Comment submitted by Laurel L. Kroack, Chief, Bureau of Air, Illinois Environmental Protection Agency

The Illinois EPA supports USEPA’s proposal that areas may remove 1-hour major NSR requirements upon designation of attainment for the 1997 8-hour standard. However, Illinois EPA believes the better approach is to allow areas to remove 1-hour major NSR requirements upon a determination of attainment of the 1-hour and 1997 8-hour standards. Further, Illinois EPA supports USEPA’s additional approach, but respectively requests that USEPA finalize this approach such that it would allow areas which have attained the 1-hour standard, but not the 1997 8-hour ozone standard (or that have also attained the 8-hour standard but not been redesignated yet), to remove 1-hour major NSR requirements. The Illinois EPA further requests that in those specific situations, USEPA not require Section 107(d)(3)(E) redesignation requirements as any such area will be required to comply with these requirements for the redesignation of the 1997 8-hour standard, which would include a more stringent 8-hour maintenance plan. The Illinois EPA maintains that the severe NSR program, under the 1-hour ozone standard, should not, at any time, apply to the Greater Chicago Ozone Nonattainment Area since this area has not only attained the 1-hour ozone standard and not been allowed to pursue and obtain redesignation, but has also attained the more stringent 1997 8-hour ozone standard. See attached letter for full details of the comments.