crew: environmental protection agency: responsive documents: 3-2-15 : batch 6

To: Cc: From: Sent: Subject:

McCabe, Janet[[email protected]] 'Teri Porterfield'[[email protected]] Adm13McCarthy, Gina Mon 7/21/2014 12:07:00 PM RE:RFS

From: McCabe, Janet Sent: Monday, July 21, 2014 4:52 AM To: Adm13McCarthy, Gina Subject: RFS

Can we talk a bit more about RFS today please?

Janet McCabe

Correspondence Management System Control Number: AX-14-001-0597 Printing Date: June 11, 2014 03:17:08

Citizen Information

Citizen/Originator: Flores, Antonio R. Organization:

Address:

Hispanic Association of Colleges and Universities

8415 Datapoint Drive, San Antonio, TX 78229

Constituent: N/A

Committee: N/A Sub-Committee: N/A

Control Information

Control Number: AX-14-001-0597 Alternate Number: N/A

Status: For Your Information Closed Date: N/A

Due Date: N/A #of Extensions: 0

Letter Date: May 30, 2014 Received Date: Jun 9, 2014

Addressee: POTUS-President of the United Addressee Org: White House

States

Contact Type: L TR (Letter) Priority Code: Normal

Signature: SNR-Signature Not Required Signature Date: N/A

File Code: 401_ 127 _a General Correspondence Files Record copy

Subject: ORF - Daily Reading File - In support of the efforts to help curb the negative environmental

impact of greenhouse gas emissions from segments of current energy-producing

infrastructure

Instructions: Instruction Note: General Notes: CC:

For Your Information -- No action required

N/A

cc to Brian Bond UI)

Donald Maddox - A0-10-DA

OEAEE - Office of External Affairs and Environmental Education

R6 - Region 6 -- Immediate Office

Lead Information

Lead Author: N/A

Lead Assignments:

Assigner Office Assignee Assigned Date Due Date Complete Date

Supporting Information

Supporting Author: N/A

Supporting Assignments:

I Assigner lattice !Jacqueline Leavy IOEX

I Martha Faulkner I OAR

History

!Action By I office

No Record Found.

I Assignee I Assigned Date

IOAR !Jun 10, 2014

IOAR-OAQPS !Jun 11, 2014

I Action I Date

Page 1of2

H A C U


Citizen Information

Citizen/Originator: Lumley, Paul Organization:

Address:

Michel, D.R. Organization:

Address:

Ray, Heather L. Organization:

Address:

Aalvik, Taylor Organization:

Address:

Janssen, Richard

Columbia River Inter-Tribal Fish Commission

700 Northeast Multnomah Street, Portland, OR 97232

Upper Columbia United Tribes

25 West Main Ave, Spokane, WA 99201

Upper Snake River Tribes

413 West Idaho Street, Boise, ID 83702

Cowlitz Indian Tribe

1055 9th Avenue, Longview, WA 98632

Organization: Confederated Salish and Kootenai Tribes

Address: 42487 Complex Boulevard PO Box 278, Pablo, MT 59855

Constituent: N/A

Committee: N/A

Control Information

Control Number: AX-14-001-0606

Status: For Your Information

Due Date: N/A

Letter Date: Jun 2, 2014

Sub-Committee:

Alternate Number: Closed Date: #of Extensions: Received Date:

N/A

N/A

N/A

0 Jun 9, 2014

Addressee: Jo-Ellen Darcy Addressee Org: Office of the Assistant Secretary of

Contact Type: Signature: File Code: Subject:


the Army (Civil Works)

L TR (Letter) Priority Code: Normal

SNR-Signature Not Required Signature Date: N/A

401_127 _a General Correspondence Files Record copy

ORF - Daily Reading File - Request that the Army Corps of Engineers initiate a domestic

regional flood risk management review for the Columbia Basin


N/A

N/A


OITA - Office of International and Tribal Affairs

OW- Office of Water-- Immediate Office

Lead Information

Lead Author: N/A

Lead Assignments:


No Record Found.

Page 1of2

• Columbia River fnter

Tribal Fish Commission

Tribes

14

Deputy Assistant Secretary Jo-Ellen Darcy Page 3 of 4 June 2, 2014

process. We will be contacting you in the near future to set up a meeting to discuss how we can work together to ensure that the tribes' concerns and objectives expressed in this letter are addressed in a timely manner.

Sincerely,

Ji?.:: Etu2 Director Columbia River Inter-Tribal Fish Commission

~ 1.e~ircctor Upper Snake River Tribes

--) --/

r· r.)~IC· ~ D.R. Michel, Executive Director Upper Columbia United Tribes

~Xivik~I Resources Director Cowlitz Indian Tribe

Richard' Janssen, Natural Resources Department Director Confederated Salish and Kootenai Tribes


Citizen Information

Citizen/Originator: Moskowitz, Richard S. Organization:

Address:

American Fuel and Petrochemical Manufacturers

1667 K Street NW, Washington, DC 20006

Constituent: N/A

Committee: N/A

Control Information

Control Number: Status: Due Date: Letter Date: Addressee: Contact Type:

AX-14-001-0614

Pending

Jun 24, 2014

Jun 2, 2014

AD-Administrator

L TR (Letter)

Sub-Committee:

Alternate Number: Closed Date: #of Extensions: Received Date: Addressee Org: Priority Code:

Signature: AA-OAR-Assistant Administrator Signature Date: -OAR

N/A

N/A

N/A

0 Jun 9, 2014

EPA

Normal

N/A

File Code: 404-141-02-01_ 141_a(2) Copy of Controlled and Major Correspondence Record of the EPA

Administrator and other senior officials - Electronic.

Subject: ORF - Daily Reading File -2013 Renewable Fuel Standard for Cellulosic Biofuel Docket No.

EPA-HQ-OAR-2012-0546

Instructions: Instruction Note:

AA-OAR-Prepare draft response for signature by the Assistant Administrator for OAR

N/A

General Notes: N/A

CC: OEAEE - Office of External Affairs and Environmental Education

R3 - Region 3 - Immediate Office

Lead Information

Lead Author: N/A

Lead Assignments:

Assigner Office Assignee Assigned Date Due Date

Brenda Salvador OEX OAR Jun 10, 2014 Jun 24, 2014

Instruction:

Complete Date

N/A





I Assigner I Office

History

!Action By !office

!Assignee I Assigned Date

No Record Found.

!Action !Date

Page 1of2

Richard Moskowitz American Fuel & Petrochemical Manufacturers


Citizen Information

Citizen/Originator: Sosland, Daniel Organization: Environment Northeast

Address: 8 Summer Street, Post Office Box 583, Rockport, ME 04856-0583

Constituent: N/A


Control Information




Letter Date: Jun 4, 2014 Received Date: Jun 9, 2014

Addressee: AD-Administrator Addressee Org: EPA



File Code: 401_127 _a General Correspondence Files Record copy

Subject: ORF - Daily Reading File - Thank you and President Obama for advancing U.S. efforts to

reduce greenhouse gas emissions.



N/A

N/A



OP - Office of Policy


Lead Information

Lead Author: N/A

Lead Assignments:





!Assigner !office

I Ken Labbe j OEX

History

!Action By lattice !Ken Labbe

No Record Found.


joAR jJun 10, 2014

!Action !Date

j Forward control to OAR jJun 10, 2014

Page 1of2

Correspondence Management System Control Number: AX-14-001-0650 Printing Date: June 11, 2014 01 :03:53

Citizen Information

Citizen/Originator: Kirk, Ken Organization: National Association of Clean Water Agencies

Address: 1816 Jefferson Place, NW, Washington, DC 20036-2505

Constituent: N/A


Control Information


Status: Pending Closed Date: N/A

Due Date: Jun 25, 2014 #of Extensions: 0




Signature: DX-Direct Reply Signature Date: N/A



Subject: Instructions:

ORF - Daily Reading File - EPA?s 1994 Combined Sewer Overflow Control Policy

DX-Respond directly to this citizen's questions, statements, or concerns

Instruction Note: N/A

General Notes: N/A



Lead Information

Lead Author: N/A

Lead Assignments:


Eliska Postell- OEX ow Jun 11, 2014 Jun 25, 2014 Glover Instruction:





Complete Date

N/A

I Assigner lattice I Assignee I Assigned Date

History

!Action By

Eliska PostellGlover

lattice OEX

No Record Found.

I Action loate Assign OW as lead office Jun 11, 2014

Page 1of2

June9, 2014

The Honorable Gina McCarthy Administrator U.S. Environmental Protection Agency WilliamJefferson Clinton Building 1200 Pennsylvania Avenue NW Mail Code 1101A Washington, DC 20460

Dear Administrator McCarthy:

I write this letter on behalf of the nearly 300 public clean water utility members of the National Association of Clean Water Agencies (NACWA) to express concern about recent developments involving application of the U.S. Environmental Protection Agency's (EPA's) 1994 Qmbina1S::vver0verflow(CSO) Qmtrol Policy. NACWA played a central role in negotiations leading to the final CSO Policy, and our members have been at the forefront of effectively implementing the Policy over the past 20 years. Due to recent activity related to implementation of the Policy, we request a reaffirmation from EPA that the Agency and its Regional offices wi 11 continue to honor thePolicyand its directives, including its language on cost considerations.

The CSOPolicy:Spubl ication in 1994, and its subsequent codification into the Clean Water Act (CWA), marked a major milestone for EPA, thestates, and the municipal clean water community in setting clear benchmarks and guidance for CSO abatement programs. In particular, thePolicyprovided a regulatory and legal foundation for communities across the country to develop long term control plans (LTCPs) that met the goals of theCWAwhilealsoensuring CSO investments were made in a cost-effective manner. It has served as an excellent example over the past two decades of how EPA, the regulated community, and other key stakeholders can come together and develop a rational approach to clean water improvement that acknowledges both environmental and economic concerns.

However, NACWA has become aware of a concerning development involving at least one EPA Regional office that has expressed a position inconsistent with the CSO Policy. In connection with an L TCP submitted by New York City, EPA Region 2 has advanced a position that ignores the specific "knee of the curve" language in the CSO Policy regarding the cost/performance considerations to be used in evaluating potential CSO control measures. Instead, the Region has taken the position that an L TCP must be designed to achieve the "highest attainable use" in order to be approved. In contrast to the emphasis on cost-effectiveness in the CSOPolicy, the Region's position suggests that the economic basis of attai nabi I ity wou Id be the "substantial and widespread economic and social impact" standard that is generally

NACWAJune 9, 2014 Letter Page2 of 3

required in changing water quality standards (WQS) via a useattainabilityanalysis (UAA). The Region's letter, a copy of which is attached, was sent to the New York State Department of Environmental Conservation shortly after that agency had disapproved a proposed L TCP that would have met the existing WQS, where the utility was not seeking to lower a designated use.

NACWA believes the position advanced by Region 2 is completely inconsistent with the CSO Policy and sets a much higher bar for both cost analysis and performance than was ever intended by the Policy. Th is new interpretation ignores the clear "knee of the curve" cost/performance consideration outlined by thePolicyas the appropriate cost analysis, and instead arbitrarily substitutes a higher analysis reserved for the UAA process. This interpretation creates a false and unauthorized requirement that all LTCPs must bedesigned to achieve a higher designated use than could be attained when applying thePolicy's"kneeof the curve" analysis.

In short, this new interpretation completely contradicts the clear language and intent of the CSO Policy. It represents a violation of the Policy and, by incorporation, the CWA itself. NACWA has significant concerns about the position taken by Region 2 in this matter, not only for New York City but also for the national municipal clean water community more broadly. If other Regional offices and/or states start taking similar positions, it will lead to immediateand significant economic harm for clean water utilities across the nation. While NACWA recognizes there may be other technical issues with the particular L TCP that Ii kely prompted Region 2's letter, the apparently new economic standard that the Region is advancing has national implications, and has prompted NACWA to reach out to EPA Headquarters.

NACWA, therefore, requests that EPA unequivocally reaffirm in writing its commitment to the 1994 CSOPolicy, including its language on use of a "knee of the curve" cost/performance analysis when evaluating appropriate cost expenditures for CSO L TCPs. NACWAalso requests EPA reaffirm that theapplicablewater quality benchmark for L TCP approvability is existing WQS, and that the Policy does not require L TCPs to achieve the "highest attainable use," which wou Id rely on the UAA economic harm standard.

EPA has made significant strides in recent years to acknowledge the significant financial pressures facing municipal clean water utilities and their communities with regard to wet weather expenditures, and to create a smarter and moreflexiblesolution to address these concerns. EPA's 2012 Integrated Planning Framework and the recent discussions on affordability are two examples of this more positive approach.

Unfortunately, the more recent developments involving theCSOPolicyoutlined in this letter areat odds with the otherwise constructive actions EPA has taken on wet weather issues. Clean water utilitiesand EPA have collaborated in recent years to champion sustainable actions and expenditures that yield thegreatest environmental benefits--we urge EPA to not al low this progress to be undermined. NACWA looks forward to working with EPA as quickly as possible to address these concerns and clarify the Agency's ongoing commitment to flexibility and smarter investment for our nation's wet weather programs.


If you have any questions or would I ike to discuss these issues further, please do not hesitate to contact me.

Sincerely, r: µ Ken Kirk Executive Director

CC: Bob Perciasepe, Deputy Administrator Nancy Stoner, Office of Water Cynthia Giles, Office of Enforcement and Compliance Assurance Deborah Nagle, Office of Water Mark Pollins, Office of Enforcement and Compliance Assurance


Citizen Information

Citizen/Originator: Miller, Helen Organization:

Address:

Constituent: N/A

Committee: N/A

Control Information


House of Representatives, State of Iowa

Statehouse, Des Moines, IA 50319

Sub-Committee: N/A

Alternate Number: N/A


Due Date: N/A #of Extensions: 0 Letter Date: Jun 9, 2014 Received Date: Jun 8, 2014

Addressee: Senator Tom Harkin Addressee Org: House of Representatives, State of

Contact Type: Signature: File Code: Subject: Instructions: Instruction Note: General Notes: CC:

Iowa




ORF - Daily Reading File - In support of Enlist herbicide


N/A

N/A

OCIR - Office of Congressional and Intergovernmental Relations



Lead Information

Lead Author: N/A

Lead Assignments:





I Assigner I office

I Jacqueline Leavy I OEX

History

!Action By lattice I Jacqueline Leavy \ OEX

No Record Found.

I Assignee !Assigned Date

locsPP \Jun 11, 2014

I Action loate \Forward control to OCSPP \Jun 11, 2014

Page 1of2

Helen Miller STATE REPRESENTATIVE

Ninth District Statehouse: (515) 281-3221

e-mail - [email protected]

HOME ADDRESS P.O. Box675

Fort Dodge, IA 50501 Home: 515-570-3535


Senator Tom Harkin

House of Representatives State oflowa

Eighty-Fifth General Assembly STATEHOUSE

Des Moines, Iowa 50319

731 Hart Senate House Office Building Washington, DC 20510

Dear Senator Harkin,

COMMITTEES Agriculture,

Ranking Member Economic Growth Natural Resources

Transportation

First allow me to thank you for your work on behalf of Iowans and working families across the country. My purpose in writing today is to encourage you to help address a growing problem for farmers in 25 states around the country. The issue relates to herbicide-resistant weeds which affect one-third of all corn and soybean growers in the United States, and is at the center of Iowa's farming industry.

In addition to consuming resources, herbicide-resistant weeds often require farmers to employ mechanical tilling to eradicate them. Mechanical tilling has proven to be extraordinarily detrimental to the environment causing erosion, run-off and water pollution, increased C02 emissions, and increased usage of water.

These environmental hazards have a price with economic modeling showing that herbicide-resistant weeds may cost farmers between $1.9 billion and $2.5 billion annually over the next six years. These impacts will create additional costs, the use of more fuel and the use of more water to combat these weeds. In a challenging economic climate, this is a real danger for rural America and one I hope you can help address.

Knowing how costly and environmentally harmful herbicide-resistance can be, it is especially surprising to know that the United States Department of Agriculture (USDA) and the Environmental Protection Agency (EPA) have held up approval of Enlist for more than four years. Typically, these reviews take around 180 days. Given that Enlist' s chemicals have been extensively tested and the new herbicide used in Enlist is used in more than 70 countries today, I am at a loss to understand the nature of this delay. A wide range of organizations support the approval of Enlist including the National Corn Growers Association and the American Soybean Association, two groups with very direct ties to Iowa's farming community.

I ask you to stand with Iowa farmers, Iowa consumers, and myself in advocating for the USDA and the EPA to complete Enlist' s approval process. This regulatory delay is hurting the environment and the economy, and needs to come to a timely and reasonable conclusion.

Best regards

Helen Miller

Correspondence Management System Control Number: AX-14-001-0710 Printing Date: June 11, 2014 02:51 :27

Citizen Information

Citizen/Originator: Stewart, Cody B. Organization: Office of the Governor

Address: 60 East South Temple Street, Salt Lake City, UT 84111

Constituent: N/A

Committee: N/A

Control Information


AX-14-001-0710

Pending

Jun 25, 2014

May 28, 2014

AD-Administrator

L TR (Letter)

Sub-Committee:



N/A

N/A

N/A

0 Jun 10, 2014

EPA

Normal

N/A



Subject:

Instructions:

ORF - Daily Reading File - State of Utah requests no less than a 12--day comment period for

its response to forthcoming proposal of greenhouse gases from existing power plants


Instruction Note: General Notes: CC:

N/A

N/A





Lead Information

Lead Author: N/A

Lead Assignments:


Ken Labbe OEX OAR Jun11,2014 Jun 25, 2014

Instruction:

Complete Date

N/A





I Assigner I Office

History


No Record Found.

Page 1of2

Correspondence Management System Control Number: OP-14-000-9912 Printing Date: June 11, 2014 11 :54:43

Citizen Information

Citizen/Originator: Beauvais, Joel Organization: U.S. Environmental Protection Agency (EPA)

Address: 1200 Pennsylvania Avenue, N.W., Washington, DC 20460

Constituent: N/A Committee: N/A Sub-Committee: N/A

Control Information

Control Number: OP-14-000-9912 Alternate Number: N/A

Status: Closed Closed Date: Jun 11, 2014

Due Date: N/A #of Extensions: 0 Letter Date: May 22, 2014 Received Date: May 22, 2014 Addressee: AD-Administrator Addressee Org: EPA

Contact Type: L TR (Letter) Priority Code: Normal Signature: N/A Signature Date: N/A



Subject:


Small Business Advocacy Review Panel Report on Polychlorinated Biphenyls (PCBs);

Reassessment of Use Authorizations - INFORMATION MEMORANDUM

ASO-OP-Prepare draft response for signature by the Associate Administrator for OP

N/A

General Notes: CC:

For the Daily Reading File.

N/A

Lead Information

Lead Author: Janet Means-thomas

Office: Due Date: Assigned Date: Complete Date: Instruction:

Lead Assignments:

Assigner Office

Janet Means- OP-ORPM tho mas Instruction:

For Concurrence




I Assigner lattice

OP-ORPM N/A

N/A

Jun 11, 2014 N/A

Assignee

OEX

Assigned Date

Jun11,2014

I Assignee

No Record Found.

Page 1of2

Due Date Complete Date

N/A Jun 11, 2014

I Assigned Date

09

on

on

were on at

on

a

0

me


Citizen Information

Citizen/Originator: Flores, Antonio R. Organization:

Address:

Hispanic Association of Colleges and Universities

8415 Datapoint Drive, San Antonio, TX 78229

Constituent: N/A


Control Information




Letter Date: May 30, 2014 Received Date: Jun 9, 2014

Addressee: POTUS-President of the United Addressee Org: White House

States



File Code: 401_ 127 _a General Correspondence Files Record copy

Subject: ORF - Daily Reading File - In support of the efforts to help curb the negative environmental

impact of greenhouse gas emissions from segments of current energy-producing

infrastructure



N/A

cc to Brian Bond UI)

Donald Maddox - A0-10-DA



Lead Information

Lead Author: N/A

Lead Assignments:





I Assigner lattice !Jacqueline Leavy IOEX

I Martha Faulkner I OAR

History

!Action By I office

No Record Found.

I Assignee I Assigned Date

IOAR !Jun 10, 2014

IOAR-OAQPS !Jun 11, 2014

I Action I Date

Page 1of2

H A C U


Citizen Information

Citizen/Originator: Lumley, Paul Organization:

Address:

Michel, D.R. Organization:

Address:

Ray, Heather L. Organization:

Address:

Aalvik, Taylor Organization:

Address:

Janssen, Richard

Columbia River Inter-Tribal Fish Commission

700 Northeast Multnomah Street, Portland, OR 97232

Upper Columbia United Tribes

25 West Main Ave, Spokane, WA 99201

Upper Snake River Tribes

413 West Idaho Street, Boise, ID 83702

Cowlitz Indian Tribe

1055 9th Avenue, Longview, WA 98632

Organization: Confederated Salish and Kootenai Tribes

Address: 42487 Complex Boulevard PO Box 278, Pablo, MT 59855

Constituent: N/A

Committee: N/A

Control Information


Status: For Your Information

Due Date: N/A

Letter Date: Jun 2, 2014

Sub-Committee:

Alternate Number: Closed Date: #of Extensions: Received Date:

N/A

N/A

N/A

0 Jun 9, 2014

Addressee: Jo-Ellen Darcy Addressee Org: Office of the Assistant Secretary of

Contact Type: Signature: File Code: Subject:


the Army (Civil Works)




ORF - Daily Reading File - Request that the Army Corps of Engineers initiate a domestic

regional flood risk management review for the Columbia Basin


N/A

N/A



OW- Office of Water-- Immediate Office

Lead Information

Lead Author: N/A

Lead Assignments:


No Record Found.

Page 1of2

• Columbia River fnter

Tribal Fish Commission

Tribes

14

Deputy Assistant Secretary Jo-Ellen Darcy Page 3 of 4 June 2, 2014

process. We will be contacting you in the near future to set up a meeting to discuss how we can work together to ensure that the tribes' concerns and objectives expressed in this letter are addressed in a timely manner.

Sincerely,

Ji?.:: Etu2 Director Columbia River Inter-Tribal Fish Commission

~ 1.e~ircctor Upper Snake River Tribes

--) --/

r· r.)~IC· ~ D.R. Michel, Executive Director Upper Columbia United Tribes

~Xivik~I Resources Director Cowlitz Indian Tribe

Richard' Janssen, Natural Resources Department Director Confederated Salish and Kootenai Tribes


Citizen Information

Citizen/Originator: Moskowitz, Richard S. Organization:

Address:

American Fuel and Petrochemical Manufacturers

1667 K Street NW, Washington, DC 20006

Constituent: N/A

Committee: N/A

Control Information


AX-14-001-0614

Pending

Jun 24, 2014

Jun 2, 2014

AD-Administrator

L TR (Letter)

Sub-Committee:



N/A

N/A

N/A

0 Jun 9, 2014

EPA

Normal

N/A



Subject: ORF - Daily Reading File -2013 Renewable Fuel Standard for Cellulosic Biofuel Docket No.

EPA-HQ-OAR-2012-0546



N/A

General Notes: N/A


R3 - Region 3 - Immediate Office

Lead Information

Lead Author: N/A

Lead Assignments:


Brenda Salvador OEX OAR Jun 10, 2014 Jun 24, 2014

Instruction:

Complete Date

N/A





I Assigner I Office

History

!Action By !office


No Record Found.

!Action !Date

Page 1of2

Richard Moskowitz American Fuel & Petrochemical Manufacturers


Citizen Information

Citizen/Originator: Sosland, Daniel Organization: Environment Northeast

Address: 8 Summer Street, Post Office Box 583, Rockport, ME 04856-0583

Constituent: N/A


Control Information








File Code: 401_127 _a General Correspondence Files Record copy

Subject: ORF - Daily Reading File - Thank you and President Obama for advancing U.S. efforts to

reduce greenhouse gas emissions.



N/A

N/A





Lead Information

Lead Author: N/A

Lead Assignments:





!Assigner !office

I Ken Labbe j OEX

History

!Action By lattice !Ken Labbe

No Record Found.


joAR jJun 10, 2014

!Action !Date

j Forward control to OAR jJun 10, 2014

Page 1of2

Correspondence Management System Control Number: AX-14-001-0650 Printing Date: June 11, 2014 01 :03:53

Citizen Information

Citizen/Originator: Kirk, Ken Organization: National Association of Clean Water Agencies

Address: 1816 Jefferson Place, NW, Washington, DC 20036-2505

Constituent: N/A


Control Information


Status: Pending Closed Date: N/A

Due Date: Jun 25, 2014 #of Extensions: 0




Signature: DX-Direct Reply Signature Date: N/A



Subject: Instructions:

ORF - Daily Reading File - EPA?s 1994 Combined Sewer Overflow Control Policy


Instruction Note: N/A

General Notes: N/A



Lead Information

Lead Author: N/A

Lead Assignments:


Eliska Postell- OEX ow Jun 11, 2014 Jun 25, 2014 Glover Instruction:





Complete Date

N/A

I Assigner lattice I Assignee I Assigned Date

History

!Action By

Eliska PostellGlover

lattice OEX

No Record Found.

I Action loate Assign OW as lead office Jun 11, 2014

Page 1of2

June9, 2014

The Honorable Gina McCarthy Administrator U.S. Environmental Protection Agency WilliamJefferson Clinton Building 1200 Pennsylvania Avenue NW Mail Code 1101A Washington, DC 20460


I write this letter on behalf of the nearly 300 public clean water utility members of the National Association of Clean Water Agencies (NACWA) to express concern about recent developments involving application of the U.S. Environmental Protection Agency's (EPA's) 1994 Qmbina1S::vver0verflow(CSO) Qmtrol Policy. NACWA played a central role in negotiations leading to the final CSO Policy, and our members have been at the forefront of effectively implementing the Policy over the past 20 years. Due to recent activity related to implementation of the Policy, we request a reaffirmation from EPA that the Agency and its Regional offices wi 11 continue to honor thePolicyand its directives, including its language on cost considerations.

The CSOPolicy:Spubl ication in 1994, and its subsequent codification into the Clean Water Act (CWA), marked a major milestone for EPA, thestates, and the municipal clean water community in setting clear benchmarks and guidance for CSO abatement programs. In particular, thePolicyprovided a regulatory and legal foundation for communities across the country to develop long term control plans (LTCPs) that met the goals of theCWAwhilealsoensuring CSO investments were made in a cost-effective manner. It has served as an excellent example over the past two decades of how EPA, the regulated community, and other key stakeholders can come together and develop a rational approach to clean water improvement that acknowledges both environmental and economic concerns.

However, NACWA has become aware of a concerning development involving at least one EPA Regional office that has expressed a position inconsistent with the CSO Policy. In connection with an L TCP submitted by New York City, EPA Region 2 has advanced a position that ignores the specific "knee of the curve" language in the CSO Policy regarding the cost/performance considerations to be used in evaluating potential CSO control measures. Instead, the Region has taken the position that an L TCP must be designed to achieve the "highest attainable use" in order to be approved. In contrast to the emphasis on cost-effectiveness in the CSOPolicy, the Region's position suggests that the economic basis of attai nabi I ity wou Id be the "substantial and widespread economic and social impact" standard that is generally


required in changing water quality standards (WQS) via a useattainabilityanalysis (UAA). The Region's letter, a copy of which is attached, was sent to the New York State Department of Environmental Conservation shortly after that agency had disapproved a proposed L TCP that would have met the existing WQS, where the utility was not seeking to lower a designated use.

NACWA believes the position advanced by Region 2 is completely inconsistent with the CSO Policy and sets a much higher bar for both cost analysis and performance than was ever intended by the Policy. Th is new interpretation ignores the clear "knee of the curve" cost/performance consideration outlined by thePolicyas the appropriate cost analysis, and instead arbitrarily substitutes a higher analysis reserved for the UAA process. This interpretation creates a false and unauthorized requirement that all LTCPs must bedesigned to achieve a higher designated use than could be attained when applying thePolicy's"kneeof the curve" analysis.

In short, this new interpretation completely contradicts the clear language and intent of the CSO Policy. It represents a violation of the Policy and, by incorporation, the CWA itself. NACWA has significant concerns about the position taken by Region 2 in this matter, not only for New York City but also for the national municipal clean water community more broadly. If other Regional offices and/or states start taking similar positions, it will lead to immediateand significant economic harm for clean water utilities across the nation. While NACWA recognizes there may be other technical issues with the particular L TCP that Ii kely prompted Region 2's letter, the apparently new economic standard that the Region is advancing has national implications, and has prompted NACWA to reach out to EPA Headquarters.

NACWA, therefore, requests that EPA unequivocally reaffirm in writing its commitment to the 1994 CSOPolicy, including its language on use of a "knee of the curve" cost/performance analysis when evaluating appropriate cost expenditures for CSO L TCPs. NACWAalso requests EPA reaffirm that theapplicablewater quality benchmark for L TCP approvability is existing WQS, and that the Policy does not require L TCPs to achieve the "highest attainable use," which wou Id rely on the UAA economic harm standard.

EPA has made significant strides in recent years to acknowledge the significant financial pressures facing municipal clean water utilities and their communities with regard to wet weather expenditures, and to create a smarter and moreflexiblesolution to address these concerns. EPA's 2012 Integrated Planning Framework and the recent discussions on affordability are two examples of this more positive approach.

Unfortunately, the more recent developments involving theCSOPolicyoutlined in this letter areat odds with the otherwise constructive actions EPA has taken on wet weather issues. Clean water utilitiesand EPA have collaborated in recent years to champion sustainable actions and expenditures that yield thegreatest environmental benefits--we urge EPA to not al low this progress to be undermined. NACWA looks forward to working with EPA as quickly as possible to address these concerns and clarify the Agency's ongoing commitment to flexibility and smarter investment for our nation's wet weather programs.


If you have any questions or would I ike to discuss these issues further, please do not hesitate to contact me.

Sincerely, r: µ Ken Kirk Executive Director

CC: Bob Perciasepe, Deputy Administrator Nancy Stoner, Office of Water Cynthia Giles, Office of Enforcement and Compliance Assurance Deborah Nagle, Office of Water Mark Pollins, Office of Enforcement and Compliance Assurance


Citizen Information

Citizen/Originator: Miller, Helen Organization:

Address:

Constituent: N/A

Committee: N/A

Control Information


House of Representatives, State of Iowa

Statehouse, Des Moines, IA 50319

Sub-Committee: N/A

Alternate Number: N/A


Due Date: N/A #of Extensions: 0 Letter Date: Jun 9, 2014 Received Date: Jun 8, 2014

Addressee: Senator Tom Harkin Addressee Org: House of Representatives, State of

Contact Type: Signature: File Code: Subject: Instructions: Instruction Note: General Notes: CC:

Iowa




ORF - Daily Reading File - In support of Enlist herbicide


N/A

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Lead Information

Lead Author: N/A

Lead Assignments:





I Assigner I office

I Jacqueline Leavy I OEX

History

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I Assignee !Assigned Date

locsPP \Jun 11, 2014

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Helen Miller STATE REPRESENTATIVE

Ninth District Statehouse: (515) 281-3221


HOME ADDRESS P.O. Box675

Fort Dodge, IA 50501 Home: 515-570-3535


Senator Tom Harkin

House of Representatives State oflowa

Eighty-Fifth General Assembly STATEHOUSE

Des Moines, Iowa 50319

731 Hart Senate House Office Building Washington, DC 20510

Dear Senator Harkin,

COMMITTEES Agriculture,

Ranking Member Economic Growth Natural Resources

Transportation

First allow me to thank you for your work on behalf of Iowans and working families across the country. My purpose in writing today is to encourage you to help address a growing problem for farmers in 25 states around the country. The issue relates to herbicide-resistant weeds which affect one-third of all corn and soybean growers in the United States, and is at the center of Iowa's farming industry.

In addition to consuming resources, herbicide-resistant weeds often require farmers to employ mechanical tilling to eradicate them. Mechanical tilling has proven to be extraordinarily detrimental to the environment causing erosion, run-off and water pollution, increased C02 emissions, and increased usage of water.

These environmental hazards have a price with economic modeling showing that herbicide-resistant weeds may cost farmers between $1.9 billion and $2.5 billion annually over the next six years. These impacts will create additional costs, the use of more fuel and the use of more water to combat these weeds. In a challenging economic climate, this is a real danger for rural America and one I hope you can help address.

Knowing how costly and environmentally harmful herbicide-resistance can be, it is especially surprising to know that the United States Department of Agriculture (USDA) and the Environmental Protection Agency (EPA) have held up approval of Enlist for more than four years. Typically, these reviews take around 180 days. Given that Enlist' s chemicals have been extensively tested and the new herbicide used in Enlist is used in more than 70 countries today, I am at a loss to understand the nature of this delay. A wide range of organizations support the approval of Enlist including the National Corn Growers Association and the American Soybean Association, two groups with very direct ties to Iowa's farming community.

I ask you to stand with Iowa farmers, Iowa consumers, and myself in advocating for the USDA and the EPA to complete Enlist' s approval process. This regulatory delay is hurting the environment and the economy, and needs to come to a timely and reasonable conclusion.

Best regards

Helen Miller

Correspondence Management System Control Number: AX-14-001-0710 Printing Date: June 11, 2014 02:51 :27

Citizen Information

Citizen/Originator: Stewart, Cody B. Organization: Office of the Governor

Address: 60 East South Temple Street, Salt Lake City, UT 84111

Constituent: N/A

Committee: N/A

Control Information


AX-14-001-0710

Pending

Jun 25, 2014

May 28, 2014

AD-Administrator

L TR (Letter)

Sub-Committee:



N/A

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0 Jun 10, 2014

EPA

Normal

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Subject:

Instructions:

ORF - Daily Reading File - State of Utah requests no less than a 12--day comment period for

its response to forthcoming proposal of greenhouse gases from existing power plants


Instruction Note: General Notes: CC:

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Lead Information

Lead Author: N/A

Lead Assignments:


Ken Labbe OEX OAR Jun11,2014 Jun 25, 2014

Instruction:

Complete Date

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History


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Correspondence Management System Control Number: OP-14-000-9912 Printing Date: June 11, 2014 11 :54:43

Citizen Information

Citizen/Originator: Beauvais, Joel Organization: U.S. Environmental Protection Agency (EPA)

Address: 1200 Pennsylvania Avenue, N.W., Washington, DC 20460

Constituent: N/A Committee: N/A Sub-Committee: N/A

Control Information

Control Number: OP-14-000-9912 Alternate Number: N/A

Status: Closed Closed Date: Jun 11, 2014

Due Date: N/A #of Extensions: 0 Letter Date: May 22, 2014 Received Date: May 22, 2014 Addressee: AD-Administrator Addressee Org: EPA

Contact Type: L TR (Letter) Priority Code: Normal Signature: N/A Signature Date: N/A



Subject:


Small Business Advocacy Review Panel Report on Polychlorinated Biphenyls (PCBs);

Reassessment of Use Authorizations - INFORMATION MEMORANDUM

ASO-OP-Prepare draft response for signature by the Associate Administrator for OP

N/A

General Notes: CC:

For the Daily Reading File.

N/A

Lead Information

Lead Author: Janet Means-thomas

Office: Due Date: Assigned Date: Complete Date: Instruction:

Lead Assignments:

Assigner Office

Janet Means- OP-ORPM tho mas Instruction:

For Concurrence




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RFS Blog

The Proposed 2014 Renewable Fuels Standards: Considering Options and Seeking Input

Today we released the 2014 Renewable Fuels Standard (RFS) Proposal (Link to PR), and we're asking for

your input on how best to strike a balance between two very important factors: the congressional

directive to annually increase the volume of renewable fuels in the U.S. fuel supply, and the practical

constraints on the pace at which the market can accommodate more ethanol above a threshold known

as the ethanol "blend wall." While some may see this as a challenge, we see it as an opportunity to work

with stakeholders and build upon the Obama Administration's commitment to furthering the

development of all biofuels - including corn-based ethanol, cellulosic biofuel, and advanced biofuel.

With this proposal, we're looking for the best ideas, information, and advice on meeting these

challenges and continuing the growth of renewable fuels into the future.

The RFS program lays the foundation for reducing greenhouse gas emissions and reducing America's

dependence on imported oil by growing our nation's renewable fuels sector. While the production of

renewable fuels has been on the rise, overall gasoline consumption in the United States has fallen below

what was anticipated when Congress authorized the RFS program in 2007. This reality has limited the

fuel market's ability to accommodate increased in ethanol into the nation's fuel supply.

Using flexibilities built into the law, EPA is proposing to adjust some of the volume requirements set by

Congress for 2014 to align the program with current market conditions. Renewable fuels production is

still projected to continue increasing- providing economic benefits and jobs in many areas of the

country while promoting U.S. energy independence and reducing greenhouse gas emissions.

The proposal discusses a broad range of approaches for setting the 2014 standards. We expect to

receive additional data during a 60-day public comment period, and we can adjust the proposed

volumes as appropriate based on the latest information. EPA looks forward to continued engagement

with stakeholders as we work in consultation with the Departments of Agriculture and Energy toward

the development of a final rule.

To: From: Sent: Subject:

Latest

Fritz, Matthew[[email protected]] Adm13McCarthy, Gina Mon 9/9/20131:44:11 PM agenda slides (2).docx

The Honorable Gina McCarthy Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460


August 6, 2013

The Committee on Energy and Commerce is conducting oversight relating to the Administration's current and planned climate change activities, including the actions identified in the President's Climate Action Plan released on June 25, 2013. To assist the Committee and to provide specific information about your agency's climate-related activities, I write to request that you or your designee testify on Wednesday, September 18, 2013, at 10:00 a.m. in 2123 Rayburn House Office Building, at a hearing of the Committee on Energy and Commerce's Subcommittee on Energy and Power entitled "The Obama Administration's Climate Change Policies and Activities."

At the hearing, we seek to hear from relevant Federal agencies about U.S. climate change policies and the Administration's second term climate agenda, and to obtain fuller information regarding the Federal government's past, current, and planned domestic and international activities, climate research programs, initiatives, and new regulatory requirements. In preparing your agency's written testimony, I request that you include the following information:

(1) Describe the climate change related research and technology programs or activities engaged in by your agency, including programs or activities undertaken with other Federal agencies.

(2) Describe the climate change adaptation, mitigation, or sustainability related activities engaged in by your agency, including activities undertaken with other Federal agencies.

(3) Identify all climate change related interagency task forces, advisory committees, working groups, and initiatives in which your agency currently participates or has participated since January 2005.

The Honorable Gina McCarthy Page2

(4) Identify all climate change or clean energy related funding, grants or financial assistance programs in which your agency currently participates or has participated, and the amounts of climate change or clean energy related funding, grants, or financial assistance distributed by your agency, if any, since January 2005.

( 5) Identify all climate change related regulations or guidance documents, including regulations or standards to reduce greenhouse gas emissions, issued, or proposed by your agency since January 2005, and/or under development by your agency.

( 6) Identify all climate change related international negotiations, agreements, partnerships, working groups, or initiatives in which your agency currently or has previously participated, and the role of your agency in those activities, since January 2005.

(7) Provide the approximate amount of annual agency funds attributed to climate change activities for each of the years 2005 through 2012.

(8) Describe the actions your agency has undertaken to respond to the Executive Order 13514 including the approximate costs, personnel, and other resources dedicated by your agency to implementing this executive order.

(9) Provide a list of each sub-agency, division and/or program office within your agency that is currently engaged in climate change related activities, and provide an estimate of the approximate number of your agency employees and/or contractors currently engaged parttime or full-time in climate change related activities.

Please confirm your agency's witness for the September 18, 2013, hearing no later than August 21, 2013, with Nick Abraham of the Majority Committee staff at (202) 225-2927. Additional instructions relating to the hearing and the submission of testimony will be provided under separate cover.

Chairman Subcommittee on Energy and Power

cc: The Honorable Henry A. Waxman, Ranking Member, Committee on Energy and Commerce The Honorable Bobby L. Rush, Ranking Member, Subcommittee on Energy and Power

To: From:

Reynolds, Thomas[[email protected]] Adm13McCarthy, Gina

Sent: Subject:

Wed 8/14/2013 12:38:14 PM Re: WSJ again on RFS

Behind an Ethanol Special Favor

By

• KIMBERLEY A. STRASSEL • WSJ • 8.14.2013

This is just ridiculous.

Gina McCarthy Administrator

Why does the public demand transparency in government? Read on.

Last week, the Environmental Protection Agency issued its annual renewable-fuels mandate, telling refineries how much ethanol they must blend into the nation's gas supply. This quota, which grows each year, is becoming a horrific financial burden on the industry, forcing many refineries to buy federal ethanol "credits" to satisfy the rules. The skyrocketing price of those credits is adding hundreds of millions of dollars to refineries' annual costs.

So it was more than a little curious that the EPA, as part of its rule, announced it was exempting just one mystery refinery (out of 143) from this year's mandate. The dispensation amounts to a significant financial favor to one lucky player, as I wrote Further reporting has revealed that the refinery is Krotz Springs facility in Louisiana. There's reason to wonder why Krotz Springs alone got a deal.

The EPA maintains a program that allows "small refineries"-those with an average capacity of less than 155,000 barrels of crude daily-to apply for a hardship exemption from the mandate. Krotz Springs was one of four refineries that applied for 2013. The other three-Hunt Refining in Alabama, Kem Oil & Refining in California and Placid Refining in Louisiana-are small, privately held concerns. The biggest, Placid, has a capacity of about 57,000 barrels a day, according to January statistics from the federal Energy Information Administration.

Krotz Springs has a capacity of 80,000 barrels, so it meets the definition. Then again, Krotz Springs is just one of Alon's five refineries, which are located in Louisiana, Texas and California, and have a combined capacity of about 215,000 barrels. A New York Stock Exchange-listed company, Alon isn't exactly a mom-and-pop outfit.

Krotz Springs is a merchant refinery, and the ethanol mandate takes a particularly hard toll on such outfits. Alon earlier this month reported a big hit to its second-quarter earnings, partly due to what it estimates this year will be $20 million in ethanol-credit expenses. So yes, Krotz Springs is hurt by the rule.

Then again, so are other refineries. What particularly burned the industry about this exemption is that the EPA is requiring the rest of the industry (including other small, struggling refineries) to pay to cover the Krotz Springs pass.

So what's so special about Alon? If nothing else, it appears to understand how Washington works. Lobbying disclosure records show Alon paid $60,000 in the second quarter of 2013 to the Manatt, Phelps & Phillips firm. This was the same quarter when Alon filed for its exemption. The records show that Manatt lobbied in the House and in the Senate for Alon on the sole issue of "renewable fuel standards." Alon didn't report any appreciable lobbying expenses for the year preceding the quarter. The records also did not tum up similar lobbying efforts by other refineries applying for an exemption.

Republican Sen. David Vitter's office acknowledged on Tuesday that he had joined other Louisiana politicians in sending a letter to President Obama supporting the Krotz Springs exemption. Sen. Vitter's co-signers were Democratic Sen. and Republican Reps. Charles Boustany and Rodney Alexander. Mr. Vitter's spokesman said the office had not been approached by other refineries for support, and noted that the senator has been pushing to waive the 2014 ethanol mandate for every refinery.

Ms. Landrieu's office would not answer inquiries about whether the senator had further involvement in the exemption. This is worth knowing, given that Ms. Landrieu's tough reelection next year will help determine whether Democrats hold the Senate. The Obama administration has an interest in helping her out.

Industry analysts meanwhile note that Alon has a financial tie up with J. Aron, the commoditiestrading arm of Goldman Sachs. That bank has more than a few of its ex-executives in key Obama administration positions, and it has retained ex-Obama officials like former White House counsel Gregory Craig to do work for it.

"There's no question [Krotz Springs] is a disadvantaged refinery," Tom Kloza, chief oil analyst at tells me. "But there are other merchant refineries that are disadvantaged. And within the industry there is a healthy sense of cynicism about this [exemption], given the Goldman Sachs-J.Aron relationship."

In response to queries, an Alon spokesman said the company did not think it "appropriate to

respond to any questions on the status of the application or the exemption process." The EPA did not respond to inquiries about why Alon received the exemption. The EPA had previously told me that its "case by case" decisions on exemptions are based on "metrics" and Energy Department "recommendations."

Maybe so. Perhaps Krotz Springs is facing a financial challenge that dwarfs that of other small refineries. Perhaps the EPA conducted a careful analysis, devoid of political pressure

The problem is we don't know. The EPA, citing confidentiality restrictions, won't explain the process. We are to trust that it did the right thing. Yet this is the same Obama administration that has spent years doling out billions in grants and loans to politically connected energy companies and junking federal rules to help favored players. Why trust the EPA now?

With federal mandates growing to crushing sizes, agencies like the EPA increasingly hold discretionary powers that can mean life or death for companies. The public deserves to know how and why that power is being exercised.

Ms. Strassel writes the Journal's Potomac Watch column.

A version of this article appeared August 14, 2013, on page Al I in the U.S. edition of The Wall Street Journal, with the headline: Behind an Ethanol Special Favor.

To: From:

Wachter, Eric[[email protected]] Adm13McCarthy, Gina

Sent: Tue 8/13/2013 9:26:39 PM Subject: Re: AFPM/API Waiver Request

Thanks. Can you acknowledge the email and thank him for the heads up?

Gina McCarthy Administrator

From: Charlie Drevna ·~===-'-'~~=="-'="'-'"'-' Sent: Tuesday, August 13, 2013 2:58 PM To: Mccarthy, Gina Subject: FW: AFPM/API Waiver Request

From: Charlie Drevna Sent: Tuesday, August 13, 2013 2:29 PM To: 'Mccarthy, Gina' Subject: AFPM/API Waiver Request

Gina,

I know you are in Colorado today, but wanted to give you a heads up. Later today (I hope) we will be filing a "Waiver Petition" for the 2014 RFS. Assume this comes as no surprise.

Best and safe travels,

Charlie

777 North Capitol Street. NE, Suite 805, Washington, D.C. 20002

202.545.4000 202.545.4001

May 23, 20I4

The Honorable Gina McCarthy Administrator U.S. Environmental Protection Agency I200 Pennsylvania Avenue Washington, DC 20S60


GrowthEnergy.org

I am writing to make you aware of some recent developments that are helping to get EIS and higher ethanol blends into the marketplace to continue to meet the achievable goals of the RFS.

First, several major retailers have announced plans to move to EIS because they understand the value of adding EIS to their consumer fuel offering. Specifically, retailers that have announced plans to add EIS include Minnoco in Minnesota as well as Mapco, the retail arm of Delek US - a refiner and obligated party under the RFS, along with Murphy Oil - another major refiner and obligated party under the RFS.

We are also poised to add many more retailers to this list with a new industry funded program to assist retailers with installing the infrastructure to offer higher blends of ethanol. The program is called Prime the Pump.

As you are fully aware, despite the RFS being the law since 2007, the oil industry has failed to give consumers choice of higher ethanol blends at the pump. Everyone was fully aware when EISA was enacted that higher blends would be necessary to meet the goals of the RFS, even at significantly higher gasoline usage projections. In fact, they have done everything possible to keep EIS and other higher blends from the consumer.

Prime the Pump is creating a $30 million fund to assist retailers with the costs of installing the equipment to offer the clean, less expensive fuel to American motorists. Prime the Pump, a fund created solely by a large consortium including the ethanol industry, agriculture companies, as well as national and state commodity organizations, combined with state and national programs will lead to breaking down the artificial blend wall erected by the oil industry. It will provide consumers with access to a less expensive, cleaner and home grown alternative to fossil fuel. We have seen success with this program already with Mapco in the southeast and we think it will only grow.

We wanted to keep you updated on these developments as they are literally changing the landscape each and every day.

Page 1 of2

Please let me know if you need additional information about these recent developments.

Sincerely,

Tom Buis CEO, Growth Energy

777 North Capitol Street, NE, Suite 805, Washington, D.C. 20002

202.545.4000 202.545.4001 Page 2 of2

GrowthEnergy.org

To: Adm13McCarthy, Gina[[email protected]]; Beauvais, Joel[[email protected]] From: Rupp, Mark Sent: Wed 6/4/2014 11 :48:50 PM Subject: Fw: Iowa Governor Branstad Letter to the President on SF 2344

I shared with Janet and crew ...

From: Bartel, Christine [IGOV] <[email protected]> Sent: Wednesday, June 4, 2014 5:53:53 PM To: Rupp, Mark Cc: Hoelscher, Doug [IGOV]; Vande Hoef, Julie [IGOV] Subject: FW: Iowa Governor Branstad Letter to the President on SF 2344

Hi Mark:

Attached please find an electronic copy of the letter Governor Branstad and Lt. Governor Reynolds sent to President Obama to share Iowa Senate File 2344. This legislation received overwhelming, bipartisan support from a split Iowa Legislature and it underscores Iowa's commitment to renewable fuels. Please let us know if you have any questions.

Governor Branstad and Lt. Governor Reynolds urge President Obama and the EPA to "reinforce this State-level policy by supporting a strong, robust Renewable Fuel Standard with higher renewable volume obligation levels." Thank you for your assistance in sharing this letter with Administrator McCarthy and for her consideration of their request.

Sincerely, Christie Bartel Downey

Christie Bartel Downey Policy Analyst State of Iowa Office of State-Federal Relations 444 North Capitol Street, Suite 359 Washington, D.C. 20001

202.624.5442-Ph 202.624.8189-Fax

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