Subject: FW: New Source Review, Particulate Matter and Greenhouse Gas Permitting Requirements and Other Permitting Rule Updates
From: "AQFeb2011Rules" <[email-masked]>
To: <[email-masked]>
Cc: "MATTHEWS Shelley" <[email-masked]>
Date: Wed, 24 Nov 2010 15:43:01 -0800

This is the last one in this box, "AQFeb2011Rules" for now. I'll log in
& forward any others after 5pm.

From: Martha Moore [mailto:[email-masked]] 
Sent: Wednesday, November 24, 2010 3:16 PM
To: AQFeb2011Rules
Subject: New Source Review, Particulate Matter and Greenhouse Gas
Permitting Requirements and Other Permitting Rule Updates

Dear DEQ Staff and Concerned Participants:

I am submitting a comment on the issue of whether DEQ should use the
same New Source Review (NSR)/Prevention of Significant Deterioration
(PSD) process for the greenhouse gas pollutants as currently used for
all other pollutants in Oregon, or should adopt the federal NSR/PSD
methods.  I strongly urge the continued use of the Oregon NSR/PSD
methods for all pollutants regulated in the future, and particularly for
the greenhouse gas pollutants.

I have worked assisting businesses in numerous states with air
permitting over the past 20 years.  I have particularly worked with many
small and family-owned businesses over that same time period.  Although
many of the small businesses I have worked with have not been subject to
NSR/PSD, I believe that will change in the future as the thresholds that
trigger NSR/PSD permitting are lowered (this intent seems fairly clear
in the preamble to the federal Tailoring Rules for Greenhouse Gases).
The Oregon NSR/PSD regulations are in some ways more stringent than the
federal regulations and in some ways more lenient.  The Oregon program
does provide an incentive for businesses to reduce emissions and not
continue the operation of outdated equipment simply to maintain an
emissions base. However, the true hallmark of the Oregon program from my
perspective is that the program is more comprehensible, less convoluted,
and more predictable than the federal program.    As these programs
begin to affect smaller businesses, the adverse effects will be reduced
if the regulations are comprehensible and predictable.

I strongly urge the continued use of the Oregon approach to NSR/PSD, and
if possible, some outreach to smaller businesses likely to be affected
by these regulations in the future.  Most of the potentially affected
smaller businesses are completely unaware that this major regulatory
program may affect them.

Thank you for the opportunity to comment.

Martha Moore, P.E.

TW Environmental, Inc.

P.O. Box 14373

Portland, OR  97293-0373

503-235-9194

[email-masked]