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         Texas Natural Resource Conservation Commission
                     Interoffice Memorandum

From:  Steve Hagle, P.E.
To:  Permit Engineers               
Date:  June 1, 1994
Subject:  Extension for start of construction in Nonattainment
            Areas

During our May teleconference with EPA Region 6, we were
reminded that the September 3, 1992 transition guidance as it
pertains to permit applications submitted prior to November
15, 1992 has several basic provisions for compliance. 

One of these provisions states that once we issue a permit,
there can be no extensions of the permit expiration date
unless the permittee is required to meet the new Part D New
Source Review provisions.  What this means is that we cannot
grant an extension of the eighteen months to begin
construction for any permit received prior to November 15,
1992 which is located in a current nonattainment area unless
the applicant first demonstrates (through netting if
necessary) that they would not have to get a nonattainment
permit under the current rules.  In addition, we cannot grant
extensions for companies who have started construction, but
have stopped and the break in construction will last longer
than the allowed 18 months.

We believe that this policy was aimed primarily at the
"deadline beaters."  However, we are not sure how this will
affect applications which were received several months prior
to the November 15, 1992 deadline.  If you receive a request
for an extension for any permit in which the original
application was received prior to November 15, 1992 and the
facility is located in a current nonattainment area please
contact Skip Clark, Craig Richardson, Susan Blevins, Tammy
Villarreal, Bruce Humphrey, or Steve Hagle.  We will make a
case-by-case decision on whether to extend these permits,
probably after consulting with EPA Region 6.

If you have any questions, please contact your section's
representative in the group listed above.  Also, please notify
your representative if you know of an extension which has
already been granted which would have at least required
netting under the current nonattainment rules.