Steven L. Beshear 

Governor 

ENERGY AND ENVIRONMENT CABINET 

Capital Plaza Tower 

500 Mero Street, 12'~ lo or 

Frankfort, Kentucky 40601 

Phone: (502) 564-7192 

Fax: (502) 564-7484 

Leonard K. Peters 

Secretary 

May 14,2012 

Ms. Gwen Keyes Fleming 

Regional Administrator 

U.S. Environmental Protection Agency, Region 4 

Sam Nunn Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, GA 30303-8960 

Dear Ms. Fleming, 

The Energy and Environment Cabinet requests that the U.S. EPA include this letter as an 

amendment to the SIP submittal containing Louisville Metro Air Pollution Control District 

(District) Regulation 2.05, Prevention of Significant Deterioration, version #lo. The original 

submittal was sent to the Kentucky Division for Air Quality (Division) on January 20, 20 1 1, and 

transmitted to the U.S. EPA on February 8,201 1. 

On March 16, 2012, EPA proposed revising the definition of "regulated NSR pollutant" 

at 40 CFR 5 1.166(b)(49)(vi), 52.21(b)(50)(vi) and 40 CFR Part 5 1, Appendix S, to clarify that 

the definition, which was adopted in the NSR PM2.j Rule in 2008, was not intended in the 

context of the PSD and NSR programs to include requirements to measure condensable 

particulate matter. [Implementation of the New Source Review (NSR) Program for Particulate 

Matter Less Than 2.5 Micrometers (PM2..5): Amendment to the DeJinition "Regulated NSR 

Pollutant" Concerning Condensable Particulate Matter, 77 Fed. Reg. 15656 (proposed rule).] 

On November 17, 20 10, the District amended Regulation 2.05, Prevention of SigniJicant 

Deterioration, by updating the version of 40 CFR 52.21 incorporated by reference from the July 

1, 2008, version to the July 1, 201 0, version. A copy of the complete SIP submittal requesting 

the amendment to the Jefferson County portion of the Kentucky SIP was submitted by the 

District to the Division on January 20, 201 1, for submittal to EPA. The Division subsequently 

transmitted the SIP submittal to EPA on February 8, 201 1. As noted in the attached Regulatdry 

Impact Assessment, the amendments to Regulation 2.05 were intended to be consistent with the 

federal requirements, including provisions applicable to PM2. j. 
Ms. Gwen Keyes Fleming 

May 14,2012 

Page 2 

The Cabinet hereby requests that, consistent with the March 16, 2012, proposed rule, 

EPA not approve the term "particulate matter emissions" into the Jefferson County portion of the 

Kentucky SIP when taking action to approve the February 8, 201 1, SIP submittal. The Cabinet 

also requests that EPA approve into the Jefferson County portion of the Kentucky SIP those 

provisions promulgated in the NSR PM2.5 Rule, including the requirement that PMlo emissions 

and PM2.5 emissions include the condensable PM fraction emitted by sources, which have been 

incorporated by reference in the SIP submittal. The Cabinet will submit a SIP revision clarifying 

that the term "particulate matter emissions" is not included in the definition of regulated NSR 

pollutant following EPA's publication of a final rule adopting the proposed revision. 

The Cabinet appreciates your prompt response to this request. If you have any further 

questions or concerns, please contact Andrea Smith at (502) 564-3999, ext. 4410, or 

Andrea.Smith@ky.gov. 

Sincerely, 

Leonard K. Peters 

Secretary 

Cc: Scott Davis 

Lynorae Benjamin 

Lauren Anderson 

An Equal Opportunity Employer M/F/D