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PM2.5 SIP Public Comments and DAQ Staff Responses
Here is a link to DAQ's summary and responses to the comments.
| Rule/Sip Section | Subject of Comment | Commenter | Comment | DAQ Initial, Unofficial/Draft |
| General Comment | Wants 30-day comment period extended. | James Holtkamp, Utah Manufacturer's Association | James Holtkamp, Comment | |
| General Comment | 1-Impose limits on firearms discharge during drought season 2-Clarify point source contribution in accordance with PM2.5 SIP Plan |
David Ashton, Citizen | David Ashton, Comment | |
| General Comment | Enforcing speed limits and reducing the maximum speed limits to 70 mph with achieve a significant reduction in air pollution | Charles Phillips | Charles Phillips Comment | |
| General Comment | Don't impose more regulations on wood-burning stoves in Box Elder County. Instead, focus on agriculture burning and vehicle emission testing. | William L. Rose | William L. Rose Comment | |
| General Comment | Expressed concern for levels of pollution and particulates in Utah and stated that technology exists to reduce them. | Judy Wolf | Judy Wolf Comment | |
| General Comment | Would like to see nuclear power plants replace burning coal. | Katie Birge | Katie Birge Comment | |
| General Comment | More environmental control on Tesoro and other polluters. | Wilma Odell | Wilma Odell Comment | |
| Emission Testing Statutes | Evaluation of Automobile Emissions Testing Statutes. Believes that the State cannot force Cache County to have a vehicle emissions program without the | Don Linton, Chief Deputy Cache County Attorney | Don Linton,s Comment and supporting documentation. | |
| Emission Testing | Opposed Emission testing in Cache County. | M. Lynn Lemon, Cache County | M. Lynn Lemon Comment | |
| Emission Testing | Supports Emission testing in Cache County | Nancy Pitblado, Citizen | Nancy Pitblado, Comment | |
| Emission Testing | Supports Cache County's vehicle sticker proposal | Keith Thompson | Keith Thompson Comments | |
| Emission Testing | Supports emission testing in Cache County and not the county's sticker proposal. | Jean Lown | Jean Lown Comment | |
| Emission Testing | Supports a self-selective emission test. | Hisako Kure | Hisako Kure Comment | |
| Emission Testing | Cache County resolution that the Air Quality Board include a Yellow/Red Air Day Emission Testing Program in the Cache County SIP. | Cache County Council | Resolution | |
| Emission Testing | Cache County Council approved servarl control strategies as alteernatives to a mandatory vehicle emission program. | Cache County Council | Cache County Council Comments | |
| Public Hearing Comments | October 15 Cache County Hearing | Commenters | Hearing Statements | |
| Public Hearing Comments | October 16 Utah County Hearing | Commenters | Hearing Statements | |
| Public Hearing Comments | October 17 SLC 2:00 PM Hearing | Commenters | Hearing Statements | |
| Public Hearing Comments | October 17 SLC 6:00 PM Hearing | Robert Ingersoll, ATK Launch Systems | Robert Ingersoll Comment | |
| PM 2.5 SIP Section IX Part A | The impact from small rocket motor tests from the ATK's small rocket motor static tests on UDAQ monitor locations and county borders in the Salt Lake City PM2.5 NAA are insignificant. | George Wilkerson, Meteorological Solutions, Inc. | George Wilkerson Comment | |
| PM 2.5 SIP Section IX Part A | IX.A.23. Pepperidge Farms is listed as a stationary point source. Their emissions have been lowered, and should no longer be considered a point source. | Craig Zavilla, Manager, Pepperidge Farms | Craig Zavilla Comments | |
| PM 2.5 SIP Section IX Part A | IX.A.23. Pepperidge farm is no longer a stationary source. Requests a correction to Page 53 Table 6.3 to reflect this
(Comment 8) |
Vic Mahoney, Plant Manager | Vic Mahoney, Comment | |
| PM 2.5 SIP Section IX Part A | IX.A.23. Supports the proposed vehicle emission testing program in Cache County. | Bryan Dixon | Bryan Dixon Comments | |
| PM 2.5 SIP Section IX Part A | IX.A.21. It is important to work with the revised GOPB population projections. | Wasatch Front Regional Council | Wasatch Front Regional Council Comments | |
| PM 2.5 SIP Section IX Part A | IX.A.21, 22, and 23. Strongly support the recommendations of diesel exhaust clean up, requiring RACT controls on additional stationary point sources and requiring Lo-Nox burners on existing boilers and furnaces | W. Glenn Lanham, American Lung Association | W. Glenn Lanham, Comments | |
| PM 2.5 SIP Section IX Part A | Corrections to PartH.13.a | Steve Zohner, BYU | Steve Zohner, Comments | |
| PM 2.5 SIP Section IX Part A | Several recommended changes to Part H. | John Krogue, Chevron Products Company | John Krogue Comment | |
| PM2.5 SIP | EPA's comments | EPA Region 8 | EPA Comments | |
| PM2.5 SIP | Recommended changes to the TSD and to IX.H.12.q | The Procter & Gamble Paper Products Company | Procter & Gamble Comments | |
| PM2.5 SIP | Raises several questions about the proposed SIP, including questions on the compliance schedule, a lack of proposed methods to reduce pollution, and insufficient enforcement mechanisms. | Joel Ban, Ban Law Office | Joel Ban Comments | |
| PM2.5 SIP | Comments on Section IX and H of the proposed SIP | Michael S. Astin, Environmental Manager, Holly Refining | Michael S. Astin Comments | |
| PM2.5 SIP | Believes the proposed SIP falls short of what is required to keep PM2.5 at acceptable levels throughout the state. | Kristin Urry, LCSW | Kristin Urry Comments | |
| PM2.5 SIP | Expresses support for the proposed PM2.5 SIP | Irene Rizza, Utah Clean Cities Coalition | Irene Rizza Comment | |
| PM2.5 SIP | Believes DAQ should require more pollution reductions from point sources. Also gives several recommendations to improve the proposed SIP. | Terry Marasco | Terry Marasco Comments | |
| PM2.5 SIP | Makes several recommendations to improve the SIP. | Jean Arnold | Jean Arnold Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Alalia berry, University of Utah | Alalia Berry Comments | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Suzanne Jensen | Suzanne Jensen Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Marian Nelson | Marian Nelson Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Dale Angell | Dale Angell Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Tyler Yeates, MD | Tyler Yeates Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Sarah Woolsey, MD | Sarah Woolsey Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Scott Morgan | Scott Morgan Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Pam Smith | Pam Smith Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Richard Kanner | Richard Kanner Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Susan Stewart and Richard Keene | Susan Stewart Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Robert Bond, MD | Robert Bond Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | John Prehn | John Prehn Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Tom Stephens | Tom Stephens Comment | |
| PM2.5 SIP | Makes several recommendations to improve air quality in Utah. | Richard Steiner | Richard Steiner Comment | |
| PM2.5 SIP | A set of general comments which they hope will facilitate the comment review and response process by DAQ. | Utah Manufacturers Association, Utah Mining Association, and the Utah Petroleum Association | Association Comments | |
| PM2.5 SIP | The PM2.5 SIP should have more restrictions on big industry, and Trax should be free on red air days. | Raphael Cordary | Raphael Cordary Comment | |
| PM2.5 SIP | 1-Wood burning doesn't make sense when there are other , less polluting wasy to heat a home. 2-The burning of fields is outdated and dangerous and should be discontinued. |
Gwen Lee | Gwen Lee Comment | |
| PM2.5 SIP | The SIP should address the issue of increased pollution from the oil refineries. | Scott N. Hurst | Scott N. Hurst Comment | |
| PM2.5 SIP | Believes the proposed SIP is inadequate to improve air pollution in Utah. Gives some suggestions for improving air quality in the state. | Lorinda LeFevre | Lorinda LeFevre Comment | |
| PM2.5 SIP | IX.H. 12 and 13 - Suggests clarifying language to the sections. IX.A.21 - Supports the notion that although the offset ratio may change in the future, the SIP does not reduce or impact any of the existing banked emission credits. |
William Lawson, PacifiCorp Energy | William Lawson Comments | |
| PM 2.5 SIP | Several recommended suggestions and corrections to IX.h and IX.A of the proposed SIP. R307-101-2. Request to extend the 30-day public comment period. |
Lee Peacock, Utah Petroleum Association | Lee Peacock Comment | |
| PM 2.5 SIP | Supports comments submitted by Lee Peacock and James Holtkamp. | Jerry Lockie, Silver Eagle | Jerry Lockie Comments | |
| PM2.5 SIP | Expresses appreciation support for UDAQ efforts on developing the SIP. | Mayor Corroon and the Salt Lake Valley Health Department | Their Comments | |
| PM2.5 SIP | 1. Kennecott's principal operations have a minor impact on Salt Lake Valley airshed. 2. Some of the emission date in the modeling analysis is inaccurate. 3. Incomplete information to assess how the SIP will address new source growth to existing sources. |
Chris Kaiser, Rio Tinto | Chris Kaiser Comments | |
| PM2.5 SIP | Recommendations and corrections to parts IX.H.12, IX.A.21, Table 6.3, and Section 5.c.iii of the TSD. | Big West Oil | Big West Oil Comment | |
| PM2.5 SIP | Point source emissions in Utah County are extremely low compared to other sources. | Steven Zohner | Steven Zohner comment | |
| PM2.5 SIP | Use fines to increase UTA ridership and fine trucks that idle. | George Chapman | George Chapman Comment | |
| PM2.5 SIP | Comments on Section IX.A, IX.H, and the TSD of the PM2.5 SIP. | Matthew Buell, Tesoro | Matthew Buell comments | |
| PM2.5 SIP | Wants to see more controls on commercial cooking establishments in Utah County. | Don Jarvis, Provo City Sustainability and Natural Resources Committee | Don Jarvis Comment | |
| PM2.5 SIP | The SIP should include a comprehensive program that includes major expansion of public transportation systems. | Sarah Fields | Sarah Fields Comments | |
| PM 2.5 SIP | 1. Requests extension of public comment period. 2. The plan lacks sufficient measures regarding mobile transportation pollution. 3. Not enough enforcement planning included in the SIP. |
Maura Hahnenberger, University of Utah | Maura Hahnenberger Comment | |
| PM2.5 SIP | Wants to see more controls required on large point sources. | Christopher Thomas, HEAL Utah | Christopher Thomas Comments | |
| PM2.5 SIP | The proposed SIP does not meet the standards required by the Clean Air Act. | Great Salt Lake Audobon | GSLA Comments | |
| PM2.5 SIP | It seems some state approvals are contradictory to the goals of the PM2.5 SIP. | James Mouritsen | James Mouritsen Comments | |
| PM2.5 SIP | Raises several concerns about the proposed SIP | Joro Walker, UPHE | Joro Walker Comments | |
| Technical Support Document | Asks DAQ staff to work with all sources to verify model input is accurate. | Chris Kaiser, Rio Tinto Kennecott Utah Copper | Chris Kaiser Comment | |
| Technical Support Document | Requests updates to the 2012 RACT analysis (Comment 7). |
Vic Mahoney, Pepperidge Farm | Vic Mahoney Comment | |
| Technical Support Document | Recommended changes to the TSD. | John Finlinson, IPSC | John Finlinson Comment | |
| Technical Support Document | RACT/RACM analysis is lacking. | Kathy Van Dame, Wasatch Clean Air Coalition | Kathy Van Dame Comment | |
| R307-101-2. | Asks for clarification on the proposed new definitions. | Michael Tomko, Parsons Behle & Latimer | Michael Tomko Comment | |
| R307-307. Road Sand and Salting. | Change the word "sand" to "abrasives" | Lynn Bernhard, Utah Department of Transportation. | Lynn Bernhard Comment | |
| R307-307. Road Sand and Salting. | In the interest of public safety, UDOT needs to apply crushed slag on certain roads, and is requesting an exemption for those roads. | Lloyd R. Neeley, UDOT | Lloyd R. Neeley Comments | |
| R307-307. Road Sand and Salting. | Does the language of the rule already allow the use of traction aides that do not have a significant component of fine particulates? | Lloyd R. Neeley, UDOT | Lloyd R. Neeley Comments | |
| R307-311. Emission Standards for PM2.5 Nonattainment Areas. | Nonsubstantive Change Recommendation. | Hunter Finch, Governor's Office of Planning and Budget | Hunter Finch Comment | We agree that the reference "172(c)(1) in R307-311-1 is incomplete. Language will be added to clarify that the reference comes from the Clean Air Act. Part H.11 cannot be found in the SIP as it is not there yet. It was proposed for public comment at the same time this rule was proposed. |
| R307-312. Aggregate Processing Operations for PM2.5 Nonattainment Areas | 1-only include PM2.5 Nonattainment area for rule applicability. 2-Opacity test method is too stringent. |
Richard Thorn, President/CEO of Associated General Contractors | Richard Thorn Comment | |
| R307-312. Aggregate Processing Operations for PM2.5 Nonattainment Areas | 1-only include PM2.5 Nonattainment area for rule applicability. 2-Opacity test method is too stringent. |
Larry Jardine, Executive Vice President/CEO Legrand Johnson Construction Co. | Larry Jardine Comment | |
| R307-312. Aggregate Processing Operations for PM2.5 Nonattainment Areas | 1-only include PM2.5 Nonattainment area for rule applicability. 2-Opacity test method is too stringent. |
John Burgraf, Lakeview Rock Products | John Burgraf Comment | |
| R307-312. Aggregate Processing Operations for PM2.5 Nonattainment Areas | 1-only include PM2.5 nonattainment area for rule applicability. 2-Opacity test method is too stringent. |
Patrick Clark, Staker Parson Companies | Patrick Clark Comment | |
| R307-312. Aggregate Processing Operationg for PM2.5 Nonattainment Areas | Suggested change to the opacity reading requirement. | Paul Glauser, | Paul Glauser Comment | |
| R307-334.Emission Standards: Baking Ovens | Controlling VOC emissions at bakeries will not significantly impact PM2.5 concentrations, and the rule is not economically feasible. | Joe Robinson, Earthgrains Baking Companies, Inc. | Joe Robinson Comment | |
| R307-334. Emission Standards: Baking Ovens. | Opposes proposed rule. (comment 1 through 6) | Vic Mahoney, Pepperidge Farm | Vic Mahoney Comment | |
| R307-334. Emission Standards: Baking Ovens. | 1-Questions the real PM2.5 reductions from this rule. 2-Requests rule applicability be increased to least least 50 to 100 tons per year |
Dale Hatch, Rocky Mountain Bread | Dale Hatch Comment | |
| R307-334. Emission Standards: Baking Ovens. | Believes that DAQ did not sufficiently involve Interstate Brands in the rulemaking process; the cost estimtes to comply with the rule are cost-prohibitive; and that Interstate Brands is disproportionally burdened under the rule. | Daniel Davis, Interstate Brands. | Daniel Davis | |
| R307-334. Emissions Standards: Baking Ovens. | Asks for some specific exemptions. | Dale hatch, Rocky Mountain Bread | Dale Hatch Comment 2 | |
| R307-343. Wood Furniture Manufacturing Operations. | Nonsubstantive Change Recommendation. | Hunter Finch, Governor’s Office of Planning and Budget. | Hunter Finch Comment | |
| R307-347. Large Appliance Surface Coatings. | Nonsubstantive Change Recommendation. | Hunter Finch, Governor’s Office of Planning and Budget. | Hunter Finch Comment | |
| R307-348. Magnet Wire Coatings. | Provided several recommended changes to the rule text. | Joseph Martone, Department of the air Force | Joseph Martone Comments | |
| R307-350. Miscellaneous Metal Parts Coatings. | Two definitions in R307-350-4 appear incomplete. | Hunter Finch, Governor’s Office of Planning and Budget. | Hunter Finch Comment | |
| R307-350. Miscellaneous Metal Parts Coatings. | Recommends the removal of Box Elder County from the applicability of the rule. | Aaron Bell, Nucor Products Group | Aaron Bell Comment | |
| R307-350. Miscellaneous Metal Parts Coatings. | Recommends that the surface coating of military munitions be exempt from the scope of the proposed rule. | Robert Ingersol, ATK | Robert Ingerson Comment | |
| R307-350. Miscellaneous Metal Parts Coatings. | It appears this rule and R307-352 both apply to drum coatings. | American Coatings Association | American Coatings Association Comments | |
| R307-350. Miscellaneous Metal Parts Coatings. | The proposed exemption for the "exterior of airplanes" creates a regulatory overlap with the proposed aerospace VOC rule. |
Blake Izatt, Boeing | Blake Izatt comment | |
| R307-350. Miscellaneous Metal Parts Coatings. | Provides several recommended changes to the rule text. | Joseph Martone, Department of the Air Force | Joseph Martone Comment | |
| R307-351. Graphic Arts | Request to remove recordkeeping requirement of R307-351-7 | John Messick, Manager Printing Resource | John Messick Comment | |
| R307-351. Graphic Arts | Believes that the existing regulation does not require modification and should not be expanded to include offset printing operations or revised to address flexible packaging operations. | Printing Industries of Utah | Printing Industries of Utah Comment | |
| R307-352. Coil Coatings | Nonsubstantive Change Recommendation. | Hunter Finch, Governor’s Office of Planning and Budget. | Hunter Finch Comment | |
| R307-352. Coil Coatings. | It appears this rule and R307-350 both apply to drum coatings. | American Coatings Association | American Coatings Association Comments | |
| R307-353. Plastic Part Coatings. | Nonsubstantive Change Recommendations. | Hunter Finch, Governor’s Office of Planning and Budget. | Hunter Finch comment | |
| R307-354. Automotive Refinishing. | Raised several concerns with the proposed rule and asked for a letter stating the additional costs the rule has on the end user. | Bob Pierson, Autobody Paint Supply | Bob Pierson Comments | |
| R307-354. Automotive Refinishing. | Makes several recommended changes for the proposed rule. | Steve Gaver, SEM Products, Inc | Steve Gaver Comments. | |
| R307-354. Automotive Refinishing. | Comments on Applicability, Work Practices and Recordkeeping, and Compliance Schedule sections of the proposed rule. | American Coatings Association (ACA) | ACA Comments | |
| R307-355. Control of Emissions from Aerospace Manufacture and Rework Facilities. | ACA suggests exempting operations that utilize a control device from HVLP spray gun requirements. | American Coatings Association | American Coatings Association Comments | |
| R307-355. Control of Emissions from Aerospace Manufacture and Rework Facilities. | Provided several recommendations and suggested changes in the rule language. | Robert Ingersol, ATK | Robert Ingersol Comments | |
| R307-355. Control of Emissions from Aerospace Manufacture and Rework Facilities. | Provided several recommendations and suggested changes in the rule language. | Blake Izatt, Boeing | Blake Izatt Comment | |
| R307-355. Control of Emissions from Aerospace Manufacture and Rework Facilities. | Provided several recommended changes to the rule text. | Joseph Martone, Department of the Air Force | Joseph Martone Comment |
