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Board of County Commissioners <br /> <br />August 16, 2004 <br /> <br />Mr. Thomas Allen <br />Division of Air Quality <br />North Carolina Department of Environment and Natural Resources (NCDENR) <br />1641 Mail Service Center <br />Raleigh, NC 27699-1641 <br /> <br />Re: <br /> <br />Proposed Amendments to 15A NCAC 02D .0530 <br />North Carolina State Register, July 15, 2004 <br />New Source Review (NSR) Rules <br /> <br />Dear Mr. Allen: <br /> <br />The Cabarrus County Board of Commissioners strongly encourages North Carolina to adopt the <br />federal version of the NSR rules, in their entirety, as shown in Option 2 of the proposed <br />amendments referenced above. Adoption of the federal rules will ensure that North Carolina <br />remains economically competitive with other states in the Southeast. Fair and consistent NSR <br />rules are crucial to maintain and grow our state's economy. <br /> <br />The regulatory clarity and operational flexibility provided by the federal NSR rules will encourage <br />industry to upgrade, modernize, and improve their facilities in environmentally and economically <br />beneficial ways that are currently hindered by the burdensome NSR permitting process. For <br />these reasons, EPA predicts an overall decline in air emissions as a result of implementation of <br />these new NSR rules. <br /> <br />Adoption of the federal NSR rules will not negatively impact North Carolina's air quality. Health- <br />based National Ambient Air Quality Standards, and the programs and requirements to protect <br />those standards will not be affectbd by the NSR revisions. In fact, air quality in North Carolina <br />and the United States is improving due to federal and state emissions reductions programs, and <br />that trend will continue. Adoption of the federal NSR rules will complement those efforts. <br /> <br />The federal NSR rules represent a proper balance of the environment and the economy. <br />Adopting limitations that are not required by any federal regulation sends the wrong message to <br />current and prospective business and industry and will place North Carolina at an economic <br />disadvantage. Therefore, the Cabarrus County Board of Commissioners urges the North <br />Carolina Environmental Management Commission to adopt the federal version of the NSR <br />rules. <br /> <br />Sincerely, <br /> <br />Robert M. Freeman <br />Chairman, Board of Commissioners <br /> <br />Cabarms County · 65 Church Street, SE · Post Office Box 707 · Concord, NC 28026-0707 <br /> <br /> Phone: 704-920-2100 · Fax: 704-920-2820 · www.cabarruscounty, us <br /> <br /> <br />