Comment submitted by Betsy Newnum

Dear Sir or Madam, I oppose this confusing and non sensical change to the definitions of construction, for NSR Air Permits because of the confusing nature of the change, an inab Changing the definitions of 'beginning construction' would be too confusing ot those who issue the permit, and thus obviously difficult to discern whether the Permittee is in violation. This could and would lead to an inability to meet important NSR requirements, as prescribed by an Environmental Air Engineer of Air Permit, precisely because it may be after the fact . It also presumes issuance of the Permit. Because a 'go- ahead' on construction presumes issuance, the Air Engineer and Permit writers /issuers (likely state environmental agencies) lose alot of leverage for compliance. The Actual emission levels and permit conditions rely on an ongoing feed back , and information gathering and dialogue. Those important condisiont may take time to craft and clarify. Then those conditions must be included IN THE PERMIT, to assurae the Permittee that the company will be operating in compliance with Air Pollution levels and laws. I speak with some experience on this. There must be an understanding of equipment needs and emission levels which is part o the working out of the Permit conditions. It take time for the applicant to provide the absolutely validated emissions as seen in the modeling,, and the equipment involved. There can be misunderstandings or incorrect data or other issues which may take time to correct and resolve, so that the Air Engineer is assured that the Permit he approves, is one which will lawfully refflect emissions standards. I worked for a state agency , in Permits for about 14 years before retiring. Thank you for the opportunity to comment. Betsy Newnum.