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”); 75 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. If finalized as proposed, the Ozone NAAQS Rule would have a 

significant impact on both the upstream 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 comment because although EPA 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 the 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, and 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

1220 L Street, NW

Washington, DC 20005-4070

USA

Telephone 202-682-8568

Fax 202-682-8270

Email steichent@api.org
2

In addition, EPA is in the midst of other PM and CO NAAQS-related activities which require API time 

and attention. Moreover, API members are impacted by numerous EPA actions. Since 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 filed 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 preparing comments, due 

March 29, in response to comments on ending the PM2.5 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 submitted,

/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 (feldman@api.org)

Khary Cauthen, Director, Federal Relations, API (cauthenk@api.org)

Janice Raburn, Senior Counsel, API (raburnj@api.org)