Nov 3, 2015· Comment submitted by Michael F. Kennedy, Associate General Counsel, National Mining Association (NMA)· EPA-HQ-OAR-2015-0310-0144
The National Mining Association (NMA) submits these comments in response to the U.S. Environmental Protection Agency's (EPA) notice for "Revision to the Guideline on Air Quality Models: Enhancements to the AERMOD Dispersion Modeling System and Incorporation of Approaches To Address Ozone and Fine Particulate Matter." 80 Fed. Reg. 45,340 (July 29, 2015) ("Proposed Rule"). NMA supports EPA's proposal to change the Modeling Guideline that improves AERMOD and its performance for modeling short-term concentrations of SO2 and NO2, as well as the corrections to low wind speeds. In addition, NMA supports and incorporates by reference the comments submitted by the National Ambient Air Quality Standards Implementation Coalition on the Proposed Rule.