PAUL R . LEPAGE 

GOVERNOR 

June 13, 2012 

David Conroy, Chief 

Air Programs Branch 

U.S . EPA Region I 

1 Congress St., Suite 1100 

Boston, Ma. 02114-2023 

RE: Required SIP Elements Under Section 110(a)(1) and (2) for the 

1997 PM2.5 NAAQS 

Dear Mr. Conroy: 

PATRICIA W. AHO 

COMMISSIONER 

On January 3, 2008, the Maine Department of Environmental Protection (DEP) submitted an 

Infrastructure State Implementation Plan (SIP) to the U.S . Environmental Protection Agency 

(EPA) demonstrating that Maine is in compliance with the procedural, timing and infrastructure 

requirements contained in section 110(a)(1) and (2) of the 1990 Clean Air Act Amendments 

(CAA) as required for the 1997 PM2.5 national ambient air quality standards. Since that time, it 

has come to the Department's attention that the Maine submittal did not fully address all section 

110(a)(2) requirements . 

The Maine submittal did not include some elements required under section 110(a)(2)(D) related 

to Federal prevention of significant deterioration (PSD) requirements for PM2.5 and greenhouse 

gases (GHG). The elements that were only partially addressed include: section 110(a)(2)(C) ; 

section 110(a)(2)(D)(i)(II) ; 110(a)(2)(D)(ii) ; and section 110(a)(2)(J) . Maine is hereby 

committing to adopt and submit the necessary regulation revisions to EPA for each of the 

aforementioned section 110(a)(2) elements for both the 1997 and 2006 PM2.5 NAAQS by a date 

that is no later than one year from the conditional approval of Maine's PM2.5 Infrastructure SIP. 

Recognizing that EPA withdrew its previous approval Maine's PSD programs to the extent they 

apply PSD to Greenhouse Gas emitting sources below the thresholds in the final Tailoring Rule 

(75 FR 31,514)1, Maine is also requesting that EPA therefore consider only the narrowed PM2.5 

PSD program in its review of this Maine Infrastructure SIP submittal 

The section 110(a)(2)(G) Emergency Power requirements were also inadequately addressed, 

since the Department had not updated its Chapter 109 Emergency Episodes Regulations to 

1 Thereby "narrowing" the scope of the GHG PSD program. 

AUGUSTA 

17 STATE HOUSE STATION 

AUGUSTA, MAINE 04333-0017 

(207) 287-7688 FAX: (207) 287-7826 

RAY BLDG., HOSPITAL ST . 

STATE OF MAINE 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

BANGOR PORTLAND PRESQUE ISLE 

106 HOGAN ROAD, SUITE 6 312 CANCO ROAD 1235 CENTRAL DRIVE, SKYWAY PARK 

BANGOR, MAINE 04401 PORTLAND, MAINE 04103 PRESQUE ISLE, MAINE 04769-2094 

(207) 941-4570 FAX: (207) 941-4584 (207) 822-6300 FAX: (207) 822-6303 (207) 764-0477 FAX: (207) 760-3143 

web site : www.maine .gov/deP 
Letter to David Conroy 

6/13/12 

Page 2 of 2 

include the new PM2.5 NAAQS and action levels . The Department has since drafted proposed 

amendments to its Chapter 109 that will fully address the section 110(a)(2)(G) requirements, and 

is scheduled to formally propose the amendments on August 1, 2012. Maine is therefore 

committing to adopt and submit the revised Emergency Episodes Regulations to EPA by a date 

that is no later than one year from the conditional approval of Maine's PM2.5 Infrastructure SIP 

Finally, with respect to section 110(a)(2)(E)- Adequate Resources, the Department is committing 

to submit statutory provisions pertaining to conflict of interest to EPA for incorporation into the 

Maine by a date that is no later than one year from the conditional approval of Maine's PM2.5 

Infrastructure SIP. 

Thank you for your attention to this matter, and if you should have any questions, please contact 

Jeff Crawford at (207) 287-7647 . 

Sincerely, 

Melanie Loyzim, Director 

Bureau of Air Quality 

Cc : Anne Arnold, EPA 

Heather Parent, DEP 

Jeff Crawford, DEP