Comment submitted by Joseph S. Casper, Vice President, Environmental, Health & Safety, The Brick Industry Association (BIA)

Dear Madame/Sir: This letter is submitted on behalf of the brick industry, a $20 billion sector responsible for producing about 10 billion structural brick equivalents on an annual basis. The Brick Industry Association is the national association of the brick industry and represents the manufacturers and distributors of 90 percent of all brick produced in the United States. Our comments are pertaining to the PSD for PM 2.5 proposed rule (Docket ID No. EPA-HQ-OAR-2006-0605). The proposed rule should be further studied to determine its impact on industry and the ability of infrastructure to handle the implementation of the rule. The BIA is concerned that the EPA is prematurely continuing down a path to regulating PM2.5. For instance, the EPA has yet to fully evaluate the test methods for differentiating PM2.5 from larger particles. We are concerned that unreasonably strict limits could be imposed on industries, including industries like ours that include many small businesses. For example: it appears that the agency is considering a limit that would be below the detection limits. Two of the options for establishing the significant monitoring concentration (SMC) for PM2.5 are below what EPA states is the "lowest detection limit." Establishing a limit that is below detection limits does not make sense, as they could not be verified. We contend that the EPA should not establish limits until the agency can reasonably assure that industry (and EPA) has the tools to verify these emission limits. This review should include full and open participation from industry. Thank you for this opportunity to make brief comment. Please contact me with any concerns at (703) 674-1545 / jcasper@bia.org. Respectfully, Joseph S. Casper Vice President, EH&S