hswriter@frontiernet.net to: R9AirPermits 11/09/2013 03:35 PM

Cc:

Bob Atwood, "bwalker@co.shasta.ca.us", Kara Christenson, Celeste, 

"marily-lobo@hotmail.com", Deborah Jordan, Omer Shalev, 

"rob@redwoodrob.com", "thebiomassmonitor@gmail.com", 

From: "hswriter@frontiernet.net" <hswriter@frontiernet.net>

To: R9AirPermits@EPA, 

Cc: Bob Atwood <bobatwood60@gmail.com>, "bwalker@co.shasta.ca.us" 

<bwalker@co.shasta.ca.us>, Kara Christenson/R9/USEPA/US@MSO365, Celeste 

<mysecretfires@gmail.com>, "marily-lobo@hotmail.com" <marily-lobo@hotmail.com>, Deborah 

Please respond to "hswriter@frontiernet.net" <hswriter@frontiernet.net>

History: This message has been forwarded.

November 9th, 2013

Shaheerah Kelly

U.S. Environmental Protection Agency, Region 

9 (AIR-3) 

75 Hawthorne Street San Francisco, CA 

94105-3901 

(415) 947-4156 R9airpermits@epa.gov

Dear Shaheerah Kelly, 

Have you replaced Omar Shalev? 

I received EPA Region 9's public 

notice yesterday regarding Sierra 

Pacific and the "new version" of the 

permit modification (No.SAC 12-01). 

You stated there will be a public 

hearing on December 10th, 2013. 

I am deeply concerned that EPA Region 

9 (Region) is only providing the 

public with 30 days to research, write 

and submit written comments on a 

multitude of substantial changes. 

Changes your agency instituted. 

Region alluded to substantial changes 

in the proposed permit in your 

November 8th, 2013 notice. 

A separate legal proceeding regarding EPA’s deferral of 

biogenic carbon dioxide emissions from PSD requirements 

has also influenced the action we are proposing today. On 

July 12, 2013, the Court of Appeals for the Circuit for the 

District of Columbia issued a decision that will, upon the 

date it becomes final and effective, invalidate EPA’s 

regulation deferring from the PSD requirements the carbon 

dioxide emissions resulting from the combustion of certain 
biological materials, including materials such as wood, 

wood waste, forest residue, and agricultural material. (See 

Ctr. for Biological Diversity v. EPA, 722 F.3d 401 (D.C. 

Cir. 2013).

Today, we are announcing a new version of the permit, 

which addresses emissions of greenhouse gases (GHGs), as 

well as criteria pollutant emissions... 

GHG emission limits and related requirements. We have 

also taken this opportunity to revise certain other 

conditions (primarily related to monitoring, performance 

testing, and recordkeeping) to address minor technical 

issues we identified since February 2013. 

Region's changes to the permit are of 

a substantial magnitude and warrant a 

90 day written comment period after 

the hearing. I am officially 

requesting the written comment period 

be extended to 90 days after the 

December 10th, 2013 public hearing.

I can not help but notice this hearing 

falls in between Thanksgiving and 

Christmas. 

I think it would benefit everyone 

involved to extend the comment period. 

Anderson, located in Shasta County has been officially recognized 

as an Environmental Justice Community by the Environmental 

Appeals Board. The need for a reasonable time to review and 

comment on the the complex proposed changes Region has 

initiated are especially acute in this case. 

KNAUF FIBER GLASS, GMBH PSD Appeal Nos. 98-3 

through 98-20:

Held: Review is granted and AQMD’s permit decision is 

remanded as to the following issues:

•The BACT determination is being remanded to AQMD 

due to an incomplete BACT analysis. Petitioners have 

raised legitimate questions about the particular control 

technology and emission limits for the proposed facility in 

light of alternative pollution control equipment 

configurations at other fiberglass manufacturing facilities. 

The record does not show that AQMD adequately 

considered the comments received on BACT. 

AQMD is to prepare a supplemental BACT analysis that 

identifies multiple pollution control options and provides 
infeasibility analyses as necessary. In preparing the 

supplemental BACT analysis, AQMD need not require 

Knauf to pursue its competitors’ trade secrets, but it must 

consider pollution control designs for other facilities that 

are a matter of public record. (Section II.B.1.)

•The issue regarding environmental justice considerations 

is being remanded to

AQMD in order that an environmental justice 

determination prepared by EPA Region IX may be added 

to the administrative record and made available for public 

comment. 

Your thoughts on this matter are requested. 

Respectfully,

Heidi Strand, Co-coordinator

Citizens for Clean Air 

P.O. Box 172, Whitmore,CA 96096

530) 472-1355 

hswriter@frontiernet.net