                 PUBLIC PARTICIPATION RESPONSIVENESS SUMMARY 
                                      FOR
                         567 IOWA ADMINISTRATIVE CODE 
                            CHAPTERs 22, 23 and 25
                                       
Introduction
Reason for Rulemaking
The rule changes continue previous efforts to improve rules for air quality programs.

Electronic Emissions Reporting
To simplify the reporting requirements for industry, increase reporting efficiency and reduce cost to the state, the Department is proposing to require the use of electronic emissions reporting for all Title V facilities, beginning with reports due to the Department by March 31, 2019. The transition to electronic reporting will make air emissions information more quickly available to industry seeking to build new facilities or expand existing facilities, and to the public because the Department will be able to access and provide to stakeholders emissions data electronically. Additionally, electronic reporting will reduce the cost to the state because Department staff will no longer need to data-enter this information prior to providing it in the annual federally required emissions report.

Address Updates
The proposed rule changes update several references for the new location and mailing address of the Department's Air Quality Bureau. 

Consistency with Federal Regulations
The rule revisions adopt technical corrections that EPA made to continuous methods for measuring air pollutant emissions. The rule changes also include adoption of revisions to federal air toxics standards (also known as National Emissions Standard for Hazardous Air Pollutants or NESHAP), new source performance standards (NSPS) and EPA's Emission Guidelines. Adopting EPA's amendments allows state rules to be consistent with federal regulations, and provides certainty to affected businesses and other interested stakeholders.

Notice of Intended Action was published in the Iowa Administrative Bulletin on December 19, 2018, as ARC 4178C, and a public hearing was held on January 22, 2019, at the Wallace State Office Building in Des Moines, Iowa. The Department received no comments at the public hearing. The Department received one written comment prior to the January 22, 2019, deadline for public comments. 

Public Comment 
Submitted on December 26, 2018, by e-mail from Linda Quinn, Iowa City, Iowa and Quinn Family Farm, c/o David Quinn, Britt, Iowa: 

"Dear DNR,

I'm very concerned about the lack of federal and state regulations on factory farm air pollution. According to the EPA map below, the air quality rating where I reside (Johnson) is POOR, as well as in Hancock County, home to my family farm. My only recourse is to personally boycott the CAFO meat industry which I do by NOT buying their cheap meat. But this action doesn't even put a dent in the environmental injustice happening all across the state. Currently each of Iowa's thousands of factory farms can emit over 100 pounds of toxic air pollutants daily and they don't even have to report their emissions much less do something to reduce them. There's something very wrong with this picture, isn't there?
 
The EPA has weakened air quality regulations on factory farms and Iowa is aligning it's own nothing regulations with even weaker federal standards. Iowa needs a state and federal government that will adequately regulate this toxic industry to protect the public health vs the current stripping away of all environmental rules.

Thank you for taking my comments,
Linda Quinn" 

Department Response
This comment is outside the scope of this rulemaking. 

Recommended Action
The Department recommends no changes to the final rules from what was proposed in the Notice of Intended Action. 

