Public Comments for Permitting Rules Revisions to LRAPA Titles 12, 14, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 40, 42, 48, 49, 50, 51

The public comments below are only for the LRAPA Permitting rule revisions to LRAPA Titles 12, 14, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 40, 42, 48, 49, 50, 51. Public comments will be accepted from October 1st, 2017 until November 8, 2017. The public is encouraged to comment on the proposed rule amendments. Comments submitted prior to the hearing date must be submitted in writing and must be received by LRAPA by Wednesday, November 8, 2017. Comments submitted at the hearing must be presented orally by the commenter.

Name Organization Zip Code Add. Document Comment  
Ron Saylor Saylor Painting Co. 97402 Ms. Lanier
I looked into the comment form and found the only available topic was open burning. If I missed something, please let me know.
I would like to submit a comment on LRAPA Title 37
Citing comments from the Staff Report, page 14:
7. Adjust industrial and commercial activity levels below which some categories of sources are exempt from permitting and delete an unused category….
LRAPA is asking for comment on the range of de minimis cutoffs for surface coating operations. The range LRAPA is considering is between 100 and 250 gallons per year. Based on 2016 annual reporting information seven (7) sources on Basic ACDPs would qualify to be exempt if the rules specified a 100 gallon/year and 5,000 board feet per shift exemption. If the lower source cutoff were specified at 250 gallon/year and 5,000 board feet per shift, a total of nine (9) sources would qualify to be exempt from permitting. The total reduction in annual fees would be $2,926 and $3,762, respectively, for each option of de minimis cutoffs for surface coating operations….
What need would the proposed rules address?
Some of the sources currently required to have an air permit under the surface coating and woodworking activity categories are very small businesses that generally do not emit significant amounts of regulated pollutants. They often have difficulty paying fees and completing annual reports, etc.
How would the proposed rules address the need?
The rules would address the need by specifying that permit for surface coating activities is only required if actual or projected usage of VOC containing coatings is greater than 100 gallons/year. By comparison, DEQ only requires permits for surface coating operations with usages of more than 250 gallons/month….(emphasis from the Staff Report)
Saylor Painting Company, in Eugene, holds a Basic permit for our in-shop spray facility. In compliance with LRAPA, in March 2017, we reported application of 113 gallons of coatings with contents on the list of 633 reportable chemicals.
• We found 11 chemicals in quantities varying from 0.5 ounce to 3.75 gallons per year, a total of 18 gallons.
• Five of the 11 chemicals were reported in ounces per year.
• It cost us about 40 hours of staff time, valued at $3,000, to discover this (my emphasis).
We see no public or environmental benefit to warrant this substantial cost. We are supportive of the mission of LRAPA and proud of our own environmentally-conscious policies and practices. If LRAPA cannot simply match the DEQ cutoff of 250 gallons/month (3,000 gallons/year), we endorse an updated LRAPA de minimis cutoff of 250 gallons/year (only 12x more stringent) rather than the unnecessarily low end of the range at 100 gallons/year (30x more stringent).
Please convey my comment to the Board and thanks to all for your efforts.
Sincerely,
Ron Saylor, President
Saylor Painting Co.
245 Monroe St.
Eugene, OR 97402
phone: 541-484-6078 / fax: 541-484-6404 / mobile: 541-953-1945
www.saylorpainting.com

 
Rich Angstrom, OCAPA President Oregon Concrete & Aggregate Producers Association 97301 PDF October 27, 2017
Robbye Lanier
Lane Regional Air Protection Agency
1010 Main Street
Springfield, OR 97477 

Dear Robbye Lanier:
Thank you for the opportunity to comment on Lane Regional Air Protection Agency's (LRAPA) rulemaking.
I am the President of Oregon Concrete & Aggregate Producers Association (OCAPA). OCAPA is a 50-year-old state trade association that represents construction materials companies that produce ready mixed concrete, concrete products, aggregate, asphalt, fly ash and cement. Currently, OCAPA represents 140 construction materials and affiliated companies from across the state. Our membership includes entities ranging from small family operations to large corporations.
The primary function of the association is to educate law and policy-makers at local, state and federal levels on issues that involve the construction materials
industry. The organization, and its member-driven committees, follows legislative changes or court decisions into agency rulemaking in order to provide background and perspective as it relates to the construction and construction materials industries. OCAPA comments on many agency rulemakings every year as well as sits on several advisory committees as rules are formulated.
We are an industry involved in mining and processing of aggregate into basic construction materials such as concrete, cement and asphalt. Through our work, we continually seek ways to mitigate any negative environmental impacts of our activities such as fugitive dust. Our industry implements best practices to minimize the environmental impact of our activities in order to ensure the continued livability of the communities in which our members work and live.
After reviewing the proposed rules, OCAPA believes the content of LRAPA's proposed rule is similar to DEQ's current administrative rule adopted in April 2015.
 
Page 2 
Similar to DEQ's rules, LRAPA's proposed rules will improve fugitive dust emissions from our rock and concrete facilities and thereby contribute to improving the air quality in the communities where they operate.
OCAPA continues to be concerned with the proposed requirement that stockpiles be covered to control fugitive dust emissions. For the reasons described below, this requirement is unnecessary, cost prohibitive, and may lead to detrimental results that would otherwise be avoided by using current best practices for dust suppression.
The production of aggregate and concrete creates a certain amount of dust during normal operations. In Oregon, because we generally have a wet climate, dust from our operations needs to be controlled during the dry summer months. Oregon's mostly wet weather is a natural dust suppression agent. It generally dampens fugitive dust from production equipment as well as from haul roads-- just as it does for agricultural or forest operations. Dust issues for our industry are seasonal in nature, and therefore generally need to be controlled only during the summer months or in dry climates.
Industry best management practices for dust control include use of water, vegetative cover, buffer areas and limiting the drop height of loading equipment and stockpiles. These are all effective, reasonable cost alternatives to mitigate fugitive dust. Use of water, or other dust suppression agents such as vegetable oil, is the primary and the most effective means of controlling dust around our aggregate and concrete production operations. A sprinkler on stockpiles and watering of any gravel operating areas during summer months mitigates fugitive dust. This is well researched and the primary method and best management practice for controlling fugitive dust from stockpiles and roads. It is also the most common condition imposed on aggregate and concrete operations by local governments, DOGAMI, and other agencies.
During aggregate production, material is separated into a variety of uses such as concrete sand, pea gravel, drain rock, road base, asphalt rock or other aggregate use materials. Larger aggregate from alluvial sites, as well as quarry rock, is often crushed into products such as asphalt rock, base rock or material for chip seal. Sand may be classified into a number of products, including concrete sand, mason sand, and sand used for ·water filters. Each of these, and a dozen more products, will have its own stockpile. Aggregate processing yards often have a dozen or more stockpiles spread out over several acres. Many of the individual stockpiles may be over 2 or 3 acres in size because processing hour limitations necessitate building large inventoried stockpiles to meet demand during the construction season. The cost of covering these multiple products either through the construction of buildings or tarping over the many acres of aggregate production would be infeasible and impractical.

Page 3 
Moreover, many of the aggregate products simply do not create fugitive dust. For instance, concrete aggregates, cobble rock, pea gravel, and drain rock do not have fines that create fugitive dust. Requiring uniform treatment of aggregate products avoids the reality that many of the products we produce do not generate dust. Further, many concrete and road base aggregates must be kept wet as a part of their performance requirements in subsequent use.
OCAPA members are concerned that covering stockpiles with tarps, as an example, would create unnecessary hazards for workers trying to drag or hoist tarps over tall and unstable stockpiles.
Members also emphasize that wheel loaders and other loading equipment would constantly have to remove the tarping and replace it as they were using or removing aggregates from the various stockpiles. This would increase loading time and production expenses, and generate dust that would otherwise be mitigated by sprinkling the piles with water.
The concrete and aggregate industry believes that fugitive dust can be, and is, effectively controlled through the use of water, wetting agents, spray bars and sprinklers, buffer areas, and vegetation. These are the current best management practices in the industry that balance cost, worker safety and environmental considerations such as fugitive dust emissions.
OCAPA respectfully requests that the requirement to include covering stockpiles be removed from the proposed rules and be replaced with a general requirement to mitigate dust using generally accepted industry practices. It should be the outcome that we value, not the method.
Thank you for your consideration. Please feel free to call me at 503-931-4323 if you have any further questions.

Respectfully,
Rich Angstrom
OCAPA President
 
Laura Allen - - PDF Dear Lane Regional Air Protection Agency, I am writing to ask you to keep existing protections and limits on GHG emissions, and not remove any of them. In addition, the City of Eugene has strong climate recovery goals and LRAPA should be a partner agency in meeting those goals. The City of Eugene is preparing to update its Climate and Energy Action plan to reduce GHG emissions and LRAPA is one of the potential partners the City hopes will help it meet its goals. As such, reducing current requirements would set these efforts back. Lastly, the State of Oregon is considering a Cap and Invest program that would raise funds from large GHG emitters and reinvest it in clean technology. Maintaining policies that limit GHG emissions will help Lane County businesses get out ahead of this type of future regulation. Thank you for your work keeping the air clean in Lane County. Sincerely, Laura Allen  
James Neu 350.EUG 97404 PDF LRAPA Commissioners, Thank you for the opportunity to express my concerns about a proposed reduction to current New Source Review requirements. The City of Eugene has a strong climate recovery goal and has set benchmarks to reduce community wide carbon dioxide levels 50% below 2010 levels by 2030 and a 7.6% greenhouse gas reduction per year effective immediately. The City of Eugene is one of very few cities that has adopted such a strong ordinance because the mayor and council understand the urgency to commit to a reduction in fossil fuel useage and commit to 100% renewable energy. Part of this commitment was to update the city's Climate Energy Action Plan. This update was recently completed and will require large lever shareholders such as LRAPA and other prominent organizations to take an active leadership roll in reaching the community wide carbon dioxide reduction benchmark. LRAPA's proposal to reduce current New Source Review requirements would set these efforts back. Maintaining policies that limit greenhouse gas emissions will help Lane County businesses get ahead of this type of future regulation. The State of Oregon is considering a cap and trade invest program that would raise funds from large GHG emitters and invest it in clean technology. I urge you to reconsider reducing the New Source Review requirements. Thank you, James Neu Eugene 97404  
Lisa Arkin Beyond Toxics   PDF See attached PDF  
Lon Otterby Chair Many Rivers Group Oregon Sierra Club 97454 PDF Dear LRAPA Board, I am speaking for the 3300 members of the Many Rivers Group of the Oregon Sierra Club representing Coos, Douglas, and Lane Counties. As you all know that the Oakridge area of the MIddle Fork of the Willamette Rivers has always had problems with stagnet and still air. We have seen restriction on burning fire wood for heat in the homes of the area restricted because of PM2.5 in the air. We believe that this is not a good time to relax restrictions and rules for this are because that would endanger the public health of this small rural community. Thanks you for not acting to relax the important rules that are inplace to protect the members of this community. Lon Otterby Chair Many Rivers Group Oregon Sierra Club 93995 Marcola Road Marcola, CA 97454   
Zach Mulholland 350 Eugene 97402 PDF Hello, A few quick comments on LRAPA's plan to remove rules regulating GHG emissions. -LRAPA should be placing additional limits on GHG emissions, not removing them. Specifically, LRAPA should maintain the current GHG emission rules requiring Best Available Control Technology for facilities emitting more than 100,000 tons of CO2e and strengthen this rule over time, with the limit slowly coming down to 25,000 tons -The City of Eugene has strong climate recovery goals and LRAPA should be a partner agency in meeting those goals. The City of Eugene is preparing to update its Climate and Energy Action plan to reduce GHG emissions and LRAPA is one of the potential partners the City hopes will help it meet its goals. As such, reducing current requirements would set these efforts back. -The State of Oregon is considering a Cap and Invest program that would raise funds from large GHG emitters and reinvest it in clean technology. Maintaining policies that limit GHG emissions will help Lane County businesses get out ahead of this type of future regulation. Thank you, Zach Mulholland 541-419-4041  
Parry Pierce       From: parry pierce <parrypierce@gmail.com>
Sent: Thursday, December 28, 2017 10:43
To: Robbye Lanier
Subject: Air quality in Oakridge
I don't understand why LRAPA cannot weigh in on the effects of the proposed new rock Quarry on TV Butte just east of Oakridge. This blasting and trucks will be adding to air quality problems for the citizens of Oakridge.

 
Trudy Hammond      
From: Trudy Hammond <tntlc@outlook.com>
Sent: Friday, December 29, 2017 05:17
To: Robbye Lanier
Subject: Wood stove enhancement program for Oakridge
Hello, my name is Trudy Hammond. I live in a house that has a certified wood stove. I am disabled and survive with a low social security income and disability limitations that complicate sustainability if resources are wasted. Though I have a certified woodstove and enjoy it I hope to buy a home this year and desire an efficient heating source without the use of wood. I wasted money in paying for firewood permits I was not able to complete the task of cutting, loading, and delivering myself. As well as the expiration of the permits while attempting to find laborers to complete the task for me and my also disabled housemate. We were cheated with the purchase of firewood by not receiving a full cord, the guy never produced his permits or returned like the second guy did. The 2nd guy who provided his permits said he had hard wood but the content was about ten small limb rounds of maple & madrone and the other wood was so bug infested we took a torch to some of it before we brought it in. These are issues to help persuade people to switch to other methods of heating sources. Issues that when paying from $150.00 to $220.00 for a cord of firewood and depending on the severity of the winter going through two to three cords if not hardwood, gets expensive. And the fact energy assistance does not kick in until February usually, sometimes March.
I have had a person at my door with a report of my location being called in for excessive smoke, it was a neighbor in actuality and not my chimney. Again, smoke from the neighboring trailer park. Others are burning items that shouldn’t be burnt. I had even called into the fire department at one time from the neighboring trailer park while delivering food there.
In Oakridge Mobile Home Park (neighboring trailer park) I am aware of water waste (running sprinklers on roof tops during summer time, people spraying off roadway as opposed to sweeping rocks away) to the point where St Vincent de Paul had increased the rent to cover some of the cost of an estimated $3,000 monthly water bill. Currently the park is under new management and maybe this manager will pay more attention to the smoke from chimney’s of those who load the stove, close the damper down to conserve their wood pile and have done so for “ forty G** damn years” and don’t think they need to change either for “anyone” or any reason. This is what I was told as I had approached space A24 about his smoke density.
I’m not sure if anything I have said has been of any benefit or only made myself sound like a fool. Our forests are in need of preservation considering the wildfires all over our West Coast have taken a toll on wildlife and the timber industry. Air quality is the oxygen we struggle to maintain in a stagnant “world” of toxic pollutants (so much larger than just our area). Without our trees filtering us, Oakridge being the fish bowl town it is, We shall gasp our last breath with words echoing … “I told you so” if no attempt of change is not pursued.
It would be a great incentive for those who participate to get firewood in partnership, when there are trees downed on Hwy 58 to be designated to Oakridge residents. That wood could be stored at the Oakridge Public works off Hwy 58 (in Oakridge) where it could season, be inventoried, and registered to be assigned to residents on a waiting list. Hwy 58 is a long stretch of highway and in the year 2016/17 there were an estimated 5 to 7 tree falls across 58 that were large enough to block traffic. Even at $100.00 per cord discount to pay…it could fund the code enforcement officer here in Oakridge to specifically patrol during season.
Just my input from the facebook invitation. Thank you for reading. If I can be at assistance I am here.
tntlc@outlook.com<mailto:tntlc@outlook.com>
Trudy Hammond

 
Diana Gerding      
From: Diana Gerding <bigmamma236@hotmail.com>
Sent: Friday, December 29, 2017 08:59
To: Robbye Lanier
Subject: Air Quality in Oakridge LRAPA to designate the town a ‘reattainment area’
Hello,
I have lived in Oakridge now a total of 20 years. I have commented to LRAPA via phone and email in the past about the HORRIBLE pollution we have here. Mostly in the winter time via “old wood stoves” or “people burning green/wet wood”. We do have problems in the summer when there are wild fires, but not much can be done about that issue. Any “backyard” burning should be banned year around I feel, the “smoke” just “hangs” here in this valley.
Having grown up as an Army Brat I have lived many places and this is the WORSE air wise that I have ever lived in. And most “old timers” don’t give a darn about hearing about “air quality” here in Oakridge. They LOVE LOVE their wood heat at all cost!!
Having said this, I do not want to give ANY industry coming to Oakridge “free rein” to send “who knows what” into the air here in exchange for new wood stoves. You NEED to FINE Oakridge so they understand how important it is for people to put in new wood stoves into their homes. Money(via fines) is the ONLY way the city will understand how important this issue is. Same with most of the population of Oakridge.
Thank you for your time,
Diana Gerding
Oakridge, OR
Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows 10

 
Linda McMahon      
From: Linda McMahon <savetvbutte@gmail.com>
Sent: Friday, December 29, 2017 13:35
To: Robbye Lanier
Subject: Public comment
This is comment to the proposal to change the Oakridge Oregon lrapa regulation. Do not do this to Oakridge. My comment is do not change the regulations to favor industrial pollution. Use other ways to have attainment in Oakridge. This is NOT an ideal for the people that pay your salaries. Listen to us not industry.
Sent from my iPhone

 
Linda McMahon       From: la kmcm <lkmcmahon30@gmail.com>
Sent: Friday, December 29, 2017 16:28
To: Robbye Lanier
Subject: comment
The proposed changed to lrapa regulations regarding Oakridge Oregon attainment, is not a good thing for Oakridge. Why would you give a small industry a "pass" and leave the people who are just trying to keep warm in the cold. There are many ways to reduce the particulate matter in Oakridge with out doing this. How about insulation in homes, I have live in Oak;ridge for 65 years and a properly insulated house could keep warm with space heaters. Go for grants that help replace the woodstoves in place, how about electric vehicles? The idea of having "small industry" having stacks above the inversion, is a crazy idea, that would have to be at least 2000' tall and I know it would not break the winter inversion. Our town's revenue is based on recreation and tourism, having an eyesore, Do NOT change the regulations, and give industry the profit on people that are trying to live in a small town. We do not need this kind of change from lrapa.
This is a BAD idea and I can't believe this is not in response to the proposed quarry in the area. Why now?
Linda McMahon

 
Michael T Williams       From: Michael T Williams <mtwilliams@nu-world.com>
Sent: Friday, December 29, 2017 16:53
To: Robbye Lanier
Subject: Oakridge Air Quality
Regarding the so-called, “reattainment” issue applying to the Oakridge area: I suggest LRAPA demonstrate Oakridge is in “attainment”. Subsequently, LRAPA can produce a maintenance plan showing continuing “attainment”.
I have been frequenting the Oakridge area, year around, for more than 50 years.
Michael T Williams
www.mtwilliamsflyfish.com