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Damberg, Rich

From: Brachtl, Megan

Sent: Monday, March 09, 2015 4:21 PM

To: Damberg, Rich

Subject: FW: Additional Interagency Comments on PM2.5 NAAQS SIP NPRM

Incoming #6

Megan V. Brachtl, Group Leader

State and Local Programs Group

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

(919) 541‐2648

brachtl.megan@epa.gov

From: Szabo, Aaron [mailto:Aaron_L_Szabo@omb.eop.gov]  

Sent: Tuesday, February 10, 2015 2:09 PM

To: Brachtl, Megan

Subject: Additional Interagency Comments on PM2.5 NAAQS SIP NPRM

Megan,

Please see below for some additional interagency comments that relates to mitigation/control options and precursor

policy options.  Please let me know if you wish to respond to these separately or with your next deliverable (redline‐

strikeout document) and how this may affect our schedule.  Thank you very much for your consideration and please give

me a call if you have any comments or questions.

Mitigation/Control:

1. Reviewer recommends providing additional information on whether food security, the availability of an

abundant and affordable food supply, and ecosystem impacts, in addition to technical and economic feasibility

and adverse environmental or energy effects, in determining the “reasonableness” of mitigation/control

options, especially in relation to ammonia.  This relates to page 54, and the use of term “additional reasonable

measures” to identify additional measures that are not included in RACM and EPA’s response to comments that

PM10 and ozone programs do not have this term as those programs already include specific requirements.

2. Reviewer recommends providing additional clarification on why PM10 requirements for control measures

guidance documents do not apply to PM2.5, as PM2.5 is a subset of PM10 (one of the bases for the regulating

PM2.5 under Subpart 4).  If the previous statement is correct, should the requirements for PM2.5 be the same

as PM10?

3. Reviewer recommends providing additional discussion on ammonia as the primary sources of ammonia are

currently identified in the EPA’s National Emissions Inventory to be “livestock raising” (54%) and “fertilizer

application” (27%).  Specifically, given that ammonia emissions from these sources are primarily driven by

biological activity and meteorology, which have generally less opportunity for human control than chemical or

mechanical processes, how is this relative lack of ability for human control into control technologies for these

sources incorporated within mitigation and control options?  Can these limitations be included in a state’s

determination of “reasonableness” or “feasibility”?

4. Reviewer recommends providing additional clarification as ammonia is a reactive nitrogen species with multiple

environmental pathways, how is the potential for other nitrogen‐related environmental impacts from reactive

nitrogen due to potential ammonia controls evaluated?  Is this an aspect that can be considered in a
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“reasonableness” determination as related to adverse environmental impacts?  How is ammonia air emission

impacts weighed in relation to potential water quality or other environmental impacts?

Precursor Policy Options:

1. Reviewer recommends providing clarification relating to PM2.5 precursor demonstration.  Specifically, when

conducting a PM2.5 precursor demonstration, would a state only consider emissions of a precursor in a

nonattainment area for this demonstration?  In this instance, is it assumed that if emissions of a precursor in the

nonattainment area are not significant, then the state would not need to consider emissions of the PM2.5

precursor outside the nonattainment area unless attainment could not be demonstrated otherwise?

Aaron L. Szabo

Policy Analyst

Office of Management and Budget

202‐395‐3621

Aaron_L_Szabo@omb.eop.gov