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NGF SUBMITS COMMENTS TO NDEQ OPPOSING CHANGES TO FUGITIVE DUST MODELING Members Urged To Submit Comments! August 31 was the final day grain elevators, grain processors and ethanol plants had to submit comments to the Nebraska Department of Environmental Quality (NDEQ) opposing the adoption of new modeling methods that could require the inclusion of fugitive dust emissions from truck traffic from haul roads. The following is the official NGF response to NDEQ. The Nebraska Grain and Feed Association (NGF) is aware that the Nebraska Department of Environmental Quality’s (NDEQ) is considering adopting new modeling methods that could require the inclusion of fugitive dust emissions from truck traffic from haul roads which, if implemented, would add unneeded regulatory restrictions and will cost the grain elevator industry unnecessarily in lost production and countless thousands of dollars. NGF feels strongly that grain elevators, ethanol facilities and other possibly effected industries are effectively dealing with the issue to control fugitive dust or particulate matter (PM) on their haul roads by the responsible and accepted approach in using best management practices. As the Association representing the majority of grain elevators, processors and dealers across the state, NGF is unaware of any singular or collective instance the issue of fugitive dust under the current rules applying to best management practices have failed, or have received any complaints from our members or their neighbors regarding additional controls of fugitive dust. I am sure that if there was an overwhelming groundswell of complaints about the current standards, we would have been notified by NDEQ as the regulatory agency responsible for these standards, and been invited to work together on a practical solution. As NGF understands, the new internal modeling methods being considered by NDEQ could require additional permit conditions on the PM source adding additional fugitive dust controls or limiting the source of the emissions operations, and these PM admission standards would be applicable to both paved and gravel haul roads. NGF is opposed to any change to current fugitive dust modeling standards or any additional controls. Industry organizations monitoring NDEQ deliberations have pointed out several possible errors or inconsistencies with the agencies internal modeling that question the accuracy of the modeling or the necessity of new regulations. Changes to the current NDEQ modeling guideline could expand the industries subject to PM emissions. Grain elevators in Nebraska could be hit especially hard because most elevators built decades ago have no buffer between the emission source and the “ambient air boundary” because the plant sits along a public highway or the elevator may not have a practical way to control access to the property. NGF agrees wholeheartedly with the issues paper submitted to the NDEQ by the Association of Nebraska Ethanol Producers (ANEP) regarding the costs, the possible errors and the negative financial strain the proposed modeling will have on our and other effected industries. Therefore, NGF respectfully requests that the NDEQ abandon the adoption of the new PM modeling.
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