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Issue Subgroups
During discussions that took place during the First Stakeholder meeting, issues were noted for further discussion. At the end of the morning session, these issues were consolidated into a list of six main issues that served as the agenda for the afternoon session. Participants were asked to identify issues in which they were interested and form issues subgroups that would report back at the next stakeholders meeting.A synopsis of the discussions on each issue is presented below.
Scope/Definition - Participants examined both the diversity and commonality among the industries included in the MMPP source category. In order to begin discussing these issues, the method for defining the source category and what is included in it was examined. Several approaches were presented for categorizing the various industries:
- By coating application method or process;
- By Materials/Technologies; and
- By coating types.
Source Size - This Issue Subgroup will look at major source facilities versus major source processes; minor source facilities versus major processes; other agency area source programs and strategies; and the inclusion of small business.
Data Collection - One of the main issues of data collection is determination of the baseline year. Participants questioned whether the baseline would be set for the whole category, by subcategory, or by facility. There was discussion regarding the inclusion of prior emission reductions when choosing the baseline. It was stated that the Aerospace MACT allowed for some facility-based regulation. The issue of actual versus permitted emission rates will be analyzed during the review of Title V/Installation permits, permits by rule, emission limitations, and others. Although all states do not currently have Title V permit programs in place, they should before this rule is promulgated. However, it was stated that many facilities have permitted emissions that are well above their actual emission rates. It was recommended that there should be distinguishment between actual emission rates and permitted emissions limitations when this data is analyzed. The issue raised earlier as to how the top 12% of the industry will be defined was also discussed further.
Alternative Questionnaire & ICR - The EPA stated that a generic ICR approved by the OMB will be sent out with a Section 114 letter. In addition, there will be an alternative questionnaire which will be more industry specific. These materials are scheduled to be sent out after the October end of the PMACT process. Participants in this issues subgroup were asked to look at alternatives to the quest ionnaire (such as emissions or permits) the ICR schedule, and the scope of requested information. Discussion digressed to a recent ICR that allowed for only three weeks response time. Participants were concerned that facilities need to be given ample time to gather the requested information.
Flexibility of Regulations - Participants would like to see some flexibility in regulations to allow for innovation in technology.
Consistency - A resounding concern of industry is the consistency among rules, specifically in the areas of record keeping and reporting. The EPA stated that the eight surface coating source categories are working closely together to ensure compatibility.