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OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

136) IV-C-50 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:24 AM Sheet 136 of 142 
A-90-37 

IV-C-50 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

JUN 17 2002 

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EPA 2 

Mr. Gene Paul 

National Fanners Organization 

528 Billy Sunday Road 

Suite 100 

Ames, Iowa 50010-8087 

Dear Mr. Paul: 

Thank you for your letter dated May 20,2002, to James Cannaughton of the Council on 

Environmental Quality, in which you expressed concerns regarding changes the Environmental 

Protection Agency (EPA) is considering for the New Source Review (NSR) program and its 

possible impact on the electricity supplies for farmers. I appreciate your concerns and believe 

they deserve serious consideration, and I want to respond to the points you raised and to update 

you on our NSR efforts. 

In May 2001, the EPA initiated a review of the NSR program in response to a 

recommendation from the President's National Energy Policy Development Group. The EPA is 

examining the impact of the NSR regulations, including administrative interpretation and 

implementation, on investment in new utility and refinery generation capacity, energy efficiency, 

and environmental protection. As part of this process, we have heard comments from over 

130,000 individuals and organizations. A significant number of these comments raise concerns 

very similar to those in your letter about how the EPA's interpretation of the "routine 

maintenance, repair, and replacement" exclusion from NSR can impact electric generators and 

other sources. Your letter indicated that your members cannot afford the uncertainty of service 

and that if peaking units are taken offline to comply with NSR requirements, then you have a 

concern that it will affect your access to electricity when your members need it most. Other 

commenters are very concerned that the environmental improvements associated with the NSR 

program not be lost as we consider ways to improve the program. I assure you we are 

considering these comments fully as we move forward. Soon the EPA plans to report to the 

President on the impact of NSR on the three areas mentioned above. At that time, we will make 

recommendations on whether improvements to the NSR program are needed to provide more 

flexibility and certainty while ensuring protection of the environment. 
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I believe we can meet the requirements of the Clean Air Act without jeopardizing 

farmers'-and the Nation's-reliabie, affordable energy supplies. Again, thank you for your letter. 

I appreciate the opportunity to be of service and trust that the information provided is helpful. 

Sincerely, 

'KiomSSS. Curran 

g Director 

Office^f*Air Quality Planning 

and Standards 
'00/04/02 15:25 FAX 2024019505 

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SHERRY RUSSELL _004/004 

WatODEMT 

Paul Olson 

VICE-PRESIDENT 

Leonard Vandanburg 

528 Billy Sunday Road 

Suite 100 

Ames, Iowa 50010-8087 

515-292-2000 

nfo@nfo.org 

RECEIVED 

James Laurence Connaughton, Chair 

Council on Environmental Quality 

722 Jackson Place, N W 

Washington, D C 20503 

Dear Mr. Connaughton: 

EXEC. SECRETARIAT 

The National Fanners Organization is a general fann organization, which specializes iii 

collective bargaining and marketing commodities for our members. We provided a 

significant service to our members in being able lo fulfill major orders for both domestic 

and international shipments o f commodities. 

One major aspect o f our organization is to maintain the agricultural basis of many of 

America's rural towns. Anything having a negative impact on farmers and rural 

Americans causes us great concerns and that is the reason I am writing to express my 

apprehension over the proposed Ne w Source Review regulations your agency is 

considering. 

Agriculture producers are a major user o f electricity and unlike many other indusiries, if 

there are blackouts because of these NS R regulations, w e stand to loose a significant 

amount o f our products. If the fans suddenly stop in July in our chicken or hog houses, 

the losses could be catastrophic; if the driers in our grain bins suddenly don't work 

because w e are at the end o f the electric line which has been shut off because o f increased 

demand, that could cost us when w e try to market that commodity. 

We urge you and the Environmental Protection Agency to consider carefully the impact 

o f any changes to the Ne w Source Review program and its affect on all industries. We 

encourage you to look at what activities should initiate a Ne w Source Review very 

carefully and routine maintenance o f power generating facilities should not prompt such a 

review. 

Like I mentioned, agriculture is very dependant on a reliable electricity supply, being at 

the end of the line should hot force us to have any less than anyone else.: The building of 

peaking plants around the country has greatly increased the reliability of electricity and 

has eased our concerns. Please do not cause us any more concern with the adoption of 

rules that are going to hurt electric consumers/ 

Sincerely, 

GenePaul 

Policy Analyst 

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