In the existing requirements for New Source Review (NSR) the rules 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 …showed first 75 words of 839 total…

…showed last 75 words of 839 total…not to constitute perpetual immunity...” (Power to Kill) Sources “Power to Kill” Clean Air Task Force, July 2001 “STAPPA/ALAPCO’s NSR Subcommittee’s revised Comments on EPA’s April 6, 2000 NSR Proposals” STAPPA/ ALAPCO, May 5, 2000 “State and Local Agency Guiding Principles for New Source Review” STAPPA/ALAPCO, April 1994 “Advice Unvarnished -- And Unsolicited” Lee Nichols. The Austin Chronicle, March 1, 2002 STAPPA/ALAPCO letter to Secretary Whitman, January 23 2002 “Prevention of Significant Deterioration Reform” States’ Workgroup White Papers, November 16 2000