KRC Requests NOx Reductions Be Made Permanent Before Louisville Ozone Redesignation Is Approved

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KRC Requests NOx Reductions Be Made Permanent Before Lousville Ozone Redesignation Is Approved  Posted: June 6, 2007
May 29, 2007

Ms. Heidi LeSane
Regulatory Development Section
Air Planning Branch
Air, Pesticides and Toxics Mgmt. Division
U.S. EPA Region IV
61 Forsyth Street SW
Atlanta GA 30303

Re: 72 F.R. 20966
Redesignation of Louisville 8-Hour Ozone
Nonattainment Area To Attainment

Dear Ms. LeSane:

These comments are submitted on behalf of the Kentucky Resources Council, Inc. concerning the proposed redesignation of Louisville to attainment with respect to the 8-hour ozone standard.

KRC has reviewed the proposed approval of the redesignation, and offers this comment regarding the proposed rule. As noted on p. 20972, EPA's approval of the redesignation rests in part on reductions achieved through the NOx SIP Call.

The data reflect that Trimble, Ghent and Mill Creek power plants are running at very low NOx emission rates, with Ghent and Trimble achieving the lowest rates for 2005 in the nation. To the extent that these reductions achieved by the utilities to aid compliance with the NOx SIP call are relied upon by the District and Kentucky in order to demonstrate attainment or maintenance of attainment, those emission reductions must be made permanent and enforceable since, as a cap and trade program, the NOx SIP call would not itself require that the utilities continue to operate at such a low emissions rate from these units.

Thank you for your consideration of these comments.

Tom FitzGerald
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