Work Plan & Progress Report - Rhode Island Department of ...

Items 6, 7, 8 & 9: Require DEM to propose new rulemaking. These items all require a significant
level-of-effort either through rulemaking or providing sufficient documentation to show that
rulemaking is not needed. It was the state’s opinion that implementing the regulations would not result
in significant emission reductions. In addition, the guidance did not include any model regulations,
which have been helpful in the past. Due to limited resources DEM may not complete all of these tasks
in 2011. Barbara indicated that the surface coating regulations are close to being completed and the
printing regulations will be next. There was a question if item #9 was needed since it is covered by one
of the other listed items in this category. Dave indicated he would look into removing this item.
Item 12: After reviewing EPA’s guidance for developing transportation conformity SIPS; DEM
decided to adopt a regulation instead of an MOU. OAR has drafted a regulation and met with the MPO
to finalize a draft regulation for public comment. DEM will initiate a stakeholder process and should
be able to complete the regulation and incorporated into the SIP before the end of 2010. DEM will
include EPA Region I as a stakeholder in this process.
Item 13: DEM wants to reevaluate its options for addressing existing and new sources under the CAIR
replacement rule. The wording in this task should be revised. Doug indicated existing sources are not a
problem, however handling new sources and growth of emissions is the issue. Doug indicated the new
rule would be better if it gave RI an emissions budget as a means to address new sources. Dave
indicated that how RI will address new sources needs tocan be built into the SIP. This issue needs
further thought and work. Dave agreed to reword this item.
Item 16: New legislation was enacted this year establishing clean diesel requirements for construction
projects. Frank indicated that DOT has a pilot project that will dedicate 1% of project costs for diesel
retrofit activities in the construction industry. By 2013 all state agency contracts (including DOT
projects) greater than $5M will require retrofits. DEM’s responsibilities in this program will include
determining the retrofit equipment requirements, and conducting a stakeholder process to determine
how to reduce emissions from pre-Tier 1 diesel equipment and how to create a statewide inventory of
diesel equipment in use. Doug mentioned DEM has concern on having the resources to perform this
work especially the inventory work. Using a contractor is an option, but the industry may have
concerns with this option since business confidentiality issues may need to be addressed. Dave
indicated this item should be reworded to reflect all the work that has been done on this issue.
Items 18 & 19: will be revised to reflect the DEM contact is Barbara Morin.
Item 21: Doug McVay will be the DEM contact. DEM will move forward with a low sulfur fuel oil
measure after several states in the Region have completed their rulemaking and potential issues have
been identified and addressed. DEM is taking this approach because of our limited resources. This is a
resource and a timing issue, DEM is not certain this rulemaking will be completed by 9/30/11.
Item 22: DEM indicated there is no available staff to conduct public outreach/education on wood
smoke issues using materials from EPA's BurnWise Campaign. In addition this project is not a high
priority for the state when considering all the other things that needs to be done. Dave indicated he will
remove it from the list this year but would like to revisit it next year.
Item 26: DEM has no expired Title V permits now and none will be expiring before 10/1/10 so the
number of expired Title V permits will be zero. The metric does not make sense and EPA should
consider language used in past P&C Lists. Dave will look to revise the language on this item.
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