on determining routine maintenance, repair or replacement are arcane and

difficult to follow. "Currently there is difficulty in determining which

document to follow since there are over 4000 pages worth of material that is

often contradictory, not easily obtainable, and written with little oversight."

As a matter of public policy, we believe that "all changes must go through

the rule-making process. This will ensure that all interested parties have the

opportunity for input... (for example) the definitions of physical changes or

changes in operation that are specifically not modifications, including

routine repair and replacement." (White Paper)

We favor a simplification process which gives industry timeliness and

certainty, but retains a strong technology requirement for all ... modified

sources. Simply put, there should be a coherent set of guidelines that

clearly spell out what thresholds are used to determine when the routine

maintenance, repair or replacement exclusion is applicable. This would

serve two goals, it would allow industry to plan better its ongoing

engineering capitol work plans to improve emissions and it would remove

have been and continue to be a small part of the overall operating costs."

Environmental Protection Agency (EPA), in the Austin Chronicle "To draw

the conclusion that environmental requirements are a primary cause of this

substantial adverse impacts because it places no restrictions on the level of

Some common words found in the essay are:
Secretary DHEC, Review NSR, White Paper, Court Appeals, Austin Chronicle, Instead Congress, Air Act, Chronicle March, useful life, STAPPA/ ALAPCO, EPA's April, repair replacement, exempt nsr, clean air, routine maintenance, air task force, existing sources, air pollution, power kill, operating costs, austin chronicle, clean air task, maintenance repair replacement, routine maintenance repair, january 23 2002,
Approximate Word count = 879
Approximate Pages = 4 (250 words per page double spaced)