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E-M:/ New Haven Violates old standard



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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TO:  enviro-mich@great-lakes.net

Were Russ Harding, John Engler, Dennis Archer, MDEQ Air Division and
EPA Region V right to advocate  redesignation SE Michigan as an 
attainment area when they did in 1995??

Attainment and maintenance of air quality standards is supposed
to occur when legal violations of air quality standards are no longer
expected to occur because of the imposition of control programs.
Air quality modelling is supposed to be used to predict standards
compliance.....

Were they right....no.....they thus continue a 25 year tradition of
being wrong in the prediction of attainment and maintenance of 
air quality standards for smog in Michigan.

Making the wrong prediction, of course, was integral to justifying
NOT imposing gasoline station vapor controls and NOT enacting
a tough vehicle emissions testing control program and NOT imposing
tougher new source review requirements and NOT requiring offsets 
for new emissions, etc. etc.

Last week, New Haven hit a one hour average of 146 ppb.   This is
the fourth excusion of the old one hour standard in a three year period 
(the old standard is still in place
now that the DC Circuit overruled EPA's new standard) and a 
legal violation of the Clean Air Act's National Ambient Air Quality
Standards.

It may be time to go to federal court or petition EPA REgion 5
on the attainment status of SE Michigan.

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Alex J. Sagady & Associates        Email:  ajs@sagady.com

Environmental Enforcement, Technical Review, Public Policy and
Communications on Air, Water and Waste Issues
and Community Environmental Protection

PO Box 39  East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)
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