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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
Response to Comment

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

Robert Ingerson 2nd 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

 

 

 

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