Official Comments for Government Agencies

UPHE strongly objects to the Trump EPA’s proposed abandonment of the Obama plan for new improved fuel efficiency standards for vehicles.  You cam find our comments here, posted Oct. 2017.

UPHE SIGNATORY ON LETTER TO EPA/HHS ON PREVENTING CHILDHOOD LEAD EXPOSURE, October 2016. UPHE is a co-signatory in a call to action letter to the Environmental Protection Agency and Dept of Health and Human Services that asks for a federal strategy to prevent childhood lead exposure.  The letter may be found here.

COMMENTS TO THE EPA ON THE REGIONAL HAZE RULE, Aug. 10, 2016.  UPHE opposes allowing states any further delay in installing pollution controls.  Any further delay means public health is needlessly and inexcusably left unprotected.  Our comments can be found here.

COMMENTS TO THE BLM ON THE PROPOSED MONUMENT BUTTE DRILLING PROJECT IN THE UINTA BASIN.  Aug. 8, 2016

UPHE has called attention to severe pollution already in the Uinta Basin from the 11,500 oil and gas wells already drilled in the area.  The BLM is proposing to allow Newfield Oil to drill another 5,750 wells in the same area.  A 2013 study revealed VOC levels comparable to what would be expected from 100 million cars.  This is nothing less than a pollution nightmare.  It would be unconscionable to allow those pollution levels get even worse.   Our comments can be found here.

COMMENTS TO BLM ON REFORMING THEIR DEEPLY FLAWED COAL LEASING PROGRAM, July 23, 2016

For an expanded, public review of the federal coal leasing program UPHE submitted extensive, heavily researched comments.   We consider the current federal coal leasing program a highly inappropriate subsidy for coal companies, a serious undermining of Obama’s climate initiative, and a major contributor to poor public health outcomes.  Our comments can be found here.

COMMENTS TO BLM ON ENEFIT CORRIDOR, June 2016

The BLM sent out to comment, their proposal to allow an Estonian state company the rights to develop a utility corridor through BLM land.  Approval would be critical to this ill conceived project that would open up Eastern Utah to full scale oil shale production.  If allowed, this would double the production of oil from the Uinta Basin.  UPHE adamantly opposes this because of the pollution, water consumption and climate consequences.  Our comments in opposition can be found here.

COMMENTS TO EPA CHALLENGING THE UTAH DAQ’S SIP ON CONTROLLING REGIONAL HAZE, 2016

Utah DAQ’s proposed plan to reduce regional haze did not require any new pollution controls from our major power plants.  We think that’s naked capitulation to Rocky Mountain Power.  DAQ had claimed that the NOx from these plants only contributed to haze in the winter, when there weren’t many tourists visiting our parks.  We found out that the information they used to claim that there weren’t many visitors to our parks in the winter was in fact 12 years old.   There is plenty of evidence to suggest that is no longer true.  And there are a myriad of other reasons to control NOx from our major power plants.  We hope the EPA listens.  You may read our extensive comments here.

COMMENTS TO UTAH PUBLIC SERVICE COMMISSION ON PACIFICORP’S 2015 INTEGRATED RESOURCE MANAGEMENT PLAN

Having been granted the privilege to operate as a monopoly, PacifiCorp incurs the obligation to operate not just in the short-term interest of its investors, but in the long-term interests of its customers and of society at large.   By clinging to a fleet of coal power plants as their dominant source of power, it is the interests of society at large that have been badly overlooked in PacifiCorp’s 2015 integrated resource plan.  In blatantly ignoring the public health and climate consequences of the emissions of these plants, Pacificorp’s plan is woefully inadequate, if not outright illegal.  UPHE’s comments can be found here:

COMMENTS ON FEDERAL COAL LEASING REFORM

UPHE considers the current federal coal leasing program a highly inappropriate subsidy for coal companies, a serious undermining of Obama’s climate initiative, and a major contributor to poor public health outcomes.  We submitted these written comments to the BLM on May 8, 2015.  Two UPHE members testified in person at the BLM hearing in Salt Lake City, May 19, 2016.

WASATCH FRONT MOUNTAIN ACCORD

UPHE believes that the interests of the ski resorts and real estate developers should not be given the same priority as more important considerations like aesthetic preservation, water shed protection, and other recreational uses that attract a much larger constituency, i.e. outdoor summer hiking.  We oppose linking the ski resorts for that reason, and we oppose mountain transportation projects that would be far more expensive than mass transit projects in the valley that would yield a much “bigger bang for the buck.” Our comments to the Mountain Accord can be found here.

REGIONAL HAZE

UPHE believes that DAQ’s proposed amendments to the regional haze SIP serve only the profitability interests of Pacific Corp. the primary owner of Utah’s coal power plants, and not the long term interests of Utah’s residents.  UPHE submitted these comments to Utah DAQ on their regional haze SIP proposal, May 1. 2015

OZONE

We believe that EPA should adopt the strictest ozone rule possible, at least no higher than 60 ppb.  UPHE Comments on ozone rulemaking PDF March 17, 2015

OBAMA CLEAN POWER PLAN

We support Obama’s clean power plan.  UPHE submitted these extensive comments to the EPA on Dec. 1, 2014 on the proposal.

EPA CARBON RULE

We support EPA’s carbon rule.  Our details comments are available here.

EPA RULE ON WOOD BURNING APPLIANCES

We urge EPA to adopt much stricter standards for wood burning appliances.   UPHE comments to the EPA on rule making for wood burning appliances.

ROCKY MOUNTAIN POWER’S ATTEMPT TO CHARGE SOLAR CUSTOMERS INCREASED FEES

UPHE vigorously opposes this attempt by Rocky Mountain Power.  Our detailed comments, May 22, 2014,  are available here.

PERMIT FOR A NEW ASPHALT PLANT IN PETALUMA, CALIF.

UPHE has supported the effort by residents of Petaluma, Calif. to block the building of a huge asphalt plant in the middle of their community.  You can read our comments to the Army Corps of Engineers here on why they should require a complete EIS before granting that permit.

 

 

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