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OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

116) IV-C-30 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:23 AM Sheet 116 of 142 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

A-lo-31 

32-.c-3o 

SEP 9 1999 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

Mr. Howard L. Rhodes, Director 

Division of Air Resources Management 

Florida Department of Environmental Protection 

Twin Towers Office Building 

2600 Blair Stone Road 

Tallahassee, Florida 32399-2400 

Dear Mr. Rhodes: 

FEB 2 5 20C0 

EPA AIR DOCKET 

Thank you for your letter of August 13,1999, encouraging us to continue the dialogue 

with the participating stakeholder groups regarding new source review reform. You expressed 

support for the idea that would allow industry to use an applicability test based on changes in 

potential emissions rates in exchange for reducing emissions at all existing major emissions 

units. You suggested further that the existing applicability criteria could continue to apply to 

sources not interested in making the voluntary reductions. 

As you may be aware, we have continued to seek further input from all stakeholders on 

the approaches that have been submitted over the past eight months or so. The meetings with 

stakeholders in August have been constructive, and we believe the follow-up meetings will 

enable us to come to a widely accepted set of program reforms by late this fall. We appreciate 

your thoughts on how these ideas can achieve our goals of providing more flexibility for 

industry, streamlining the permitting process where possible, while preserving the environmental 

protection called for by the Clean Air Act. We will take your comments under consideration as 

we conclude the discussion. 

Again, thank you for your concern and comments. If I can be of further service, please do 

not hesitate to contact me. 

sflSBfilRAL SIGNED 

BY 

HENRY C. THOMAS, JR. 

John S. Seitz 

Director 

Office of Air Quality Planning 

and Standards 

Recycled/Recyclable .Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer) 
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Department of A6fs-ira4-ii if 

Environmental Protection

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Twin Towers Office Building 

jeb Bush 2600 Blair Stone Road David B. Struhs 

Governor Tallahassee, Florida 32399-2400 Secretary 

August 13,1999 

Mr. John Seitz, Director 

Office of Air Quality Planning and Standards 

MD-10 

United States Environmental Protection Agency 

Research Triangle Park, North Carolina 27711 

Dear Mr. Seitz: 

Recently the Florida Pulp and Paper Association met with me to discuss the progress of 

efforts to revise the new source review permitting program through a stakeholders' 

process. There was a major concern that the recent, ongoing discussions may be 

prematurely ended. The stakeholder groups have only been involved in proposing some 

alternatives for the last six months. They believe that further discussion would be useful. 

In light of discussions they had with me, I support the principal of using the stakeholders' 

process. I believe that further discussion would prove useful if the stakeholders as a 

whole were as committed to resolution as this group appears to be. 

From our vantage point, it is clear that the PSD program is one of the more effective air 

pollution reduction programs we have in-Florida. We are able to obtain state-of-the-art 

emissions reductions for new sources and for major modifications at existing sources. 

As the PSD program is reviewed, program modifications should result in more simplicity, 

greater certainty, paperwork elimination, and continuation of emissions reductions. Over 

time, this approach is supposed to result in state-of-the-art emissions control at 

previously grandfathered facilities and major new sources. 

In our discussions, the following idea seemed to attract some support from the pulp and 

paper industry in Florida. If incorporated into revised PSD regulations, it could provide a 

new tool to simplify the current process. If industry proposed to reduce emissions at 

existing major emissions units, the proposal could be used to establish an enforceable 

schedule in a Title V permit. This would bring all major emissions units up to a high level 

of emissions reduction in a reasonable timeframe, such as ten years. If a longer period 

were used, then perhaps there could be <a decreasing benefit for each passing year. 

Obviously, this concept would have to be discussed extensively. 

z 

"Protect; Conserve and Manage Florida's Environment and Natural Resources" 

Printed on recycled paper. 
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Mr. John Seitz 

August 13, 1999 

Page Two 

With these emissions reductions, the need for extensive PSD permits for existing 

participating sources could essentially be eliminated. This would cut costs at all levels 

in the public and private sector. At this point, one could go to a system of potential to 

potential tests, knowing that only increases in emissions beyond a certain threshold 

would trigger PSD. Unless a better solution is found, modifying the existing program 

without making fairly radical changes will in all likelihood result in a more complex and 

confusing program. The complexity of the existing program is difficult to comprehend, 

and there must be a better way. This type of concept may only be attractive to certain 

segments of industry, but it might be one of several options that would reward a 

willingness to reduce emissions in a voluntary program. The existing program would 

continue for those that do not accelerate emissions reductions in some form. 

Having several ways to begin eliminating PSD to achieve environmental cleanup faster 

than the present slow and laborious method is attractive. As a plantwide applicability 

limit may be a good way to provide an alternative to PSD, so might an enforceable 

schedule in a Title V permit that reduced emissions from existing emissions units in 

exchange for elimination of future PSD permitting. Such permits could be negotiated 

one at a time. 

Sincerely, 

Howard L. Rhodes, Director 

Division of Air Resources Management 

HLR/pk 

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