MEMORANDUM

TO: Environmental Issues Committee
                State Issues Committee

FROM: Frank Ferraro, Environmental Issues Committee Chair
                Jane Cahill, State Issues Committee Chair
                Samantha Slater, Manager of State and Regional Affairs

DATE: April 2, 2001

RE: NOx SIP Call Implementation - Draft EPSA Letters to Michigan
                and North Carolina Attached
? Comments Due By Wednesday, April 4th, Close of Business

Most of the 19 states subject to the NOx-SIP Call rule have submitted draft 
or final plans to revise their state implementation plans (SIPs) to meet the 
rule's emission-reduction requirements.  U.S. EPA is in various stages of 
reviewing and taking action on the plans.  It is expected that Northeastern 
states' plans will generally be acted upon first since they were among the 
first to be submitted.

North Carolina and Michigan are both in the process of finalizing their plans 
for implementing the NOx SIP-Call rule.  Both of their rules, as currently 
drafted, contain approaches of particular concern to merchant suppliers.  
Specifically, both feature provisions that could limit significantly the 
number of allowances available to new generating facilities.

EPSA has drafted comments to these states advocating more reasonable 
approaches, which will be more likely to ensure sufficient allowances to 
support capacity additions.  A copy of the drafts is attached for review.  
Please provide any comments on the letter to Samantha Slater at (202) 
628-8200 or sslater@epsa.org no later than the close of business on 
Wednesday, April 4th.  Please contact Samantha Slater at EPSA for further 
information.

Attachments


 - EPSA NC letter.doc
 - EPSA MI letter.doc