con Edison 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, New York 10007-1866 

Submitted Via E-Mail to Ruvo.Richard@epa.gov 

Andrea J. Schmitz 

Vice President 

Environment, Health & Safety 

Re: Rescission of Determination of Attainment and Call for Attainment Plans for New York, New Jersey 

and Connecticut for the 1997 8-Hour Ozone National Ambient Air Quality Standard for the NY-NJ-CT 1997 

Ozone Nonattainment Area - Docket ID No. EPA-ROZ-OAR-2014-0251 

Dear Mr. Ruvo: 

Consolidated Edison Company of New York ("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 describes your agency's proposed intent to rescind its June 18, 2012 

determination that the New York-New Jersey-Connecticut (NY-NJ-CT) metropolitan area had attained the 

1997 8-hour ozone national ambient air quality standard (NAAQS). The notice states that 2010- 2012 and 

2011- 2013 monitoring data show that the NY-NJ-CT metropolitan area is now in nonattainment for 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) for the States of New York, New Jersey 

and Connecticut ("the States"). The notice proposes that the States submit revisions to their SIPs showing 

how the States will re-attain the 1997 8-hour NAAQS and sets forth two alternative options for the 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 that classification so that 

the region can attain the NAAQAS as expeditiously as possible but no later than 2018; or, 

2) Voluntarily prepare an attainment SIP for the NY-NJ-CT metropolitan area for the 2008 8-hour 

ozone NAAQS which demonstrates how the States can come into attainment by the current 

"marginal" classification attainment date of 2015. 

The Company encourages the EPA to adopt the first of the two alternative options listed above for the 

following reasons: 

1) The Company has made significant capital investments in the last several years to meet the strict 

NOx emission requirements associated with the New York State NOx RACT rule amendments that 

go into effect on July 1, 2014. Other emission sources in the New York metropolitan area have also 

made similar investments, and it is reasonable to believe that NOx emissions in the New York 

portion of the NY-NJ-CT attainment area will be reduced once the stricter rules go into effect. 

Consolidated Edison Company of New York, Inc. 

4 Irving Place - 15th Floor NE New York NY 10003-3598 212 460 1293 schmitza@coned.com 
Extending the SIP revision development out to 2018 will allow the States to capture the value 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. It would 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) It would 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 by the States' efforts to meet the current NAAQS (the 2008 8-hour standard}. 

4) The Company is hopeful that both New York State and the EPA will take proactive steps to address 

interstate transport of ozone-related pollutants within the 2015 - 2018 planning horizon which can 

be incorporated into the States' response to the SIP call. Such presumed air quality improvements 

could not be identified if the States are required to prepare SIP modifications for the 1997 8-hour 

ozone NAAQS or the 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 of New York residents. The Company likewise supports the efforts of New York State to provide 

regulatory certainty to emission sources in the 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 

of this organization at 212-460-4858. 

Sincerely, 

Andrea Schmitz 

cc: R. Sliwinski, DEC 

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