March 9 , 2010

Filed via: e

- mail and www.regulations.gov

Ms. Susan Lynn Stone , EPA ( stone.susan@epa.gov ) Health and Environmental Impacts Division Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

Mail Code C504

- 06
Research Triangle Park, NC 27711

Request for Extension of Comment Period for Proposed Rule Regarding the National

Ambient Air Quality Standards for Ozone (“Ozone NAAQS”) ; 7 5 Fed

. Reg

. 2938; January 19, 2010 ; Docket No. EPA

- HQ

- OAR

- 2005

- 0172

To Whom It May Concern:

The American Petroleum Institute (API) represents about 400 member companies involved in all aspects of the oil and natural gas industry. I f finalized as proposed, the Ozone NAAQS Rule would have a significant impact on both the ups tream and downstream segments of this industry.

To adequately address this proposal, API requests that EPA grant an additional 60 days for public comment, extending the comment period until May 21

, 2010. EPA is not under a court order to finalize

the reconsideration ; the August 31, 2010 deadline is self

- imposed. EPA provided 90 days for comment on the 2007 Ozone NAAQS rule, when they were under a court ordered deadline. This proposal merits a longer comment period for the reasons provided below.

This proposal merits 60 additional days to co mment because although E PA is purporting to base the reconsideration on the same data underlying the 2008 NAAQS standard, the proposal actually references new data and issues not previously raised and analyzes t he older data in entirely new ways. EPA has

asked for comments on many complex science and policy issues that industry must review and analyze. First and foremost, EPA has requested comment on a new range of standards, both primary and secondary. EPA has also included an updated benefits assessment, including new approaches to assessing both ozone and PM “co

- benefits,” benefits to welfare at different possible levels of the secondary standard, a nd the most efficient and effective way to implement a secondary standard that differs markedly from primary in form. Ted Steichen

Policy Advisor, Regulatory and Scientific Affairs

1220 L Street, NW Washington, DC 20005

- 4070

USA Telephone 202

- 682

- 8568

Fax 202

- 682

- 8270
Email steichent@api.org Ted Steichen

Policy Advisor, Regulatory and Scientific Affairs

12 20 L Street, NW Washington, DC 20005

- 4070

USA Telephone 202

- 682

- 8568

Fax 202

- 682

- 8270
Email steichent@api.org2

In addition, EPA is in the midst of o ther PM and CO NAAQS

- related activities which require API time

and attention

. Moreover, API members are impacted by numerous EPA actions . S ince the January 19 Federal Register publication of the Ozone NAAQS proposal, API has been participating in EPA rulemaking activities or reviewing final rules with which our members must comply, as follows:

API fi led comments regarding the proposed SO2 NAAQS and a Request for Correction of

Technical Information of Sulfur Dioxide Health Effects on February 8 ;

API filed comments on the Lead Ambient Air Monitoring Requirements on February 16 ;

API testified at a hearing on February 26 and is in the process of prepar ing comments , due

March 29, in response to comments on ending the PM 2.5 NSR transition;

API submitted comments regarding the Utah PM10 redesignation on March 1

API is reviewing the final NO2 NAAQS rule , and the recent modeling guidance

API is reviewing the final Renewable Fuel Standards rule

, not yet published in the Federal Register.

To ensure an adequate and complete record for EPA’s reconsideration of the ozone NAAQS and to

allow commenters a fair opportunity to review and analyze EPA’s proposal, given the high level of EPA regulatory activities that impact API members, API respectfully requests that EPA extend the public comment deadline until May 21, 2010. Please contact me at steichent@api.org or ( 202) 682

- 8568 at your earliest convenience.

Respectfully s ubmit ted,

/s/

Ted Steichen

cc: EPA Docket No. EPA

- HQ

- OAR

- 2005

- 0172

Karin Martin , EPA ( martin.karen@epa.gov ) Lydia Wegman, EPA ( wegman.lydia@epa.gov ) Steve Page, EPA ( page.steve@epa.gov ) Gina McCarthy, Assistant Administrator, Air and Radiation, EPA ( mccarthy.gina@epa.gov ) Howard Feldman, Director, Regulatory and Scientific Affairs, API ( f eldman@api.org ) Khary Cauthen, Director, Federal Relations, API ( cauthenk@api.org ) Janice Raburn, Senior Counsel, API ( raburnj@api.org )