Appendix I-5 Response To Public Comments.pdf

The Florida Department of Environmental Protection received comments regarding emissions from sugarcane burning, environmental justice, and NOX emissions. Commenters stated that the Department must consider emissions from pre-harvest sugarcane field burning and require green harvesting. The Department responded that the regional haze rule does not require evaluating all sources of visibility-impairing pollutants and that it has discretion to select sources for analysis. The Department focused on emissions and point sources, which are the most significant source of SO2 in Florida.

Regarding environmental justice, commenters stated that the Department should analyze the environmental justice impacts of its regional haze SIP. The Department responded that while the rule does not require analysis of environmental justice, EPA's guidance encourages states to consider environmental justice impacts. The Department's regional haze SIP requires emission limits that will provide air quality benefits to areas around selected sources.

Commenters also stated that the Department's analysis used outdated monitoring data and did not reflect the shift in nitrate contribution to visibility impairment. The Department responded that there has not been a significant shift in the nitrate contribution to visibility impairment in Class I areas in and nearby Florida, and that sulfates continue to be the largest contributor to anthropogenic visibility impairment. The Department did not analyze NOX emissions but did analyze SO2 emissions.