Background: In late 2013, the state released its plan to control PM2.5. At this time the EPA and many environmental groups offered suggestions for ways to improve this State Implementation Plan, or SIP. In the second SIP, which was released in fall of 2014, the state incorporated a few recommendations, but not all. UPHE, HEAL Utah, and Western Resource Advocates have taken those EPA recommendations and added our own suggstions to make we believe will be measurable difference in our emissions from big industry!
Rule #1. Prevent Emissions Spikes – Utah currently violates the nation’s 24-hour standard for PM2.5 pollution: In other words, we have too many days when our fine particle pollution reaches unhealthy levels. So, logically, our policies need to focus on limiting excess pollution on any given day. However, our permits for industrial polluters typically restrict how much air pollution can be released in a week, or a month, or in some cases – a whole year! Thus, our first proposed rule would force big industry to comply with a 24-hour emissions standard – ensuring their pollution doesn’t spike on a bad air day.
Rule #2. Close “Offset” Loophole – Because Utah does violate federal PM2.5 standards, big industry cannot increase their emissions unless they find a reduction elsewhere in their operations — or from another polluter. Those reductions are called “offsets.” The purpose of the rule is to maintain valley-wide pollution levels, even if a facility expands. However, in Utah, we only require offsets if the increase is pretty high. And so, unfortunately, a polluter can propose numerous “minor” expansions, and even if they add up, industry doesn’t have to find cuts elsewhere. Our rule, simply, halves the levels at which a proposed increase would trigger the offset requirement, making it more difficult for a big polluter to increase emissions.
Rule #3. Boost Testing Frequency. A plan for limiting pollution only works if you can verify its being met. And so you need tests! Those “stack tests” have to be performed often enough so officials and the public have faith that industry is not exceeding permit limits. In Utah, however, such tests are sometimes required as infrequently as once every three to five years. Our rule would first require an improving technology called “continuous monitoring,” unless a facility can prove it’s just not feasible or necessary. Then, however, they’d have to start testing at least once a year.
Rule #4. Improve Air Quality Participation – This rule is the most straightforward, with two simple parts. First, it requires that technical documents are made available at the start of the comment period. Second, it extends length of comment period for intents to approve or draft permits.
What you can do: Send an email to Utah Division of Air Quality Director, Bryce Bird, at firstname.lastname@example.org. State that you would like to see the Air Quality Board formally consider these rules with a public hearing and a period of public comment in order for the public to weigh in this proposal.