Bob Irvine
Air Quality Division
Michigan Department of Environment, Great Lakes, and Energy
Constitution Hall
P.O. Box 30260
Lansing, MI 48909-7760 

Re: Requesting Extension of Comment Period for Michigan’s Regional Haze State Implementation Plan for the Second Implementation Period.

Dear Mr. Irvine:

On behalf of the Sierra Club, National Parks Conservation Association and the Coalition to Protect America’s National Parks, (the “Conservation Organizations”), we request that Michigan EGLE grant a 30-day extension on the public comment deadline and virtual public hearing date for Michigan’s Regional Haze State Implementation Plan (“SIP”) for the Second Implementation Period, currently noticed for public comment.1See public notice: https://www.michigan.gov/documents/egle/egle-aqd-aqe-sip-Haze_SIP_2021_Public_comment_May_2021_725171_7.pdf Specifically, we ask that the current deadline for comments and date of a virtual public hearing, Tuesday, June 15, 2021, be extended to Thursday, July 15, 2021.

 For the proposed SIP, Michigan EGLE provided interested stakeholders with approximately 30 days to evaluate and provide comment regarding detailed pages of technical analysis, as well as emissions data files provided by LADCO.2See Michigan Proposed SIP and LADCO files https://www.michigan.gov/documents/egle/egle-aqd-aqe-sip-Haze_SIP_2021_Public_comment_May_2021_725171_7.pdf and https://www.ladco.org/technical/projects/regional-haze-progress/ Given the scope, volume, and complexity of this information, the Conservation Organizations believe that the current comment period is not sufficient to fully analyze the potential impacts of the proposed SIP and provide meaningful comment during the current comment period, ending June 15, 2021. 

An extension of time will not adversely impact any other party. We understand that Michigan EGLE intends to submit the SIP to U.S. EPA by the end of July 2021. As the current comment period would only allow the state several weeks to consider comments prior to this planned submission we believe it is reasonable for the state to consider whether a window of additional time is needed to thoroughly review comment submissions and evaluate any changes needed to the SIP accordingly. To the extent that this extension would result in delayed submission to EPA, we believe that such delay would be outweighed by fully considering comments submitted and revising the SIP to reflect such considerations. Because the proposal consists primarily of technical analyses prepared by the regulated sources themselves, it is unlikely that this docket will generate voluminous new material from regulated industry. Thus, a mere 30-day extension of the deadline will not prejudice any regulated entity, and will not materially affect Michigan EGLE’s ability to submit its SIP to EPA within a reasonable time. 

Conversely, given the scope and complexity of the proposed SIP, the current deadline for comments will effectively preclude the Conservation Organizations from reviewing all of the relevant technical data supporting the rule, fully analyzing those voluminous files, and providing meaningful legal and technical comments. Moreover, if finalized, the proposed SIP will adversely affect the Conservation Organizations’ interests in pollution reduction, the environment, as well the health and welfare of our members and their use and enjoyment of protected national parks and wilderness areas. 

We respectfully ask that you grant our request by Tuesday, June 1, 2021, so that we can plan our comments most efficiently.

Respectfully submitted,

Christine Goepfert
Associate Director, Midwest Region
National Parks Conservation Association
546 Rice Street, Suite 100
St. Paul, MN 55103

Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013

Elena Saxonhouse
Senior Attorney, Environmental Law Program
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA 94612