MLPA files public comments on revisions to 10 CSR 10-6.060


October 4, 2018

Carol Comer - Director
Missouri Department of Natural Resources
P. O. Box 176
Jefferson City, MO 65102-0176

We appreciate the Missouri Department of Natural Resources initiative to reduce the regulatory burden on business activity in the State of Missouri. Although in the past we have had specific suggestions relating to environmental regulations, we must note that the leadership in programs that have the most authority over our industry (Air Pollution Control Program, Water Protection Program and Land Reclamation Program) have done an excellent job of seeking our comments when regulatory changes are necessary. We have worked together to achieve our common goals of flexibility for operators while protecting the environment.  However, recent proposed changes to 10 CSR 10-6.060 may, in fact, undo reasonable application review policy recently developed collaboratively between industry and DNR staff.

The MLPA respectfully requests that the MDNR not make any additions or changes to 10 CSR 10-6.060 at this time and instead engage a stakeholder group to reconsider some of the substantive changes proposed during the state’s Red Tape Reduction initiative.  For example, it is unclear what, if any, modeling would be required under proposed subsections (3)(E), (4)(B), (4)(E), and (5)(E) for the de minimis limitation permits traditionally obtained by our industry.  The proposed language found in subsection (5)(E)2. includes a modeling threshold that has historically been applicable to air quality analysis for hazardous air pollutants only; that threshold now appears to be additionally applicable to criteria pollutants.  We respectfully request that Missouri DNR withdraw this proposed change and take more time to study and examine this issue, working with industry and stakeholders.

The Missouri Limestone Producers Association is the statewide service organization for 47 companies engaged in the production of crushed stone aggregate for commercial, residential, agricultural and infrastructure needs. The total amount of crushed stone produced in Missouri is nearly 70 million tons representing a value of about $550 million. MLPA also represents 109 companies that provide products and services to our industry.

 

Respectfully,

 

Morgan Mundell
Executive Manager