Dear Mr. Aburano:
The notice of the proposed rule does not state that EPA conducted a modeling analysis to
demonstrate that removal of the I/M program will not interfere with maintenance or attainment
of the new 1-hour NOx NAAQS. It likely will. Therefore, EPA cannot approve this SIP
modification without a quantitative analysis of its impacts on the 1-hour NOx NAAQS.
Sincerely,
Robert Ukeiley
Law Office of Robert Ukeiley
435R Chestnut Street, Ste. 1
Berea, KY 40403
(859) 986-5402
Clark and Floyd Counties Indiana I/M Shutdown: Ukeiley comment
This is comment on Proposed Rule
Proposed Approval of the Clark and Floyd Counties Indiana I/M Shutdown Request
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Related Comments
Public Submission Posted: 02/15/2011 ID: EPA-R05-OAR-2009-0729-0009
Feb 11,2011 11:59 PM ET
Public Submission Posted: 02/15/2011 ID: EPA-R05-OAR-2009-0729-0010
Feb 11,2011 11:59 PM ET