## conEdison a conEdison, inc. company June 13, 2014 Mr. Richard Ruvo, Chief, Air Programs Branch Environmental Protection Agency, Region 2 Office 290 Braodway, z5th Floor New York, NewYork 10007-1866 SubmittedVia E-Mail to Ruvo.Richard@epa.gov Andrea J. Schmitz Vice President Environment, Health & Safety

Re: Rescission of Determination ofAttainment and Call forAttainment Plans for NewYork, NewJersey and Connecticutfor the 1997 8-Hour Ozone NationalAmbientAir QualityStandard forthe NY-NJ-CT 1997 Ozone NonattainmentArea - Docket ID No. EPA-ROZ-OAR-2014-0251

Dear Mr. Ruvo: Consolidated Edison Company of NewYork ("Con Edison" or "the Company") files these comments in response to the above-referenced notice published in the May 15, 2014 Federal Register(79 FR 27830) ("the notice"). The notice describesyour agency's proposed intentto rescind its June 18, 2012 determination that the New York-New Jersey-Connecticut (NY-NJ-CT) metropolitan area had attained the 19978-hourozone national ambient airquality standard (NAAQS). The notice states that 2010- 2012 and 2011- 2013 monitoring data showthatthe NY-NJ-CT metropolitan area is now in nonattainmentfor the 1997 8-hour ozone NAAQS which, in turn, requires that the U.S. Environmental Protection Agency (EPA) issue a call for revisions to the State Implementation Plans (SIPs) forthe States of NewYork, NewJersey and Connecticut ("the States"). The notice proposes thatthe States submit revisions to theirSIPs showing howthe States will re-attain the 1997 8-hour NAAQS and sets forth two alternative optionsforthe States. According to EPA's proposal, the States may: 1} Request that the entire NY-NJ-CT metropolitan area be reclassified to "moderate"for the 2008 8- hour ozone NAAQS and prepare the required SIP elements pursuant to thatclassification so that the region can attain the NAAQAS as expeditiously as possible but no laterthan 2018; or, 2) Voluntarily prepare an attainment SIP for the NY-NJ-CT metropolitan area forthe 2008 8-hour ozone NAAQS which demonstrates howthe States can come into attainment bythe current "marginal" classification attainment date of2015. The Company encourages the EPAto adoptthe first ofthe two alternative options listed above forthe following reasons: 1) The Company has made significant capital investments in the last several years to meetthe strict NOx emission requirements associated with the NewYork State NOx RACT rule amendmentsthat go into effect on July 1, 2014. Other emission sources in the NewYork metropolitan area have also made similar investments, and it is reasonable to believe that NOx emissions in the NewYork portion ofthe NY-NJ-CT attainment area will be reduced once the stricter rules go into effect.

Consolidated Edison Company of NewYork, Inc. 4 Irving Place - 15th Floor NE NewYork NY 10003-3598 212 460 1293 schmitza@coned.comExtending the SIP revision development out to 2018 will allow the States to capture thevalue of these significant capital investments in terms of reduced ozone concentrations. 2} Regulated sources can better plan for emission reductions, if required, with longer-term planning horizons. For example, the capital investments and emission reductions associated with the new NOx RACT standards have been in the planning and installation phases since 2009. Itwould be a significant burden for sources to plan for actions in response to a SIP revision focused on the 1997 8-hour NAAQS and then to re-tool in response to subsequent SIP revisions associated with the 2008 8-hour NAAQS. 3) Itwould not be an efficient use of limited state and federal agency staff resources to prepare and to review SIP revisions that address an outdated NAAQS (e.g., the 1997 8-hour standard) that will be subsumed bythe States' efforts to meetthe current NAAQS (the 2008 8-hourstandard}. 4) The Company is hopeful that both NewYork State and the EPA will take proactive steps to address interstatetransport ofozone-related pollutantswithin the 2015 - 2018 planning horizon which can be incorporated intothe States' response to the SIP call. Such presumed air quality improvements could not be identified ifthe States are required to prepare SIP modifications forthe 1997 8-hour ozone NAAQS orthe 2008 8-hour NAAQS "marginal" classification within the next 18 months. The Company is proud of its record of reducing emissions and providing reliable electric and steam service to millions ofNewYork residents. The Company likewise supports the efforts of NewYork State to provide regulatory certaintyto emission sources inthe State, and believes that both agencies and sources will be best served if EPA pursues the SIP call option outlined above. Should you wish to discuss the Company's position on this matter, please contact Mr. Anthony Guastafeste ofthis organization at 212-460-4858. Sincerely,

Andrea Schmitz

cc: R. Sliwinski, DEC



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