Within Section IV.C it does not address situations where a state with a SIP approved program has specifically not adopted 40 CFR 52.21(b)(23)(ii). It seems an untenable position that any increase in emissions is significant when a significance level has been defined in the regulation requiring implementation of the requirements for PM2.5.
EPA should address and issue at the same time as the repeal the other components of the PM2.5 program including but not limited to: the PM2.5 significant impact levels for the 24-hour and annual standard; the PM2.5 monitoring exemption thresholds for direct and indirect emissions; and whether indirect emissions should be addressed in short range transport modeling; rather than promising to address the issues in the future so that the whole program can be effectively implemented by states.
Without direct pressure to resolve the issues assocaited with the PM2.5 program these issues will not get addressed within any relavant time frame. In general, EPA has been unable to resolve these issues since the date of promulagation of the NAAQS.
Comment submitted by E. Milligan
This is comment on Proposed Rule
Implementation of the New Source Review NSR Program for Particulate Matter Less Than 2.5 Micrometers: Proposed Repeal of Grandfathering Provision and End the PM10 Surrogate Policy
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