Bird, Patrick 

From: 

Sent: 

To: 

Cc: 

Subject: 

Hi Pat, 

Kennedy, Eric <Eric.Kennedy@maine.gov> 

Friday, April 08, 2016 4:02 PM 

Bird, Patrick 

Crawford, Jeff S; Graham, Tom; Ostrowski, Kevin; Gilbert, Jane; Cone, Marc A 

RE: Growth Analysis in Maine's SIP Approved Chapter 115 

Thanks for consulting with us about this. After checking with folks here, we agree with you that it is appropriate to 

remove the existing SIP language referenced below and add the current version of the "Growth Analysis" language 

contained in Chapter 115 and also referenced below. 

Let us know if you have any other questions. 

Have a good weekend ! 

Eric 

Eric Kennedy, P.E . 

Director, Division of Licensing and Compliance 

Bureau of Air Quality 

Ma ine Department of Environment al Protection 

207-287-5412 

eric.kennedy@maine.gov 

From: Bird, Patrick [mailto:Bird.Patrick@epa.gov] 

Sent: Wednesday, April 06, 2016 10:27 AM 

To: Kennedy, Eric 

Cc: Crawford, Jeff S 

Subject: Growth Analysis in Maine's SIP Approved Chapter 115 

Hi Eric, 

Thanks for taking my call earlier. We're trying to be clear as possible in our upcoming PSD SIP action {PM2.5 action, 

with some additional PSD-related items) and reduce any potential redundancies in the Maine SIP. 

With that in mind, I noticed a new provision being added to the SIP at Chapter 115 entitled "Growth Analysis" (found at 

115(4}{A}{4}{h}) reads very closely to a provision in the existing Maine SIP. In the new provision Maine essentially adds 

the baseline concentration dates for each pollutant that may require an increment determination, whereas the old 

provision keys off of a 1977 date (which is actually how our PSD rules read, but I think your version is more instructive). 

Maine's current version "Growth Analysis" (found at 115(4)(A)(4)(h) 

(h) Growth Ana lysis. The air quality impacts and the nature and extent of emissions from all general, commercial, residential, 

industrial, and other growth in the area affected by the Major Modification or the new major source license, including 

associated mobile sources, which has occurred since August 7, l 977 for sulfur dioxide (SOz) and PM IO• since February 8, 1988 

for Oz, and since October ZO, ZO I 0 for PM2.5 pursuant to Section 7 of this Chapter. The growth analysis shall be performed 

only for those pollutants (SOz. PM IO· PM2.5 and/or Oz) for which the modification or new source was determined as major. 

Maine's SIP approved version (found at l SS(III)(B)(S) 

https://www3 .epa.gov/region l /topics/air/sips/me/2003 ME ch 115 .pdf 

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5. The air quality impacts and the nature and extent of emissions from all general commercial, residential, industrial, and 

other growth, including associated mobile sources, which has occurred since August 7, 1977, in the area the source or 

modification would affect. 

I am wondering if you would concur that the appropriate action would be to remove the existing SIP language (mark it 

as "reserved") and add the "Growth Analysis" provision inline beneath it. 

Thanks, 

Pat 

Patrick Bird 

U.S. EPA - Region 1 

5 Post Office Square, OEPOS-2 

Boston, MA 02109-3912 

Phone:617-918-1287 

Fax: 617-918-0287 

Email: bird.patrick@epa.gov 

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