                 PUBLIC PARTICIPATION RESPONSIVENESS SUMMARY 
                                      FOR
                         567 IOWA ADMINISTRATIVE CODE 
                            CHAPTERS 20, 21, and 22
                                       

Rule making Summary and Rationale
The rule changes will require electronic submittal of all air emissions reporting, air permit applications, and other air quality documents with a proposed implementation date of January 1, 2023. 

Electronic submittals will increase government efficiencies and reduce programmatic costs at the Department of Natural Resources (Department). Electronic submittal makes permit application submittal and emissions reporting easier and more efficient, and allows businesses to submit their information from any location at any time. This expedites the Department's ability to issue permits and increases data accuracy, thereby cutting costs for both businesses and the Department.

Notice of Intended Action was published in the Iowa Administrative Bulletin on January 12, 2022, as ARC 6144CC. A public hearing was held on February 14, 2022, at 1 p.m. via video/conference call. No one attended the public hearing. 

The Department received one written comment prior to the February 14, 2022, deadline for public comments 

Public Comment 
Submitted by e-mail from Mae Thomas, Bayer U.S.  -  Crop Science, Muscatine, Iowa: 

"Bayer Crop Science LP (Bayer) has no objections or concerns with the proposed rule changes requiring electronic submissions of air quality documents, including air emissions reporting and air permit applications. However, we would like to make one comment. Bayer would like to suggest that DNR also revise 567 IAC Chapter 20 and/or 25 in order to allow stack test reports and notifications to be made using email, FTP, or other electronic submittal system. Currently stack test reports are required to be hardcopy reports. Having these reports in electronic form will enhance the ease of submittal, handling, and storing, as well as review of these reports. It will also save the Department the time and resources needed to scan these reports into an electronic form; and save facilities the time and resources to produce hardcopies. It is possible that this change could effectively be made by adding a definition in Chapter 20 for the term "in writing" and defining the term as a notification or report that can be submitted to the Department via FTP, email, other electronic form, or a hardcopy delivered to the Department.

Thank you for the opportunity to comment on the proposed rule and for your consideration of our comment."

Department Response
The Department reviews all stack test reports by recreating calculations to ensure stack test results submitted are complete and accurate. Stack test reports are large documents that require gathering information from several data sections throughout the stack test report, time and time again. Reviewing stack test reports electronically would add significant time and effort to the DNR review process.

Recommended Action
In response to this comment, the Department recommends no changes to the final rules from what was proposed in the Notice of Intended Action.


                                       
