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OAR Box 1790 

Prepped by Keeia Richards 

Document Number: 

225) ll-F-14 

Docket Number: 

A-90-37 

Printed 10/31/2008 12:43:17 PM Sheet 225 of 250 
ro ?^ IFTT O i V * *^a > i 0 « 

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" .--. o .. . • i \ .-» ^ , • i . .•a-a^i . ~ [ C O 

§§& United States Department of the Interior gjgg, 

A-QO-37 

l> nriM m'.FKR T" 

NATIONAL I'ARK SERVICE 

P.O. Box 37127 

Washington. D.C. 20VV.-i[21 

NUMBER OF PACES TO FOLLOW 

TO: _ 

FRONt 

SUBJECT: 

-XJC+ 26_ 

2. 

W7 

DATE: y/s 

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DENNIS, JOHN 

EADY, COLLETTE 

JOHNSTON. 6ARY 

KLIWINSKI, SHARON 

MALKIN, KAREN 

HCCLELLAND, LINDSAY 

MILLER, ABBY 

PECK, DEB8Y 

202-208-5193 

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WALKER. BILL 202-219-3386 

WATKINS. WIUA 202-208-4913 

WILSON, RITA 202-208-3884 

U ^ ] AP?x :"• C IS33 

17. 
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NSR Paokage, Proposed WPS/U8FW8 Inserts to 11/16/94 OMB Version 

Preamble 

P. 314, Insert A, first full para., after "adveree impact 

determination": 

The NSR Class I Area Coordination Subgroup came up with the 

following criteria to be considered by the permitting authority: 

(a) Scip.nti.fic basis of the FLM's adverse impact determination; 

(b) Existing status of potentially affected Class I areas and their 

AQRVe; 

(c) Presence of mltiqatiny factors, such as offsets; 

(d) Permit conditions, such as pre- and post-construction 

monitoring, with contingent corrective action plan; 

(e) Informal mediation efforts during consideration of the. 

application; 

(f) Participation by the FLM duriny completeness review; 

(q) Public support/opposition to the permit; and 

(h) alternative siting. 

P. 315, Insert D, after (2) , deleting existing tevt and substitute 

following: 

Existing Adverse Impacts Previously Documented for the Class I Area 

Where the PLM has previously publicly documented or certified 

existing adverse impact conditionc at a Class I area, or determined 

that one or more particular proposed sources would constitute an 

adversie impact to an AQRV aL a particular Cla3s I area, that 

information should be afforded substantial weight hy the permitting 

authority. The legislative history of the CAA instructs to "err on 

the side of protecting the air-quality related values for future 

generations." 6. Rep. No. 95-127, 95th Cong., 1st Sess. 36 (1977). 

The permitting authority should consider that instruction, in light 

of existinq conditions at a particular class I area. 

P. 336, Tnsert C, after "52.21(o) (3)," delete rest of para, and 

substitute: 

In recognizing that Federal class I and li areas have AQRVs, which 

are mandated under various statutes for preservation unimpaired 

(e.g., Organic Act, Wilderncce Act), EPA is proposing to delete the 

last sentence in (o)(i) of both current requlatiuna. These 

clarifications Should help ensure that permit applicants consider 

all potential impacts to Class I and II area AQRVs. 

V. 343, Insert D, new section, before "7. Information 

Clearinghouse": 

Generic Approaches to Address Any AQRV Issue 

The NSR Subcommittee, Existing sources Subgroup discussed several 

options for addressing specific AQRV degradation in Class I areas. 

The group came to consensus on the need to enforce existing rules 

requiring STP revisions in cases where PSD increment cxceedanccc 

have been documented. In particular, the group discussed the need 
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to enforce existing requirements for permitting authorities Lo 

track increment consumption cumulatively for all sources. The need 

for EPA guidance on methodology for tracking emissions cumulatively 

and periodically assessing Increment consumption was recognized. 

EPA.will endeavor to provide such guidance 

The existing Sources Subqroup alsu discussed supplementing existing 

regulations by adding a trigger for SIP revisions, or even adoption 

of regional implementation plans, to address existing adverse 

Impact conditions for AQRVs at Class I areas within a particular 

atate or region. Although PLMs and environmental group 

re.prp.Rentatives pointed out the merits of such an approach in 

ameliorating the "existing sources problem" for AQRVc, no consensus 

of the full group could be reached on this option.