Midwest Environmental Defense Center Inc. comment on Proposed Approval of Indianapolis PM 2.5 Redesignation and Maintenance Plan

Dear Mr. Aburano: On behalf of Midwest Environmental Defense Center Inc., I am writing to comment on EPA’s proposal to re-designate the Indianapolis, IN 1997 PM2.5 nonattainment area. EPA should not finalize this proposed re-designation for the following reasons. EPA cannot approve the re-designation request because Indiana does not have an adequate PM2.5 PSD program. The PSD program is part of the SIP that an area being re-designated needs to have to ensure that the area will stay in attainment, especially the parts of the area where there are no ambient monitors. The Indiana PSD program is inadequate for PM2.5 because it does not have the required PM2.5 significant emission rates for PM2.5 and its precursor and because it does not have the PM2.5 increments. In addition there has not been a sufficient showing that recent lower monitoring data is due to enforceable and permanent emission reductions. Respectfully submitted, Robert Ukeiley Law Office of Robert Ukeiley 435R Chestnut Street, Ste. 1 Berea, KY 40403 (859) 986-5402