October 1, 2021
Via electronic mail
Senior Environmental Engineer
Indiana Department of Environmental Management Office of Air Quality, Air Programs Branch
100 North Senate Avenue, MC 61-53 IGCN 1003
Indianapolis, IN 46204-2251
Re: Requesting Extension of Comment Period for Indiana’s Regional Haze State Implementation Plan for the Second Implementation Period.
Dear Ms. Boling,
On behalf of Citizens Action Coalition, Hoosier Environmental Council, Sierra Club, National Parks Conservation Association, and Coalition to Protect America’s National Parks (the “Conservation Organizations”), we request that Indiana Department of Environmental Management (IDEM) grant an extension on the public comment deadline and public hearing date for Indiana’s Regional Haze State Implementation Plan (“SIP”) for the Second Implementation Period, currently noticed for public comment.1See public notice: https://www.in.gov/idem/files/notice_20211105_sips_regional_haze.pdf Specifically, we ask that the current date of a public hearing, Thursday, October 28, 2021, and the current deadline for comments, Friday, November 5, 2021, both be extended to Friday December 10, 2021. Additionally, we request the addition of a virtual option for the public hearing as we continue to be in a period of uncertainty with the COVID global pandemic.
For review of the proposed SIP, IDEM provided interested stakeholders with approximately 35 days to evaluate and provide comment regarding hundreds of pages of legal and technical analysis, as well as 20 appendices of modeling data, four-factor analyses, and consultation documents.2See Indiana Proposed SIP and appendices: https://www.in.gov/idem/sips/regional-haze/ 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. Reviewing IDEM’s legal and technical analysis along with its modeling, conducting any analysis of our own, and developing comments will take more time than allowed by the current comment period, which ends on November 5, 2021.
An extension of time will not adversely impact any other party. We understand and appreciate that IDEM has offered stakeholder engagement opportunities throughout the planning process, but that does not affect the need for our groups to have sufficient time to review the extensive proposal adequately and thoroughly, which we have not seen before now. A 35-day extension of the deadline will not prejudice any regulated entity and will not materially affect IDEM’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 Friday, October 8, 2021, so that we can plan our comments most efficiently.
Citizens Action Coalition
Hoosier Environmental Council
317.685.8800, ext. 1005
Senior Director & Counsel Clean Air and Climate Programs
National Parks Conservation Association
Senior Campaign Representative Indiana and Kentucky
Philip A. Francis, Jr.
Coalition to Protect America’s National Parks
Mark Derf, Section Chief
See public notice: https://www.in.gov/idem/files/notice_20211105_sips_regional_haze.pdf
See Indiana Proposed SIP and appendices: https://www.in.gov/idem/sips/regional-haze/