Comment on Air Quality State Implementation Plans; Approvals and Promulgations: Idaho; 

Reclassification as Serious Nonattainment for the 2006 Fine Particulate Matter Standards. 

Dear Jeff Hunt of the Environmental Protection Agency,

I am in support of reclassification of Franklin County, ID and Logan, UT as areas of 

serious nonattainment in compliance to the 2006 Fine Particulate Matter Standards. As a 

resident, I attest to the fact that it would be beneficial for our counties to be designated as an 

area of serious nonattainment, in order for change to occur. Furthermore, to be granted a two 

year extension on our moderate nonattainment status would be detrimental to the purpose of 

this 10 year evaluation across all districts involved. Also, it is in the best interest of the EPA to 

continue accepting notice and comment on granting the two year extension on Franklin County, 

ID and Logan, UT so our district members can continue giving advice and opinions. My 

assertions on the two year extension are based on the low volume of comments made on this 

proposed rule in comparison to our areas combined populations and the state of our compliance 

to the 2006 Fine Particulate Matter Standards. Despite all local efforts, our areas have made no 

significant progress in meeting AQI Pm2.5 acceptable pollution standards. 

The Utah air quality reports for the Pm2.5 24-hour standard, based on 98th percentile by 

year and site, measured in units ug/m3, calculated in three year block averages, and compared 

to 35 ug/m3 (pollution concentration standard for increased human risk laid out by the 2006 Fine 

Particulate Matter Standards) has been violated in every three year block since 2005 by Logan, 

UT. Not only that, but, the data shows no downward trend in Pm2.5 concentration over that time 

at all. The area of Franklin County, ID and Logan, UT certainly qualifies for serious 

nonattainment status of the 2006 Fine Particulate Matter Standards by not meeting AQI 

standards once over the last ten years. 

In fact, Logan, UT and Franklin County, ID made the EPA’s top ten cities most polluted 

by short term particulate pollution list in this year, 2015. The inability to fix our particulate 

pollution problem has made us a target city for studying air pollution. With the increased 

monitoring and reports that are mandatory within the designation of serious nonattainment 

status, the EPA will be able to gather data on our unique situation in Logan,UT and Franklin 

County, ID. With more data gathered there is bound to be insight into the geography, 

meteorology, environment, and high atmospheric surface pressure that traps particulate 

pollution in our valley. Working closer with the federal government through this process of 

cleaning our air will lead to scientific discoveries of significant importance to areas around the 

world that have similar geographical and meteorological qualities that create pollution prone 

environments. Since Logan, UT and Franklin County, ID are areas prone to Pm2.5 pollution, we 

especially need this federal reclassification for more intensive monitoring and regulation. 

The single largest contributor to Pm2.5 pollution in our valley is motorized vehicles with 

more minor contributions from home heating (wood burning) and industry. Within the severely 

affected counties in Northern Utah and Southern Idaho there were public hearings about 

community sentiment towards a wood burning ban held over the course of this last year, 2015. I 
attended the public hearing in Logan,UT and to say the least, the public was not receptive. I 

arrived to a packed courthouse with large trucks loaded with fuming wood burning stoves 

outside and maneuvered my way through the crowd into the courthouse. Standing squished 

next the room the hearing was taking place in, I watched as community members heckled a 

local elderly woman with a respiratory illness for voicing her concerns with our county's air 

quality with remarks like ,” Go back to California!” and ,”Stay away from big business!”. I don’t 

blame our citizens for being defensive about their continued ability to heat their homes, I just 

think there has to be something done for the high risk citizens in our areas whom are advised to 

stay indoors on red air days or risk health hazards. As of 2014, ~20,473 citizens in Cache 

County, UT were surveyed by the United States Census as being under 5 years old or over 65 

years old, making 17.9% of our population high risk on any day the Pm2.5 concentration rises 

above a yellow air day classification.

Serious nonattainment status by Franklin County, ID and Logan, UT is something we 

qualify for by the EPA’s own definition. Because of our area’s unique situation (culturally and 

ecologically) our new status of serious nonattainment will lend legitimacy to efforts, both local 

and federal, focused on improving air quality. I can only hope change occurs in the near future, 

perhaps if our industry and local government faces federal litigation by 2019 due to continued 

non compliance, our people will finally be able to breathe easy. 

All the best,

James Robert Sears Wirth