, EPA suggested the following technical correction: 

A CMPU is subject (to this rule) if the collective concentration of the Table 1 HAPs exceeds 50 parts per 

million by volume in any process vent stream. This threshold was specified because this concentration 

defines a process vent, and such emissions streams are subject to control. 

 

In the Final Rule, EPA states: 

We have revised this language to clarify that the concentration thresholds for applicability of Table 1 

HAP are to be determined on an individual Table 1 HAP concentration, rather than a collective 

concentration. In addition, we have also clarified that the 0.1 percent by weight threshold for Table 1 

HAP present in liquid streams (process or waste) also applies to Table 1 HAP present in any continuous

process or batch process vent, rather than the proposed 50 ppmv threshold. 

 

Interagency commenters would like to better understand EPA’s revisions in the final rule language, and

welcomes the opportunity to discuss the final rule language with EPA. 

 

 

Page 2 of 2

file://C:\Documents and Settings\nparsons\Local Settings\Temp\notes87944B\~web2060.h... 10/4/2012