Comment on FR Doc # E7-15055

Dear Ms. Harder, 8/2/07 We hereby submit our objection to Georgia CAIR Plan's New Source Allocation, which is inadequate and unfairly biases against new renewable resources in the State. To wit, a single coal plant, such as the recently permitted Longleaf 1,200 MW coal-fired plant, will take substantially all of the New Source NOx allocation. The New Source allocation is by emission level. Because a renewable resource is sized by its ability to collect and transport biomass, the typical plant is perhaps 50MW to 100 MWs, or only 4% to 9% of the coal-fired unit. As a result, there is no chance, practically speaking, that a renewable New Sources will receive a meaningful New Source NOx allocation. Such an outcome is bad public policy and contrary to the goals of EPA. For example, A 75 MW biomass-user energy plant, displaces approximately 5 tons/year of coal use, with less of an air quality impact on the Regulated Pollutants, especially Hazardous Air Pollutants, such as mercury, arsenic, cadmium and beryllium. These pollutants are found in coal, but not in biomass. In addition, the collection and use of biomass in a pollution-controlled environment will result in a reduction of PM10 (particulates) as most land clearing and logging debris is open-air burned, which releases smoke (particluates) into the atmosphere. Georgia has one of the highest asthma problems of any state because of particulates. Therefore, as a matter of good public policy, EPA should remand the proposed plan to Georgia EPA to resolve a New Source allocation in a way which does not favor large coal-fired units over the smaller scale renewable resources. EPA can thereby achieve a wider goal of not just NOx emission reduction, but also reduce HAPs from coal use and PM. Thank you for your consideration. Respectfully submitted, Mark S. Sajer Managing Director Summit Energy Partners, LLC via e-mail