March 23, 1995


Donald Sutton, Manager
Permit Section
Bureau of Air
Illinois Environmental Protection Agency
P.O. Box 19276
2200 Churchill Road
Springfield, Illinois 62794-9276

Dear Mr. Sutton:

The purpose of this letter is to respond to Illinois Environmental Protection Agency's (IEPA) February 27, 1995, request for reconsideration of the interpretation of stationary source applicability to Color Communications, Inc. located in Chicago, Illinois.

IEPA questioned the use of the preamble of the August 7, 1980, Federal Register to support the United States Environmental Protection Agency's (USEPA) February 2, 1995, determination that the two Color Communication buildings are considered one source. Webster's dictionary defines adjacent as close to or nearby. USEPA considers the one city block distance between buildings to be nearby and therefore adjacent. This has been USEPA's national position for 15 years. To make an exception would violate the federal position.

Until further evidence to prove that the two buildings are not adjacent is furnished, USEPA does not think that it is appropriate to reconsider the February 2, 1995, determination.

As always, we are available to assist you in permitting this source. If you have any questions in regards to this letter, please contact Genevieve Nearmyer at (312) 353-4761.

Sincerely yours,


Cheryl Newton, Chief
Permits and Grants Section

cc: Robb Layman
Division of Legal Counsel
Illinois Environmental Protection Agency