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 certainbiological 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 (p rimarily related to monitoring, p erformance 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 providesinfeasibility 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