222 Berkeley Street • P.O. Box 763 • Boston, MA 02117-0763 • 617-262-1180 • Fax: 617-536-6785 • www.aimnet.org 

June 30, 2004 

Robert Donaldson 

Department of Environmental Protection 

Bureau of Waste Prevention 

One Winter Street, 8t h Floor 

Boston, MA 02108 

In Re: Proposed Amendments to 310 CMR 7.00 et.seq. and 310 CMR 70.00 - Engines 

and Combustion Turbines 

Dear Mr. Donaldson: 

Associated Industries of Massachusetts (A.I.M.) is pleased to submit the following 

comments regarding the above referenced proposed amendments. Associated Industries 

of Massachusetts is the largest employer association in Massachusetts with more than 

7,600 Bay State businesses and institutions as members. A.I.M. members include large 

and small employers from the industrial, commercial and service sectors, including many 

members affected by this proposed rule. 

Overall, A.I.M. is pleased that the Department has chosen to follow the national model 

with regard to emission standards on these engines. A.I.M. is also encouraged that in 

some cases, the proposed rules will result in a reduction of paperwork and process burden 

for regulated facilities. These amendments will also provide clearer direction for 

regulated sources when trying to permit facilities. This all falls under the category of 

"streamlining", making the process clearer and reducing paperwork while at the same 

time improving the environment. 

However, A.I.M. shares the view articulated by Polaroid Corporation and others that 

these proposed rules may have unintended bureaucratic consequences for those major 

sources that are regulated under the federal Title V program. Since the threshold for the 

engines subject to these regulation drops from 3,000,000 Btu's to approximately 300,000 

Btu's, the increase in workload for Title V sources (and hence for DEP) could be sizable, 

not to mention the fee increases for these sources, for no environmental benefit. Intended 

or not that is the result. This will make these permits more complicated and costly for the 

sources as well as DEP. Complicating Title V permits is simply not what the Department 

needs. The current permitting is years behind the original deadline and the program 

nationally has been mired in bureaucracy almost since its inception. A.I.M. urges DEP to 

BEDFORD, BRIDGEWATER, BURLINGTON, HOLYOKE, WORCESTER, Massachusetts • WASHINGTON, D.C. 
take special notice as to the effect these regulatory changes would have on other 

programs, and rationalize any negative and unproductive impacts. 

A.I.M. would also like to second the remainder of Polaroid Corporations comments 

which represent valid across the board observations and suggestions applicable to the 

program overall and all facilities. 

Should you have any questions please do not hesitate to contact me at 617-262-1180. 

Sincerely yours, 

Robert A. Rio, Esq. 

Vice President 

Environmental Programs 
Donaldson, Robert (DEP) 

From: 

Sent: 

To: 

Subject: 

Bob Rio [RRio@aimnet.org] 

Wednesday, June 30, 2004 4:16 PM 

Robert Donaldson (E-mail) 

engine comments 

generator 

mments.doc (34 KB] 

Hard copy i n mai l today. Basicall y the y support the comments o f Polaroi d 

<<generator comments.doc>> 

PLEASE NOTE MY NEW EMAIL ADDRESS I S rrio@aimnet.or g 

I f you have any question s about thi s email contact : 

Robert A. Rio, Esq. 

Vice President , Environmental Programs 

Associated Industrie s o f Massachusetts 

222 Berkeley Stree t 

Boston, MA 02117 

phone: 617-262-1180 

fax : 617-536-6785 

email : rrio@aimnet.org 

Mission Statement - Associate d Industrie s o f Massachusetts 

Establishe d i n 1915, Associated Industrie s o f Massachusetts i s th e larges t nonprofit , 

nonpartisa n associatio n o f Massachusetts employers. A.I.M.'s missio n i s t o promote the 

well-bein g of it s members and thei r employees and the prosperit y o f the Commonwealth of 

Massachusetts by: improvin g th e economic climat e of Massachusetts; proactivel y 

advocating fai r and equitabl e publi c policy ; providin g relevant , reliabl e informatio n 

and excellen t services . 

1 
June 30, 2004 

Robert Donaldson 

Department of Environmental Protection 

Bureau of Waste Prevention 

One Winter Street, 8th Floor 

Boston, MA 02108 

In Re: Proposed Amendments to 310 CMR 7.00 et.seq. and 310 CMR 70.00 - Engines 

and Combustion Turbines 

Dear Mr. Donaldson: 

Associated Industries of Massachusetts (A.I.M.) is pleased to submit the following 

comments regarding the above referenced proposed amendments. Associated Industries 

of Massachusetts is the largest employer association in Massachusetts with more than 

7,600 Bay State businesses and institutions as members. A.I.M. members include large 

and small employers from the industrial, commercial and service sectors, including many 

members affected by this proposed rule. 

Overall, A.I.M. is pleased that the Department has chosen to follow the national model 

with regard to emission standards on these engines. A.I.M. is also encouraged that in 

some cases, the proposed rules will result in a reduction of paperwork and process burden 

for regulated facilities. These amendments will also provide clearer direction for 

regulated sources when trying to permit facilities. This all falls under the category of 

"streamlining", making the process clearer and reducing paperwork while at the same 

time improving the environment. 

However, A.I.M. shares the view articulated by Polaroid Corporation and others that 

these proposed rules may have unintended bureaucratic consequences for those major 

sources that are regulated under the federal Title V program. Since the threshold for the 

engines subject to these regulation drops from 3,000,000 Btu's to approximately 300,000 

Btu's, the increase in workload for Title V sources (and hence for DEP) could be sizable, 

not to mention the fee increases for these sources, for no environmental benefit. Intended 

or not that is the result. This will make these permits more complicated and costly for the 

sources as well as DEP. Complicating Title V permits is simply not what the Department 
needs. The current permitting is years behind the original deadline and the program 

nationally has been mired in bureaucracy almost since its inception. A.I.M. urges DEP to 

take special notice as to the effect these regulatory changes would have on other 

programs, and rationalize any negative and unproductive impacts. 

A.I.M. would also like to second the remainder of Polaroid Corporations comments 

which represent valid across the board observations and suggestions applicable to the 

program overall and all facilities. 

Should you have any questions please do not hesitate to contact me at 617-262-1180. 

Sincerely yours, 

Robert A. Rio, Esq. 

Vice President 

Environmental Programs