Environment Health & Safety	Ours to Protect

Texaco Inc.

P.O. Box 509

Beacon, NY 12508

From the Desk of Arthur Lee	TXN 341-7173

Tel: (914) 838-7173

Fax: (914) 838-7115

DATE:	May 10, 1996

TO:	Joe Paisie, EPA	FAX (919) 541-5489

Sharon Reinders, EPA	FAX (919) 541-0824

Research Triangle Park, NC

SUBJECT:	(1) The Base Program and Policy Analysis Workgroup Process

(2) Framework of the Interim Implementation Transition Policy

First, let me express my appreciation to you for the work in coordinating the processes and meetings of the subject workgroup. However, I continue to have the following concerns.

1.	THE BASE PROGRAM AND POLICY ANALYSIS WORKGROUP PROCESS

The preliminary schedule, dated April 29, 1996, is too ambitious. Although the first issue paper received a fair amount of discussion, subsequent papers may not receive sufficient deliberation. Three papers are scheduled to be discussed per conference call, with each expected to receive an average of about 40 minutes total. Each paper can raise important inter-related issues that may not be fully comprehended when the issue paper is first scoped. EPA should consider the possibility of stretching out the schedule to accommodate full deliberation of all issues and consider the possibility that the issuance of a final implementation policy for any potential new standard may be delayed.

2.	FRAMEWORK OF THE INTERIM IMPLEMENTATION TRANSITION POLICY

Innovative programs and strategies should be allowed during the transition period if the ozone and particulate matter standards are revised. In order to encourage innovation, EPA's final guidance during this period must be sufficiently flexible to allow innovative approaches that would result, at least directionally, in air quality improvement. Prescriptive mandates can only discourage innovative thinking. Ultimately, EPA should recognize that there will be programs and strategies that will result in the most air quality improvement at the least cost to the regulated community and society.

cc:	Jerry Golden, TVA;	FAX (423) 751-7545	Filename:	o3pmrh01.ioc