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21a. BAAQMD letter to EPACity Hall 10300 Torre Avenue Cupertino, CA 95014 -3255 (408) 777 -3212 FAX: (408) 777 -3366 CUPERTINO PUBLIC AND ENVIRONMENTAL AFFAIRS SUMMARY Agenda Item No. a - Meeting Date: May 4, 2010 SUBJECT Authorize sending of attached letter to BAAQMI) regarding implementation of the EPA's Proposed Rule. BACKGROUND For many years, the City of Cupertino has advocated for the implementation and enforcement of the highest possible legal standards for environmental protection. The attached letter from the Legislative Committee asks the Board of Directors of the Bay Area Air Quality Management District to require the Lehigh Cement Company to comply with the EPA's rule as proposed. The BAAQMD has the authority to require the emission limits as proposed, even if the proposed limits turn out to be stricter than the final rule. National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing Industry [EPA -HQ- OAR -?002 -0051; FRL- 8898 -1], RIN 2060 -A015 Federal Register/Vol. 74, No. 861Wednesday, May 6, 2009/Proposed Rules, (p. 21140, third column, mercury cap /million tons clinker) LEGISLATIVE COMNIITTEE RECOMMENDATION Based on phone communications received from Vice Mayor Wong and Councilmember Mahoney in support, it is the recommendation of the Legislative Committee that the council endorse the attached letter. Submitted by: Rick Kitson, Public & Environmental Affairs Director Approved for submission to the City Council: 4 David W. Knapp, City Manager Attachment A: Draft Letter to BAAQMD Board Members 21a -1 Date Brad Wagenknecht, Chairperson, Board of Directors, Bay Area Air Qu bra d .wagenknecht @countyofnapa.or Gayle B. Uilkema, Chairperson, Stationary Source Committee gayle @bos.cccounty.us Directors, Bay Area Air Quality Management District 939 Ellis Street San Francisco, CA 94109 Re: Facility #A0017, Lehigh Southwest Cement Company Directors Wagenknecht and Uilkema: We would like to thank you for your active participation in the City Council Study Session on the Lehigh Heidelberg facility here in Cupertino. We wanted to share our view, and indeed our support, for a several matters that have been raised either by you or others during the study session. First, we would like to express our support for the proposed air monitoring system at Monte Vista Recreation Center. We believe this would be a productive step towards both gauging the air quality in our community and addressing the concerns of the citizens. Secondly, we would also like to express our support for the implementation of the currently proposed rules promulgated by the U.S. Environmental Protection Agency (US EPA) upcoming National Emissions Standards for Hazardous Air Pollutants (NESHAP). We hope that the BAAQMD would require those rules even if the final EPA rules lead to a lower standard. We would recommend that the BAAQMD appear at the City Council for a follow -up study session when the new NESHAP rules are implemented to explain what the standards are and how Lehigh Permanente is complying within the new rulemaking framework. Finally, we were pleased to hear that the BAAQMD and Lehigh -- as well as our residents -- all favor the possibility of a single stack at the Lehigh facility here in Cupertino. We would like to suggest that both the BAAQMD and Lehigh look further into this possibility and the City Council urges the BAAQMD to facilitate the timely processing of all permitting required for the construction of a single stack. Sincerely, 21a -2