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OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

96) IV-C-9 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:22 AM Sheet 96 of 142 
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* •• « ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

| \^J^ 7 | RESEARCH TRIANGLE PARK. NC 27711 

\ma^ APR 7 1999 OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

Mr. Robert C. Kaufman 

American Forest & Paper Association 

llll Nineteenth Street, NW, Suite 800 

Washington, D.C. 20036 

Dear Mr. Kaufman: 

This is in response to your March 16,1999 letter that strongly favorea 2-month 

discussion period among key stakeholders to see whether a new "outside the box" conceptual 

approach to new source review (NSR) reform can be worked out, as outlined in the joint industry 

letter to me dated January 26,1999. I am interested to hear that you are optimistic about 

reaching agreement on a number of issues. 

As you know, in the February 2-3 meeting, we asked that by February 28 stakeholders 

provide written proposals that addressed some of the key issues identified on February 2-3. To 

date, we have received only one written product. The EPA is willing to review any work product 

that you develop that reflects a way of dealing with applicability issues that will help us as we 

finalize our NSR Reform rulemaking effort. 

Because of EPA's interest in moving forward on NSR Reform, we have resumed work to 

produce a final rulemaking, based largely on the 1996 proposal, the 1998 notice of availability 

and the ensuing comments on each. We plan to promulgate the rule around the end of 

December 1999 which would have us completing a draft of the Federal Register package around 

June 1999. If a work product on the applicability issues can be produced in a timely manner 

relative to our schedule, we will give it due consideration in promulgating the final rule. This 

means that you should provide such information to us by May 21,1999 so that we can stay on 

track with our schedule. 

I want to thank you for your work on this issue. I look forward to reviewing your 

altemative approach to NSR applicability that would help us to bring the NSR Reform effort to 

closure. Please contact Karen Blanchard (919) 541-5503 regarding whether a meeting to discuss 

your completed work product should be scheduled. 

Sincerely, 

LL-OQ__ 

<L&v John S. Seitz 

^ Director 

Office of Air Quality Planning 

and Standards 
AF&PA 

"•f""""" •** "•* 'f if f 

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AMERICAN FOREST & PAPER ASSOCIATION 

Regulatory Affairs 

March 16,1999 

Mr. John Seitz i 

Director, Office of Air Quality Planning & Standards 

MD-10 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

Dear Mr. Seitz: 

I am writing to you as your staff requested with the comments of the American Forest & 

Paper Association ("AF&PA") on the "nejw source review" reform meeting held on February 2-

3,1999, and on the next steps we should tpke toward NSR reform. As you know, AF&PA and 

its members are deeply interested in this sjibject and have participated actively in EPA's NSR 

reform effort since its inception. 

We strongly favor a two-month period of discussion and negotiation among key 

stakeholders to see whether a new "outsid^e the box" conceptual approach to NSR reform can be 

worked out, as outlined in the joint imdustfy letter to you dated February 26. Based on our first 

meetings, we are optimistic about reaching agreement on a range of issues. It appears that all the 

key stakeholders are committed to these d|scussions. 

As your staff heard February 3, this approach holds out more promise of progress than 

simply promulgating the NSR reform package. A wide range of interest groups—not just 

industry- view that package as seriously ffawed. Given the complexity of NSR and its 25-year 

history, we think that the short time we h^ve set for the reinvention discussions is entirely 

reasonable, and one that we must in good faith take advantage of. 

We very much appreciate the contribution the Agency has already made to this effort and 

we look forward to being able to work wiflh you and your staff in the future. If you or your staff 

have any questions, please fell free to calL write, or send an e-mail. 

cc: Tammy Wyles, Georgia-Pacific 

z 

Sincerely, 

m a tU—. 

Robert C. Kaufmann 

Director, Air Quality Programs 

1111 Nineteenth Street, NW, Suite 800 i Washington, DC 20036 i 202 463-2700 Fax: 202 463-2423 

America's Forest & Paper People—Improving Tomorrow's Environment Today