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OAR Box 1802 

Prepped by Charmelle Mathews 

Document Number: 

48) IV-E-43 

Docket Number: 

A-90-37 

Printed 11/4/2008 11:57:59 AM Sheet 48 of 117 
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T37 -E - 43 

For NSR REFORM Rulemaking Docket 

SUMMARY OF COMPLEX MANUFACTURER'S MEETING WITH ROBERT 

PERCIASEPE ON JANUARY 21,2000 

The meeting with Bob Perciasepe was requested by an industry group with 

representatives from NED A CARP, CMA, API, AFPA, Alliance of Automobile Manufacturers, 

Flexible Packaging Assoc, and the National Assoc, of Manufacturers. An attendee list is 

attached. The group indicated their view that there is broad agreement that the New Source 

Review (NSR) program is broken. They indicated that their goal is to have clarity, consistency 

and predictability. They do not mind putting on good controls, however their primary concern is 

the delay and uncertainty associated with the current system. They know the final NSR rule is 

imminent and want a period of intense further dialogue before the rule is cast in concrete. Their 

goal from this dialogue would be to have a workable rule in order to minimize action 

(presumably legal), after the rule is promulgated. Bob Perciasepe noted that his view of the 

NSR program is one where as industry modernizes and makes changes to their facilities, that 

the pollution control should be upgraded at the same time. He indicated that a lot of work has 

been done over the last year, and mentioned plant wide applicability limits (PALs) and the sector 

based approach, in addition to the base program. He indicated that there may be some room for 

further dialogue, and that he would ask staff to get back to Josephine Cooper (Alliance of 

Automobile Manufacturers) on the nature and timing of any future dialogue on this subject after 

some internal discussions. 
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MEMORANDU M 

January 19, 2000 

VIA FACSIMILE 

TO: Assistant Administrator Robert Perciasepe 

FROM: Leslie Ritts, Hogan & Hartson, LLP 

Chuck Knauss, Swidler, Berlin, Sheriff & Friedman, LLP 

RE: Industry Representatives Attending January 21, 2000 NSR 

Meeting 

Don Clay, Director, Environmental Affairs, Koch Industries; Vice Chairman, 

NED^/CARP, and for the National Petroleum Refiners Association 

Josephine Cooper, President, Alliance of Automobile Manufacturers | 

Lee Hughes, Vice President, Bayer; and Chairman, Chemical Manufacturers 

Association's Air Committee 

Jeff Lammers, Vice President, Duralam Industries; and Chairman, Flexible 

Packaging Association 

Susan Moore, Vice President, Environmental Health & Safely, Georgia-Pacific 

Corporation, and for American Forest & Paper Association 

Nancy Newkirk, Vice President, Environment Affairs, American Petroleum 

Institute 

Mark Whittenton, Vice President, Environmental Affairs, Niitional Association of 

Manufacturers 

If you have questions, please call Leslie at 202/637-6573 or Chuck at 

202/424-7644. 

cc: Paul Babosh, OAR 

Rob Brenner, OAR 

Dennis Crumpler, OAQPS 

William Harnett, OAQPS 

John Seitz, OAQPS 

Anna Wood, OAR 

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