14 determining the appropriate inventory of nearby sources to include in the cumulative modeling

15 analysis, including the potential influence of terrain characteristics on concentration gradients

16 and the availability and adequacy of ambient monitoring data to account for background sources.

17 In light of the March 1, 2011, guidance, the EPA cautions against the literal and uncritical

18 application of very prescriptive procedures for identifying which nearby sources should be

19 included in the modeled emission inventory for NAAQS compliance demonstrations, such as

20 those described in Chapter C, Section IV.C.1 of the draft New Source Review Workshop Manual

21 (U.S. EPA, 1990). This caution should not be taken to imply that the procedures outlined in the

22 draft New Source Review Workshop Manual are flawed or inappropriate in themselves.

23 Cumulative impact assessments based on following such procedures will generally be acceptable

as the basis for permitting decisions, contingent on an appropriate 1 accounting for the monitored

2 contribution. Our main concern is that following such procedures in a literal and uncritical

3 manner may increase the likelihood of double counting modeled and monitored concentrations in

4 many cases, resulting in cumulative impact assessments that are overly conservative and would

5 unnecessarily complicate the permitting process in some cases. Such procedures might be

6 characterized as being sufficient in most cases, but not always necessary to fulfill the

7 requirements of a cumulative impact assessment.


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