By Electronic Mail and U.S. Mail Dr. Thomas Armitage Designated Federal Officer EPA Science Advisory Board (1400R) U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 Email:
[email protected] Re: Science Advisory Board (SAB) Consideration of the Scientific and Technical Basis of EPA’s Proposed Mercury and Air Toxics Standards for Power Plants Residual Risk and Technology Review and Cost Review Dear Mr. Armitage: The undersigned organizations respectfully submit this written statement concerning the Science Advisory Board’s (SAB’s) review of the Environmental Protection Agency’s (EPA’s) Proposed Rule entitled National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units—Reconsideration of Supplemental Finding and Risk and Technology Review, 84 Fed. Reg. 2670 (Feb. 7, 2019) (Proposal). INTRODUCTION The SAB has issued a Draft Report on its review of the Proposal. Although dated October 16, 2019, the Draft Report did not become publicly available until December 31, 2019, and the SAB has stated that written statements should be submitted by January 10, 2020. The abbreviated public comment period does not allow sufficient time for adequate in-depth review and detailed discussion of all of the topics raised in the Draft Report. Accordingly, in this letter, we offer general comments but point the SAB to more-extensive and detailed discussions in some of the comments that our groups and commenters have provided in response to EPA’s Proposal. See Comments of Environmental, Public Health, and Civil Rights Organizations (dated April 17, 2019) (Appendix A). We also attach for reference the rulemaking comments filed by Attorneys General of Massachusetts and 20 other states, and other governmental entities, which are also cited below.1 The SAB plans to accept oral testimony on the proposed rule and the Draft Report, together with three other major rulemaking reviews, for one hour during a single abbreviated session on January 17.