Informational Session and Public Hearing for FCA Mack Plant
10:00PM Sep 5, 2024
Speakers:
Keywords:
permit
question
emissions
facility
comment
rto
air quality
health
community
put
odors
particulate matter
area
proposed
increase
pm
vocs
emission limits
rules
people
Recording in progress.
For joining us. I know Caitlin is in the back helping us out with the hybrid portion of the meeting tonight. So we do have some folks online. Caitlin, can you tell right now how
many people we've got online? 14 people online. Awesome.
That's great. So 14 people online, and then we've got, I would say about 10 here in the room right now, but maybe some more will be coming. So going to Billy Valley a little bit on the beginning of this kind of introducing everything, just to give folks time to get in, either online or here with us or in person. We're not virtual here in the room. So So my name is Jennifer Dixon, and I work with our Air Quality Division. I'm going to be the kind of like the moderator, and then also the hearing officer tonight when we get to that portion of the night. So we're here tonight to talk about a proposed permit for FCA us LLC at their Detroit assembly complex, the Mac plan. Before we get started, started, I'm going to have to make sure my computer is working.
There we go. All right, so one of the things that I like to do is just talk about how things are going to work tonight, because we're going to have two sort of separate sections of second presentation. We're going to talk, Dave's going to talk, introduce, about the Air Quality Division in general, sort of What we do, what we're here
to interact with.
If Hey everyone, it looks like we've had some technical difficulties. I apologize. I am going to, I'm reaching out to Caitlin right now, and Jennifer and I'm going to see if we can get folks back on the line. So I apologize if you'll bear with us, and I will, I'll check in as often as I can here, as I try and get folks that were live in the room back with us. So again, you're gonna hear some some silence for just a few minutes here as I try and connect with those folks that were in the room. Thanks for your patience, and I'll see what I can do to get them back online. Thanks. APPLAUSE.
Hey, everyone I see the attendees are climbing again, so I just want to let everybody know who may have just joined us. We're having some technical difficulties with folks that were live in the room presenting this evening, so I'm reaching out to them right now to see what we can do to get them back live. So I apologize again. If you can hang with us for just a couple minutes, I will. I'll do my best to update as I go. I know there were some internet issues today, so I will update you as best I can here over the next couple minutes as we try and get those folks that were live in the room back online. So thanks again for your patience, and I will Update you in just A little Bit. Thanks. Applause.
Hey everyone, it looks like folks back in the room have rejoined the meeting. We're going to see if we can get them loaded up here with their camera. We do not we do not see them yet, but it looks like there we go now we see them. Alright. Internet got moved in here. Okay, awesome. I will turn it back over to you guys. Think,
Mike, can you tell can people online see the presentation? Or No? No,
they cannot see the presentation. I
see that's
not gonna let me right now.
So see if you can share the presentation, and then if you can just follow along with my slides. Here. We're nothing if not adaptable around here, right? Everyone, apology for the heat in here. I'm glad we got a fan. I was actually thinking that the notepad would make the best fan. I tried out the stuff out there, and I was like, this notepad is nice and firm, and we'll make a great band. I could blow you know on you guys, but I don't think he would like that either. So Caitlin let me know when you are up and running here. I think Mike said he can hear us at least. So Mike, can you still hear us? Or no? Yep,
yeah, we can see and hear you guys. I will let Caitlin know when the presentation is up and run.
Keep going ahead and introducing people, just so that we can move things along. Alright, so we met Dave. We met Jeff, introducing Jim. So Jim is our air modeler. So there's 2m words that are important, modeling and monitoring, so they're a little bit different. We'll talk about them each. But Jim does our air modeling, and that is where he uses a computer system to basically look at what is going to be happening in the air in the area, typically before new equipment is put in, sometimes afterwards, things like that. So he'll be able to talk more answer kind of those questions in a little bit. Then we have bermine laner. So Dorian is our toxicologist. So our toxicologist, one of their jobs is to make sure that we have health based screening levels for a group of pollutants called toxic air contaminants. So when a company is asking for a new permit, that's one of the things that we really look at. And Doreen and her other toxicologists that she works with do a lot of that work. Um, Erica Wolf is our in our air monitoring section, so there's that other M word. So the air monitors are going to be stationary monitors, so monitors that don't move, they're typically pretty big. They look kind of like a little, sometimes like a little hut or a house, or I'm losing my word because I'm getting older. Trailer, trailer, thank you. I looked at her and I figured it out. Eventually it came that has a bunch of equipment in it that measures the outdoor air. And so that's just another part of the work that we do as Air Quality Division. And because there are so many air monitors in this area, and we're going to be putting a new one and soon we want to make sure Erica was here to chat with you guys about it. Alright,
so there's the staff, so we're going to, like I said, we're going to do a short information session. You're going to mostly hearing from Dave and Jeff. They're going to talk about what is the proposed permit, permit, how we assess compliance. We'll get to that Q and A session where you guys will be able to ask questions because we only have a couple mics. It might be a little bit wonky. I'm going to be getting my steps in, but I will get to we'll we'll do our best here. Then we'll get to that hearing portion. So just a reminder during the hearing, there's not give and take with us. We're just going to be listening and taking your comments on the record. Once we're done with that, we will talk about how you can submit an increase of confidence. So I always like to tell people you do not need to submit an official comment tonight. If you do not feel ready, you can submit one tonight. You can submit another one later. Just let you know that we're flexible. There's a lot of different ways that we take comments, and not just at the public hearing. So just want people to know. A lot of times people come and they just want to learn, and then they want to go back and go back and write it down, you know, whatever? We'll talk to you about how you can do that. We'll talk to you about where you can find other information. There's a lot out there, but there might be something else that you want to learn about, or you have questions about, so I'll talk a little bit about that, and then we'll talk about how you can get a hold of these guys if you have further questions. All right, so without saying too many more words, I'm going to pass this over to Dave, and he's going to go through part
of the prosecution.
All right, thank you, Jen. Good evening. Hello. Good evening, everyone. My name is Dave Thompson, thank you for coming out. I am, as Ben said, I am the lead permit engineer and one of multiple APD staff that were involved in the review for the proposed permit changes at the FCA Detroit assembly complex Mac plant, which I'm going to be referring to as FCA Mac, where we will be referring to as FCA Mac through throughout the Evening, before we get into the details of the proposed changes, I would like to do an overview of what the Air Quality Division does and how the permanent process works for those who have not necessarily been the one that support so air pollution, as we know, comes from many different places, such as power plants, fuel burning vehicles and other various, you know, various industrial sources. And the overall mission of the Air Quality Division is to protect, excuse me, protect public health and the environment, and we provide this protection by using our authority through state and federal rules, through the regulation of industrial sources. So a QD staff do a lot of things, as Jen mentioned earlier, we do monitor we monitor levels of air pollutants, such as what Eric is involved with. We examine toxic air contaminants to ensure public health is protected, as you noted for Doreen, we conduct inspections of facilities like an automotive manufacturing facility, and we review applications and write permits for sources of air pollutants to ensure to make sure that the proposed projects comply with state and federal rules to protect public health. Whoops. Question. Our rules do require us to issue permits to sources of air pollutants. I would like to point out a few things that the draft permits do not cover and that we aren't able to regulate through there in terms of the Air Quality Division. These items include zoning, noise and traffic on public roads. If you do have questions or concerns about those issues, you'll have to talk to your you will want to talk to your local government. In addition what residents think about a project is important. However, when making a decision on an air permit application, we can't consider whether residents want the project to be done. Whether people also think the project is needed, is also important to know and hear about. But again, we can't consider that when making a decision on air permit application, we have to evaluate the project to ensure it meets all the applicable air quality rules. And if the project needs the needs those air quality rules, we are required to issue the air permit. So to make sure that a company is meeting all of the rules and regulations, they need to follow a permit for the for that equipment. And I'm going to go through a quick, simple overview of the air permitting process. First, the company decides they want to install, modify or construct a source of air emissions. They then submit an application to the aqd, the application has been reviewed by an engineer like myself, decide request can meet the state and federal rules, air quality rules. Now, during that review, other air quality staff, like the members on our panel are involved to help with different parts of the review. This includes reviews for such as toxic air contaminants. I'm going to talk a little bit about those later. About those later. They're also called tax and how those missions may impact the surrounding community. If these rules are met, then the engineer creates a draft permit if public comment is required, as in this case, the draft permit is posted for the public to comment on. Now, public comment is an important part of the permitting process, which is why we're here talking tonight. Once the comment period ends, we review all comments received, and the comments can lead to changes in the final decision, or in or changes in the permit if it is issued. And finally, a decision is made on the plan, on the permit application, and that decision can be either to approve the permit as it's written, when it's an out for comment, it could be approved with changes, or is to deny the permit. And this decision is based on whether what the company wants to do can meet the air quality regulations. Next, I'm going to briefly talk about automotive manufacturing process such as that, FCA, Mac, an automotive manufacturing process consists of three main portions. It is a body shop where they they build the unpainted vehicle, the paint shop where they apply paints and other various materials to the vehicle body, oops, sorry. And an assembly area where final operations, such as glass engine entire installation are formed. So FC Mac has submitted an application to make changes to their existing permit after the plant started running. Odor complaints were received from the community surrounding community, and the consent order was established to help address these complaints. Now, because the consent order is a legal document used to resolve violations and stipulates changes that the facility must follow to must make to come back into compliance with state and federal rules. Now, this particular consent order required certain items, such as installation of an additional control device and rerouting of certain processes. The application includes placing the requirements that were from the consent order into the permit. And these changes are being referred to as the RTO two project. So to go into more little detail, what was the RTO two project? The project includes the following items. There were physical changes that were required by the within the consent order that have been performed, that have been done. There was installation. It required installation and operation of a control device called a regenerative thermal oxidizer. It's being referred to as RTO two. They were rerouting certain processes, and I'm going to go into more detail about that in a few minutes, things that were not equipped, male specific, physically related, placing the requirement for a nuisance minimization plan for odors into the permit and to update emission limits for particulate matter that are seen in the draft permit. So I mentioned earlier that RTO two was installed and is operating as required under the consent order. So what is an RTO? An RTO is an air pollution control device. It uses natural gas and has been found to be the most reliable type of control and addressing odors at a facility like FCA Mac. That at FCA Mac, specifically, RTO two is used to help address odors in certain areas of the paint shop. Oops, sorry about that. So natural gas, it was natural as a noted natural gas is the most reliable for controlling odors from a facility like this. This diagram, sorry, shows the original design for certain portions of the paint shop. The top protective coating is applied to the vehicle body in the clear coat operation. Over on the left side of this diagram, this concentrator is a piece of equipment used before an RTO to lower how much air goes to that RTO, with the original design, the clear coat and concentrator processes each had an exhaust stack, while most emissions from these sources were sent to the original RTO, which is referred to as RTO one. Sorry. Sorry, I'm trying to stay on your way. Sorry, some emissions were exhausted through those other stacks. This diagram shows the current design after the RTO two project, the process, if you look here, the process going to RT one has not changed, however, to help address odors, the clear coat and concentrator process stacks are no longer being used. The clear code exhaust is now being sent to RTO two while the concentrator exhaust is being routed to the RTO two stack.
You want to just go back to that slide, just for a second. Made you step back. Just minutes.
So green, the green obviously follow me on that, obviously, but the green shows the new, essentially, a simple way of showing how it's being routed through the system, instead of through the individual stack.
So how does the RTO two project affect emissions? The installation of RTO two helps reduce orders portions of the paint shop and also the it's been pro updated. Particulate Matter emission limit increases have been proposed before the project. The burning of natural gas within our TLT produces multiple pollutants, including particulate matter, in addition to clear coat and concentrator processes contain particulate matter to particulate emissions from the painting operation that are now exhausted the RTO two stack, the particulate matter emission limits were adjusted and increased by taking into account natural gas used in RTO two as well as stack test results from the from clear coat and concentrator processes. So, oops, sorry, I thought he's taking a picture. So,
oh, so we will share these slides with you if you want them, and you can guys take pictures if you want, but we will send these to you.
So this table shows the proposed increases in particulate matter emission limits. Particulate matter, which is short in the PM, would increase, is proposed to be increased from 5.54 to 9.20 tons per year. Or TPY, PM, 10, which is a slightly smaller, would go from 5.54 to 7.89 tons per year. And PM, 2.5 which is fine, fine particulate, would go from 5.54 to 6.14 tons per year. So now that we've talked we've talked about what FCA Mac is requesting, I'm going to talk about how the aqd reviews a permit application. When reviewing a proposed permit, the permit engineer works with other staff, and the review includes determining what rules, state and federal rules are applicable. There's evaluation of the proposed pollutant or releases against the rules that apply, and air toxics reveal, review is performed to make sure that toxic air contaminants meet akD health based screening levels. I'm going to go into a little more detail on that one. And we do air modeling for criteria pollutants and toxic air contaminants when approval. So basically, the goal is, and what we need to know is, if what an FCA Mac is proposing would meet these requirements. And I'm going to talk a little more detail about the different parts of the review in the coming slides. So even with the pollution control devices I talked about earlier, an automotive manufacturing process releases air pollutants. And this slide, I'm going to talk about the categories of groups of air pollutants that we that we review. The first group are called criteria pollutants. This is a small group of well studied and regulated pollutants such as nitrogen oxide, volatile organic compounds or VOCs. You may have heard that, and particulate matter, the US EPA sets national ambient air quality standards, also known as Max, for these pollutants, to protect public health and the environment, and any releases of these pollutants must be below the max. Now, based on our evaluation, the draft permit as written meets those rules and regulations, a larger group of pollutants is known as hazardous air pollutants. These are pollutants that are known or suspected to cause health or environmental effects. We regulate these pollutants by applying any federal regulations that exist, as well as any applicable state toxic air contaminant. State rules, excuse me, state rules for what are called toxic air contaminants. And the third group, as I just mentioned, is toxic air contaminants, and they are a larger group of pollutants covered by Michigan rules. They include almost any pro air pollutant, including hazardous the hazardous air pollutants. And our rules allow our toxicologists to set health based screening levels, toxic air contaminants, which may you may also hear for purchase tax pollutants being released from the project, must meet these health based screening levels. And I'm going to talk a little bit more about toxic air contaminants in the next slide. So the screening levels, as we talk, as we mentioned before, the toxic air contaminants, and our toxicologists can set health based screening levels on those. These screening levels are designed to protect against health issues like developing cancer or breathing problems. And when we are performing our review, we look at all toxic air contaminants that could be released to the air and compare these against those health based screening goals. Our review of the toxic of toxic air contaminants is based on maximum emission rates and often uses computer dispersion modeling, as discussed in the proposed project summary and the technical fact sheets. Our review determined that TAC emissions, toxic air contaminant emissions, would not violate any of the health based screening levels. So I had mentioned a couple of times we modeled various we can model various pollutants. So what is modeling and why is it important to the review of a permit application? Computer modeling basically predicts what concentrations neighbors would be exposed to from a project, the modeling simulates, essentially, it simulates a grid of virtual air monitors surrounding the facility. This allows for the highest concentration at any one of those points to be considered for our analysis or for our review. And modeling was for this project was done for toxic air contaminants, the proposed pm 10 and pm 2.5 emission limits, as well as emissions for nitrogen dioxide. And the modeling that was performed showed that all tax and criteria pollutants are expected to meet their required their required standards. So at this point, a draft permit is is created, and a permit. Just for more a little more background, a permit is a legally enforceable document with a list of requirements that the company must comply with. The requirements in the permit are there to ensure that the opera the equipment, operates as described in the application, and ensures that it operates in the same area that was reviewed by the Air Quality Division. Now, the existing permit for FCA, Mac has requirements such as emission limits to restrict the amount of emissions requirements to have the various pollution controls installed, maintained and operated properly. As testing requirements monitor and record keeping, including control device monitoring any reporting you know, reporting requirements as well as requirements of EPA rules that apply to FCA Mac, the proposed draft permit for FCA Mac includes many of the same conditions that are in the in the current permit, conditions for RTO operation and monitoring of RTO two have been added. Requirements to have and maintain a nuisance minimization plan for odors has been added in the PM, PM, 10 and PM, 2.5 limits have been increased to those proposed. Now that we've covered the permits review, application review, I'm going to turn it over to our district representative, Jeff cornisky, so we can tell you what a district district does.
Jeff, thank you, Dave. Good evening. My name is Jeff corneski and I work in our Detroit district office, which covers compliance activities for sources located in Lake County. So as Dave just described, all the steps involved in the permit review and all of the different units that are involved in the permit review and in the draft conditions if a permit is issued, when that permit is issued, the responsibility for further compliance evaluations falls to the district staff. This particular source is this particular source, mcmack, is classified as a major source of air containments, and is subject to many state and federal rules. Because of this, it is subject to frequent unannounced compliance inspections by district staff. When we do the compliance inspections, we're walking through the facility, we're looking at all the process equipment, we're looking at all the control equipment, and we're asking for records to compare to the permit to make sure that the source is in compliance with all the standards that they're required to comply with. In particular, and we look at the graph permit, each one of the operations is kind of split up into what are called emissions of flexible groups. And within those tables are different sections. One is for emission limits, one is for material limits and restrictions. One is for testing, and then there's record keeping and reporting. And when we do the inspection and subsequent compliance evaluations, we are seeking to to have the facility show compliance with each one of those sections in each one of those groups. So all the equipment on compliance evaluation is done, all the equipment is is evaluated for all of the conditions in the permanent and even their state or federal rules that apply. So one of the most prominent ways that we determine compliance is through sac testing. So again, we have the emission limits in section one, and one of the really, the only real ways of determining whether the facilities and compliance is through basically stating a probe, in a stack and measuring the emissions that are coming out. There are two aspects of this, of this test, the district staff attend these staff, these stack tests, and we determine whether or not the process is operating in the way that we expect to be representative for typical process operations, because we don't want them operate in a way that is, you know, with low production or high production, that's not necessarily typical of what they're, what they're they're normally operating another part of our, of our division, the technical programs unit. They're responsible for evaluating all of the test methods for each of these tests. There is usually a federal standard reference test method, and it is the technical programs unit who determine whether or not facility their initial plan when they're actually doing the test on site, and then in the report, whether the reference method has been has been substantially met, also for these facilities, because this is a major source, they're required to submit annual emission reports to us. They are required to submit semi annual reports to us that show whether or not they're in compliance, and in some instances, they're even required to submit quarterly reports. So an example of this is like the neighboring plan of Jefferson North has to submit quarterly reports for their for their mission limits. And it was during one of these report reviews that we discovered that, in fact, that plan was over their mission limits, and that resulted in the consent that was signed earlier this year. The SAT testing at Mac has already occurred because, of course, the permit was issued a few years ago, and this is an amendment to that permit, if it is approved. And many of those stack testing events have already taken place, and it was for the RTO two in particular, which is the subject of this review. They've already done a staff test to determine compliance with the emission limits that are outlined in the permit. And there is a condition which Davis put in which would require subsequent tests at the request of the division to determine if the facility is continuing to comply with those initiatives. So the records review is also a substantial part of the compliance evaluation for a source of this type, if there is a violation that has been noted, which has been in the case for this plan in the past, the violation notice is issued, and the company is required to respond in writing to that violation notice and outline the steps that they're going to take the correct problem. District staff also, in addition to all of these compliance valuations, we also take complaints from the committee, which we have received for in this case, voters, but also for other facilities and what you fall out of regional dust complaints, and the we can report those complaints to our office, either by calling me or one of the or calling our peace line, which is the pollution emergency alert system. And we also now have recently an online complaint form on the website, or even larger complaints. At this time, I'm going to turn it back over to Jen and
thank you too. How are you doing back there? Caitlin, everything good.
We're staying on the line,
still online. How
many folks do we have on the line?
We are up to 36
Awesome. That's wonderful. So I think I was kind of trying to tell in here. I think we have about 2527 in here. So great group. Thank you guys again, so much for saying and listening. And I know it can be a lot of information to take in, so we're going to open it up the first question and answer. Now, just a reminder, we're going to go Q and A, so it's going to be about half hour. We'll be able to do it if you have a lot of questions. But once we either get to seven o'clock or y'all are done asking questions, we'll get to the hearing portion. So I love that you just raised your hand first. It's perfect. Caitlin's going to keep me up to date if we have questions from our hybrid online folks, but so I'm going to come to you, I'm going to have you ask a question, and then we'll get our families answers that sound good. Okay? And if I fall down, which could very well happen. And please feel free to laugh, because it did happen before another meeting around. So go right. Okay, good.
So a bit more procedural about
tonight in terms of
tonight, how much time we
just each individual have? A lot
of Yes. So that's a great question. So he asked, How much time does each person have? Because we have a really good group, and we do have to be out of here at a certain amount of time, we'll limit to limit it to around three minutes. I do the best I can with giving people three minutes. Usually it's a little bit more, just say, putting that out there. But if you can try to keep your comment to three minutes, we'd appreciate that, just so that everybody has a chance. We'll stay as long as we possibly can to get everybody's comments. But yeah, that's a great question.
Anybody else
have questions?
Yeah, hold on one second. Oh, okay,
yeah, sure. No, that's fine. Let me get on the side.
So my first question is, my understanding is that whatever these levels, these increased levels, are, they're already emitting at those levels. And the question, part of that is, is, Why were we not made aware of the fact that they are already emitting at these increased levels. This information is coming from the internal source, so they are being allowed to already emit these increased level levels. That's that's why I like to find that out first. Yeah, that's
a great question. So do you guys mind shuffling the mic back and forth over here? Let's give it to Dave first, so and Jeff might be able to answer a little bit of this as well, because you're right. The RTO two that we're talking about today is already installed and operating. So I'm there to control orders, so if you want to just build on that a little
bit, well, the the RTO two is installed and operated and operated, and the process is there. The way that the permit is set up, there is an emission limit that they cannot exceed, that is not, and that is in the existing permit, they're not allowed to exceed that permit limit in the existing permit, regardless of how they are emitting or what they're emitting at this point in time, on A short term basis. Essentially, yes,
that is, that's none. Well,
I'll just say, You know what, what you said is accurate, right? It's it is installed. It was installed at the end of June of 2023 so the the question was, when we had this with a decision, what do we do first? Typically, you're right, typically, we would wait for the permit to be issued, and then the equipment will be solved afterwards. But in this case, because the you know, the net effect of it was, hopefully, to reduce, if not eliminate, orders. It was decided by our division management. Oh, sorry. It was decided by our division management to go ahead and allow through the consent order. So it was a legal document through the consent order to install it by a certain name and then have the permit follow. So that was, you're right. Typically, the permit comes first. But in this case, it was decided that, you know, because they it might have taken a while to actually get the permit issued, and we wanted to have the equipment installed and hopefully have some sort of mitigating effect with the orders. We the division, decided to have the through the consent order process, have the RTO two installed first.
So correct me, if I'm wrong, let me try to get a little bit of clarification for you, if that's okay. So right now, FCA Mac, it's operating under a permit that exists so it is not allowed to exceed the emission limits in its existing permit. Right now, even with the new equipment, it's still not allowed to exceed those limits that are existing. Yes, they did ask for increases, though, so you're right. Follow
up. Follow up is, is if they're operating at the increased levels that you showed us on your program there, and there is supposed to be public comment before they are given this permit. What is the point? They're already operating at that level. So what is the point? And is there going? What is the point? If we're going to make a public comment, we're just spinning our wheels, it's already a done deal. So what? What I mean? And seriously, okay, these are the human beings that are outside of that plan. So the point is, is that, if you are already operating at that six point, whatever it was, what is the point. So let's
go back to this chart a minute and look at it. So I think you guys are very right in that it's a different way than normal. How this happened. Company got in trouble, right? So the company got in trouble, they didn't route their duct work like your like your furnace duct work, right? Say your furnace duct work was going into the wall instead of going out where it was supposed to. Kind of what happened so they got in trouble. The infer, the enforcement action that duck was talking about said, Hey, you have to do something to get rid of these odors. This is your job. This you legally have to do something. So what they legally did was they we required them to put in this new piece of equipment and change their doctorate. So it wasn't going just out into the air and causing odors and causing problems for the community, but it was actually going through this piece of equipment that limits those odors, that cuts those odors down, right? So, yes, you're absolutely right. But as it stands right now, this right here is what they're allowed. This is what they have right now without doesn't matter what equipment they have running. It doesn't matter anything. This is what they're legally able to do. So if they're going to exceed this without this permit, if they're going to be here, so like what you said, yes, they're operating equipment, but they leave the we cannot be here yet because they don't have a permit to do it. So if they don't get a permit, they're going to have to do something else at their facility to make sure they do not go over this, because they are not allowed to go over this right now as we're speaking. So even though that equipment's running, and this happens a lot of times with facilities, they might have a limit on how much gas they can use or how much paint they can spray. If they're getting close to that limit, they can't just go over it. They have to figure out something in the way they operate their facility to make sure that doesn't happen. So I know that's not really helpful. Yes, they are asking for this increase because they want to operate as they're operating and and make sure that they can, or any of them here, and if they if they
are here, or any of them here, that's
going to be something that, you know, there's definitely going to be opportunities. If both want to talk to people from the facility, and they want they're open to it. We can have that out in the lobby for sure. So it's a great question, though. Thank you for, you know, pushing on that clarification. Um,
did you want to go next? Yeah,
okay, hold
on one second. I
do want to understand the answer to darnell's question. So right now, they are operating both our 2r two RTOS, and they're, they're still at the 5.54 Okay, and so they're wanting to increase to the Yeah, okay. So I have two questions there, but though the first one is, when we get to the public comment section the hearing, does that go on like an official record?
Yes, ma'am, oh, that goes on an official record. Okay, great.
And then my next question is,
well, I'm
going to preface it so everybody keeps talking about odors, um, but the reason of the the odors, there's you, there's particulate matter, there's POCs, there's things that are causing the odor. You know, you can want to kind of minimize it and diminish it by saying odors, but there's pollution happening in our community, number one, and my and that leads into my question, who in the state can we talk to about getting, you know, health screens? Because we I live four blocks away from that facility, and since it's been running, I know I've been experiencing health issues. I've talked to my neighbors. A lot of them have and especially people with children. Um, I don't think one of my neighbors isn't here with her son, um, but whenever he has a severe asthma attack, and his asthma really accelerated after the plant became operational, she'll go and check the air quality monitor. She'll go to just there and look at it, and it's always at an elevated air quality rate when he has an asthma attack, we are being affected. Our health is being affected. So we want, I want to know who in the state we can we go to, because this our health issues need to be addressed and, you know, and documented, because we are suffering health issues because of these emissions at the
plant. Yeah, thank you for bringing that thanks for sharing that story. You appreciate it. And oops,
I'm sure I don't fall
so it's a great comment, for sure. Thank you for saying it now, but I would, you know, put it on the record too. Our department, although our rules are health based and designed to protect even the most sensitive individuals. The work that Doreen does and some of our other staff, it doesn't mean that you might and your neighbors might not have a lived experience that has been done that. So our Department of Health and Human Services is another state agency that deals with a lot of that, and might be able to help. We might be able to find somebody that we could put you in contact with. But if you put that comment on the record, that would also be really wonderful. Darren, do you have a question really quick? Then I'll get to you.
I know, sorry, so
don't try to take my job away.
So my question is around the model, the model being used. I know there are a lot of assumptions and models, error mod or help up whatever we use, could we speak to what assumptions we had in the model? And two, where are the gaps, or where could we have improved the model? Yeah, what are limitations of what assumptions are made up? So, yeah, that's
awesome. Hold on to market, right? So we're going to have Jim, since he's our modeler, talk to that.
Okay, good question. Thanks, Eric. The model that we use to write is called Air mod. It is the model that EPA pretty much forces us to use in improving situations like thanks. They wrote it on it. They updated every year. By law, they have to go down. They got to look at it. They have to revise it and upgrade it. Hopefully, it gets better every year. The constants that we look at when we do a model like this, and for those of you maybe kind of get to the weeds or just a little bit, there's a lot of things that don't understand what our model is, what it does, why we do it. It is a computer simulation of what happens when a blue enters the atmosphere. Basically, is the transport of that blue. What happens to it when it enters the atmosphere? Where does it go? What magnitude is going to be? What is going to be potency out of when it gets to a level that somebody breathe. The reason that we do this is that we cannot issue a permit unless we are convinced that whatever the project is that's not going to cause a contributing to a violation of any state or federal air quality standard. You might say, Well, no, why don't we just put a monitor out there? Well, that's a great idea, but we don't know that the project's not going to cause a violation before the project is built. So the only way we can do that is kind of, what, what's your term for Jim, Futurecast, future casting. So the model that we build, and it's pretty sophisticated model. We put virtual monitors out there about every 25 meters we could travel 75 feet apart. So in the neighborhood around the facility, going out pretty much as far as we want to go, we can put one of these virtual monitors in every backyard, every front yard. Put them at schools, churches. I'm
going to pull that picture up, just because it might help people. This one, yeah,
it's a good picture. Every one of those little cross hatches up there shows one of our virtual monitors. And with the capacity of computers these days, pretty much limit how many we put out there. We put 1000s out there, we put 10s of 1000s
out there. Project account.
Ultimately, when we put all this information into the model, what we do put into the model is we put what the facility is proposing to do. And it's a cumulative study where we're looking at the criteria blooms, like particulates, nitrogen dioxide, salted dioxide. It is a cumulative study a lot of people in essence. So in the model, we put what the facility is proposing, and if that doesn't cover everything in the facility, then we go back and put everything else that's going on at the end there. So basically, everything that is currently being emitted from the facility, plus what they're going to emit that's in addition to what they're already meant. And it's worst case too. It's not just an average number. It's what the permit allows them to do, but it's always going to be a little bit higher than they're going to do. I always say like it's a checking account. You always want a little bit more money in the bank that you expect to spend sort of the same. You want to put in what your neighbors are contributing to the air, same pollutants. If we're looking at pm two and five, we want to know what your facility is emitting, what they're potentially going to be emitting. We want to know what your neighbors are also potentially going to emit, in a worst case number. And we also want to know what's already in the air. And we do that from the monitor. So it's a three phase things a little bit? The facility being permitted, it's neighbors that are emitting the same blue and what's already in the air via the month. We put all of those into the model, and we run it. It looks at all the meteorology in the area. We do it over a long term period, five year period of time, because we want to be able to say we've covered every potential neurological condition that's ever going to happen this area. And at the end of the run the number that it spits out, we look at it, and if it's above the health standard, the permit cannot be issued. What can they do with that? Well, we go back and say, Look, you're going to have to reduce your emissions. You're going to come up with additional control devices, you've got to do something that's going to reduce your ground level back at that point, they come back to us. We make these changes in the models. We run it again, again, the same conditions, same meteorology, the same background, number, the same bad neighbors around them, etc, etc. And we keep doing that until they no longer violate standard at that point, then I can go back to the permit engine there and say, based on what we see, again, worst case numbers. That's what we always like to be conservative. We're looking at the worst case background. We're looking at the worst case emissions. It's got to pass that worst case condition, because then, in theory, everything else is going to be less than that, and that's what we're looking to do. Well, that's sort of a long, drawn out in the weeds explanation of what modeling is
so limitations. That was one of the things Darren asked, like, what kind of limitations might you have in the model?
Good question. I'm not sure I can come up with any good limitations in there. You may be limited by what memory that you have in your computer, so rather than maybe 25,000 receptors. Now 100,000 receptors, it might be able to do it might not be able something like that. You can split up runs. You have different quadrants instead of them. The other limitation may be the speed. And some of these models that we do literally can take days or something like this, that that's basically you're only looking at a relatively small number of sources there doesn't take that long to run. But if we have situations where you have a lot of fugitive emissions from roads or pits, you name it, that can take a long time to run. So as far as physical limitations, that's about all I could think of. Okay, yeah, thanks, Jim.
So we're going to do two more questions here, this gentleman, and then this gentleman, and then we do have some online, so we're gonna do that, and we'll come back to the room. Okay.
Are any of you respiratory physiologists sitting up there?
I know we have Doreen is our toxicologist, but She's our only doctor. Well,
yes, I did. There's a chemical in your lungs, called lung surfactant. It's also bronchial surfactant. Particulate matter is the worst thing that you can put on lung surfactant. Lung surfactant is responsible for making sure that you get oxygen in and out. It also helps with the surface tension of the LP line, which means, and I know this is kind of in the weeds, but it means it's easier to get oxygen in and paramatoxy out. If you have functioning lungs or peg the most dangerous thing you can run into is particulate matter. That's why, if anybody's ever had an operation, they always make sure you go and eat out without eating, because the last thing you want is particulate matter coming up out of your stomach, going into your lungs and damaging your lungs effect. And once the lung surfactants damage, it's damaged. If you're lucky, you don't die from particular matter. If that happens. Now, this young lady, unfortunately knows young man has asked, when he takes his inhaler, he's opening up the smaller alveoli in your lungs, which are deeper down in your in your respiratory tract. When that happens, it is ingesting more particulate matter, and now when you smell that stuff, you're getting particulate matter. Yeah. So why would you ever want to be able to increase particulate matter like you're doing here, and the smaller the particular matter, 2.5 will be exact, is where you can do some serious damage to your luxury. Fact, luxury like small film and it just helps you to breathe. Without luxury, you go to heaven.
Yeah, thank you for saying that it it's having increases in emissions releases and pollutants, especially, PM, 2.5 and areas like Detroit is definitely
what you want, yeah. Why would you ever want to increase particular marriages we
ended here, that's our question, yeah.
And it's a great it's a great question. So going back to what Dave had mentioned earlier, when we get a permit application, the law requires us to look at what company is asking for. We don't decide what they're asking for. Unfortunately, maybe we would agree, maybe we wouldn't agree with what they're asking for, but in this case, what we had to do is look at what they asked for, make sure that it had those state and federal rules and regulations, which, based on our review, it did, and then so your comment and your question is a perfect thing to bring up tonight. We really appreciate that. You know, it's it's not a decision that we make or something that we would want or not want to do when we bring these to the community. It's something that the company is asking for, and our job is to make sure that what they're asking for that they bring to or meet those local regulations, whether it's a decrease or not. So it's, I appreciate you bringing that up, and it really is a conveyor question to bring forward to the group today. So I want to get to you, and then we're going to get to some folks, a
couple of some requests they're following up on this model thing we've got going here. The first thing I wanted to know is maybe modeling my little community, we'll be putting in the health centers of what's going on as far as the people. Is it off of a federal world expand? Because when we talk about dropping a bottle in somebody's community, people have ads and different things going on, this should be considered in what you're doing. The second thing guys, because I'm really against my especially when you can do what you want. But the second thing is, it's been five years. We've been three or four different fixes, supposedly, and we're still having the same issue, maybe not on the same level, and you guys are allowed to actually do something like the same thing, so we don't smell it in there. I'm somebody who has to wash my eyes out and things. So at least once a week, if I don't want to go and walk around, it'll dry eyes totally. You know the particular matter, anything going on, but you have a human model right here. Why haven't you guys, in five years came out and talked to any of the residents over there about what's going on, how it's affecting and things of that nature?
Absolutely, I
don't understand that.
Absolutely, so
lucky. That's
the major question. I'm
sorry. Do you want Jim to respond to any health
you can tell me about his model to let you know that your model's been complete, you get what I'm saying. We can all come up with items. My point is we drop something on somebody's community. You shouldn't know what's going on, health wise. And all that information was available to you guys before all of this time, you can pull up your tank top. And in just about every need you guys have had just about everyone. And it's the same thing we're going through the most policies and procedures. It's time for you guys to step up into humans instead of following policies and procedures. Have some moral some humanity about yourself and protect these people. The way to protect themselves, whether you answer or not, I'll do it. Well,
I don't know. I don't know. Do you have any information about, like, how we would, how we consider health at all in a model, or, especially when you're looking at Tech modeling that is looking at health based reading level. So there is some health based information that's considered in that part of the modeling. So I don't know if you can talk speak to that, but you're right. I mean, what you're talking about? Because
if you look at the census of that area, the high asthma rates and everything else is going on, there's no way you with the first purpose, yeah. I
mean, you're right. It's not based on human being.
We talk about what's acceptable and what is because, see, now you've been trying to make it better, you've had about five fixes, and you're downplaying each party. And I'm saying this because I want other people to know when what's going on. I've watched every step of what's been we went from dubbing VOCs on us being unvented. Oh, they went through this. No, no, they were vented and dropped and making people sick, with people that's moved away. There's people who have passed on the black people. I can't say it to that, because I know I'm not, thank God I'm not a examiner into that. But a lot of things have transpired, health and people that still have issues. You guys need to stop this permitting until you will strike for the community period. I ain't talking about the school, which schools are important? I'm not trying to be but nonprofits, all that stuff is great. You need to be doing something on the ground, and they can make sure something happens to people.
And I would like to make that as a comment, okay, I figured you did. I figured you did, but no, thank you for doing that. I don't You're right. It's not census tract base, but there is some parts of the model through the the toxic air contaminant part of the model, but it's slightly healthy you want.
Is it helpful
to talk about your plan? You plan?
So we do have a couple questions online. Caitlin, are they focusing? Are you going to read the question, or are they asking the question? I'm going to read the question.
So the first question about RTO number two.
So the question is, RTO
number two is described
as controlling voters
online. They're going to ask me their questions as well.
So RTO two is described as controlling odors. Is it actually controlling the emissions escaping the facility that have an impact on health, or is it reducing the odors that allow us to detect the emissions released while also creating more pm emissions? So maybe you guys could just explain the RTO a little bit
too, a little bit more.
So Dave, yeah,
oops, sorry.
So essentially, yes, it was described as control of helping control odors. Odors at the facility are mostly called most would typically mostly be caused by the volatile organic compounds facility. So when the volatile, when the VOCs, volatile organic compounds and VOCs are sent there they are. They are burned in the the in the oxidizer. So there is going to actually be a reduction of the OCS in from that portion as it passes through the RTO.
So, Caitlin, let's do I'm just letting everybody know a time check it is after seven already. I know we still have a lot of questions, so we're going to go to like 715 for questions. Is everyone okay with that? And then, okay, Caitlin, we have another question from online. So we have quite a few from online. So if we don't get to people's questions, which we might not anybody that type their questions in online, especially if it's kind of already been asked to answer, don't ask that one. We can respond back to people directly as well. So we'll make sure that we do that. So Kim, go ahead. Oh, get your microphone. Sorry, this is where I
really is getting your steps in today. So one of the questions is multi parts. I don't think we're we'll get to all of these multi parts, since there was five parts to this question. So the question was imposed previous violations at the facility. So in previous violations, in previous violations, especially when they don't disclose, used to deny a permit application, has Egle denied it in permits in the last three years? And then the subsequent question for that is that increase, has the state's health department been engaged?
Okay, so, Jeff, I'm going to have you talk a little bit about the violation question. You don't mind?
Yeah, so the violations that were issued, there was a total of, I think, nine or 10 of them, and they were resolved through the consent orders that were considered that risk issue. So those violations used to deny this particular fairway action. So what I want to also address some of the previous questions about the POC so they the RTO two, as we acknowledge, is installed and operating, and so when they did the testing on it, more than we was reduction. It went from about 28 tons per year down to about six. So that doesn't mean that those six are not still causing problems, like owners still existing, but there was a reduction in the vaccines from the operation of the RTO two versus having that original 28 going on the beta.
Okay, so we can't, and this, for this permit, deny a permit because they have violations. We it's very rare that that will happen. So just being very transparent, it's very rare that that happens. It's very rare that we deny print applications. What usually happens is we tell the company you can't pass the model. They withdraw the application because they don't want it to get denied. So they go back to the drawing board and figure out how they can do the manufacturing process they want to do within the rules. So that's typically what happens. So we don't deny a lot of permit applications, just to be very transparent. That doesn't come very
often. We
do do this, which is trying to make sure things make rules and regulations. So it's kind of a balance. But I know you have a question here, Caitlin, we maybe have time to get to one more question. Oh, I'm sorry. We'll do two more. Does that sound good. Okay. Thanks.
Hello. I have more of a technical question, which is, I would like to better understand what was considered to limit the particulate matter of the RTO two, because there are things you could do to, like, make it ensure that it's pretty clear. Are we getting complete combustion? Like, how much have we pushed back on these values that they're saying they're going to increase to? I'm not entirely convinced that they can't operate RTO two with the lower emissions. So that's what I'm trying to understand. Yeah, sure. That's
a great question. And can you talk a little bit about that?
So essentially, with regards to natural gas combustion, we typically use approved emission factors that are typically achieved through good combustion practices. They typically have to get those, you know, testing or those have been the emission factors have been figured out and trying to use they've been they've been obtained through, typically, what's considered to be good combustion.
Now you obviously provide a comment on that if
you think we need to do more, but it's typically admission factors for that, for the financial gas.
So thanks for that. And next time, can you put the mic a little closer channel if you have okay, sorry, that's okay.
I usually I'm pretty loud. So
sorry,
two questions.
So my first
is, I think it's important for us to clarify
what's authority. Because I too would look at the data that was presented for what's the current legal limit and what Samantha is proposing in my first level eight. Well, legal guardian established their legal limit. How dare Samantha's proposed to go over it. Why is it not automatically objected? But Jennifer already clarified that legally we have patient so I think this is where we have to look at our city council and our mayor and say, why aren't they? And that leads me to question you, once this application means equal, or any application of this type, when is it shared of city council?
Yeah, that's a good question. So
we have some limitations on that, but with applications like this, foreign facilities that we know are highly controversial, then there's a lot of public interest in them once we get them and they're determined to be administrative incomplete, which basically just means the company gave us all the pieces of information we need to be able to evaluate that application. We post the application online. We actually put this one because we have, and if y'all are not already on this list, we have a specific list for anybody interested in FCA facilities, where we send out updates. We also have a web page dedicated to FCA, so we try to get the word out as much as we can, to give people time to look at these applications. Because you're absolutely right. This is, you know, a big thing with a lot of information. And you know, to this young lady's point here, when we're looking at what the ask is, you know, the thing that they asked for in the beginning, they did reduce what they asked for. They did not get. So that number that you saw on the chart where you had the two columns, the one that they're asking for, they had asked for more than that. And we said, this is what we can look at. That's, you know, something that can pass a little to regulation. So we do try to share these. Now we are getting a new system. It's going to be online, which helps some people. Doesn't help everybody, but that will have any application that comes in will be available to for people to see as soon as it clears that administratively, right now, we have to sort of manually do it. When we get this new system in the next three to six months, everybody will be able to see every application, so it'll be a lot easier to kind of go and do that. So it's a great that's a great question, and you've had
a follow up ready, yeah, so
I just wanted to clarify so you say everyone, because I'm also looking at an account of the factor of people who do have the power to see this application. Say No, yeah, because they represent the district where the plant is located. I'm also looking at their accountability. So that's what I want to know. Yeah,
so the city was notified that we have this application that I personally know of shortly after we got the application and it was determined to be administratively so thank you. So one more question here, and then Caitlin can give me a time check please. Okay,
good evening. First
of all, it's something to be in person after many years of virtual webinar, public hearing. So this is very exciting. I guess, a couple related questions. One you know, is there any consideration for knowing that this is going to be the increase in PM, 2.5 and the effect that, according to this effect units, going to be really, really close to what that limit should be. Is there any consideration that people is making regarding, you know, future projections? Because we, I, I had heard that the EPA, including that Wake County, is going to be, you know, in exceedance of particulate matter in the mix, and that's really concerning. And so why would we be approving or considering the approval of an increase in human food by when we already know that there are federal agencies that have identified this as a potential concern. So it's the first one, and the second question is, knowing that the RTO installation is absolutely, really important to control the older issues. Was there any conversation between people in the company about reducing point five in some other part of the facility so that we end up with a net zero impact often, sorry, one more question we live in last week, we will came to an agreement with the community around us, technology, absolutely different topic, but I was decided to see an EG analysis as a requirement now going forward in that area, right in a limited way, but is there a way that that can then also be applied in air quality as well, not just in just one specific division within Egle. Can that be applied across the board? Because it seems very clear from the comments here that it should be applied, not just hazardous interest levels
in there. So a lot of good questions. Thank you. The first question has to do with non attainment evaluation, so or just evaluation with the PM, 2.5 standard. So, Dave, I don't know if you can talk a little bit about what standard applied when we looked at this, and how you looked at evaluating that gets the standard. So this is in because we had this conversation earlier. Oh, she sent out. So there's a difference between the pm emissions coming from the company and then the national ambient air quality standards that are looking at the breathability of outdoor air or individuals. So they're not one to one. It's a little bit different. But you can kind of talk about that. That that would be helpful. I think,
well, as part of the per as part of the applicant application review, we are required to review the applicable, applicable rules at the time that the US time. So at this point, it is still in the Cayman area for PM, 2.5 the modeling was performed for that, you know, against all, every, every, all the recent standards, just to, just to clarify, you know, there was a change. We remodeled the the modeling was redone to do that. But basically, we are required to evaluate based off the the attainment status that it is currently in the area? Yeah,
so it's a good question. This could be a whole conversation about the pm 2.5 standards, and maybe there's an opportunity for us to even come back and have that talk. February 2025 is when we have to put in our recommendations. So that's still a little bit away, and then EPA has time to look at that our recommendations and then make their final presentation. So it's the time frame is kind of long on them. But the other question was, did we talk to FCA about a net zero, like, can they reduce pm somewhere else? So caveating us, we can't force them to ask for something necessarily, but I don't know if there was any conversations around that. I mean, it certainly would be an amazing comment
to be honest. I'm not aware of any of any conversations my head. I I personally just it's my job is to review the proposed emission increase and against those rules. And then, if they don't need them, as they said, I can go back and say they don't meet this. You have to, you have to try to do better. So I'm not aware of asking for any net, net process that's only really required when they when they emit more than a certain amount, and not attainment area, when offsets are required. But, yeah, you can, you can provide a comment, yeah, I think
that's it. That would be absolutely a comment and Regina, are you okay if I click on the spot? Necessarily us ecology question. Okay, so the question was, just to reiterate us, ecology had a Civil Rights Complaint last few years, and it was recently resolved last week. That was kind of a long time coming, and one of the things that had come out of that resolution is in a very limited way, not not Air Quality Division, our work, but our materials management division agreed to do an EJ analysis for hazardous waste license facilities. So it's very different than this. But the question was, could that be something that is then extended to other aspects of Egle, or in the Air Quality Division, or so I'm going to this is Regina strong. She's our environmental justice Public Advocate, for those of you who don't know her, and thank you for letting me put you on the spot.
No problem. It's um Stephanie, thank you for referencing that agreement. So that agreement was very specific to the complaint that was filed at that time. The resolution was based on the regulatory framework for handling hazardous waste, which is different than the air quality regulations. So within those regulations, there's essentially an opportunity to look at that regulation and think a little differently than we have been thinking before in terms of what considered very different. So in each program, in each division, from the Egle perspective, they're looking at different regulations. In this particular case of the agreement, there was an opportunity to in the due diligence part, so that early part, when the company is built together, what they will submit in terms of an application as as Jennifer referred to in this process, um, to include some elements that they look at. And we have a screening tool at the state level called My EJ screen, and they can look at at the census track level a variety of factors. They could take that and use that tool to assess the community that was able to be part of that process, because the regulatory framework is different, and I won't go too deep in the woods, I'm not even sure I can in terms of the difference between the different regulations, but I would say it is an opportunity for us to think about how we use the information. There just isn't a regulatory framework right now in the air quality regulations to use it in that same way.
Thank you so much Regina for that. So hopefully that's helpful. We talked on the side a little bit about and given here the rules and regulations that apply, and a lot of times for things like you mentioned with finding EJ analysis or cumulative risk analysis or things like that, what we would really need is the regulations to change. So you've heard us say, and I know it gets very frustrating to hear us say, these are the rules that apply, and this is what we're doing, but this is the evaluation that we're required to do, and we do try to do this, a very thorough job of that we really appreciate coming to talk to communities about it and explaining things and answering your questions, and I know we can't always answer them 100% satisfactorily, so we're not going to get to everyone's questions tonight. So I apologize for that. If we do come back, we'll have to factor in some amount of time, just to make sure we have a venue that can accommodate a longer time period. We definitely want people to be able to make comments. So what we're going to do now is take a five minute break, where the panelists are going to leave, and then Chris Etheridge, the decision maker, and I are going to get ready to start the hearing. So we're going to take about a five minute break. If anyone needs to go to the restroom or get a drink or whatever. Please go ahead and do that. But then we'll be getting right into the hearing portion of The night. So thanks again For all The Questions You
idea of what we're going to be talking about for comments. Sorry. All right, thank you so much. So I'm going to go over just one more thing before we get started, and this is this, is this slide was like developed because we got a lot of questions from communities about public comment. So what is the public comment? What Can I comment on? Are there limitations to what I can comment on, or things like that. So anybody is going to comment on any part of this or anything, really, they'll take comments on anything. But the one thing to know is that there's certain comments that are more likely to lead to changes than other comments. So I know Dave talked about this in the beginning, and just acknowledging that if everyone in the room said yes, we really want this, or no, we really don't want this. It's not going to be something that we would be able to consider in the decision. So even though it's an important thing to put on the record, it wouldn't be something that would impact whether or not the permit is issued. Things that are going to lead to changes might be things that you look at this and you say, You know what? I think they need to do more testing. I think they need to look at more monitoring, I think they might need to look at like what was brought up earlier, ways to have, like a net zero particulate emission, so we're not seeing an increase. Those are all things that are very valid, and stuff that you would want to make comments on that are more likely to change the outcome of the permitting decision. So other things, just like zoning, truck traffic, noise, we kind of talked about those earlier too. So those aren't things that we have an Air Quality Division that we can make decisions on. So just want to kind of lay that out before we get into the actual hearing portion. So folks know, alright. So like I had mentioned earlier, there is thank you, Joe. There's an opening statement that we need to read to officially start the hearing, and just to remind folks that we will not be responding to any questions that you might include in your comment during this because this is just to take your comments on the record. Okay? And it's kind of boring, like I said don't fall asleep, is what it is, alright. So Good evening, ladies and gentlemen, and welcome to this public hearing. My name is Jennifer Dixon. I'm with the Michigan Department of Environment, Great Lakes and energy, and I will be hearing officer tonight. Chris ettridge, Assistant Division, director of the Air Quality Division, is the decision maker for this permit application, and is joining and listening to your comments this evening, he will be considering all comments before making decisions. This hearing is related to a request from FCA us LLC regarding their Detroit assembly complex back plan. This is an existing source located at 4000 st gene. And honest 4000 st gene in Detroit, Michigan, the company has requested a permit for an existing regenerative thermal oxidizer to satisfy a requirement of the administrative consent order a QD number 2022, dash one, six. The Air Quality Division is responsible regulating sources of air pollutants to minimize adverse impacts on public housing environment. The law governing those responsibilities is part 55 of the natural resources and environmental protection. Although the control device is already installed and operating, it is still required to obtain a permit that meets the requirements of Michigan's air quality laws. This means the equipment must be capable of meeting state and federal emission standards, including health based standards. The proposed permit must also contain conditions that include the mission limits and specific ways of operating the equipment to ensure the standards are met. The purpose of tonight's hearing is to allow anyone interested in the proposed permit to provide information we can use in deciding whether to approve the permit or if there are additional issues to consider. The proposed permit is still a draft permit. This does not mean the department has already made a decision. Instead, it reflects an initial technical review of the proposal. We hope having the details of the draft permit available will help you to provide comments. Everything in the draft permit remains open for comment and for their consideration by the department, including whether department will be granted at all. The department can only use the information you provide if it relates to criteria. We can be instantly decisions. So, for example, local zoning, truck traffic and noise concerns are not within our authority. Some of you may want to express your support or opposition to the proposed project. We're happy to make note of your position, but the law does not allow us to base our decision on whether there is widespread support or opposition to the proposed project. This hearing is being recorded, and your comments will be part of the information we will consider in deciding on the proposed project. The public comment period for this proposed permit began on June 12 and will end at midnight on September 9, 2024 additional comments or information may be submitted through that time via written or verbal comment. This can be done during this hearing, by email or by voicemail. After the public comment period closes, the decision maker will review all written and verbal comments received, all significant air quality related comments will be considered, and a final decision will be made. The decision maker may deny the permit approved, best drafted amendments. If approved, the decision will specify which provisions of the direct permit, if any, have been changed in the final permit, and the reasons for the change in all three scenarios, all interested parties, including everyone who was on the original mailing list, anyone who provided comments during the public comment period, or anyone who attended public hearing will be directly notified of the decision. Included in the mailing will be a letter from the decision maker regarding the decision, and if applicable, the approved permit. Department staff are here tonight to provide a fair opportunity to express your views on the proposed project and listen to your comments. You may submit a written comment at any time during the comment period by us, post or email, you may also call in a comment to the public comment voicemail. We'll start comments with those present in person who have noted on their attendance card but they would like to comment. We will then move to anyone online who would like to comment. Once we get through those, we will open the floor for anyone else to comment. If you said you would like to make a comment and have changed your mind, just let me know when I call your name. You can submit a written comment by typing the word comment into the question box. If you're online, and submit your comment and writing tonight, we will limit time to about three minutes, so if you're speaking, I'll try to let you know if you have about 30 seconds left. So before starting your comment, please state your name and any affiliation you may want to add to the record. Thank you so much for your attention, and I'll now begin calling the names of those who have indicated if they would like to make a statement. Okay, so we have Missy burns. She's one of our permit section managers. She's going to come to you when your name is called. So like I said, you said originally you wanted to make a comment, but you changed your mind, that's okay, not required to make a comment tonight, if you don't want to. And then once we get through these cards, we'll go to online, and then we'll come back to the moment and see if anybody else has it. So just for folks online, I know we have some people calling in if you would like to make a comment and raise your hand, you're going to just press pound two on your phone that will raise your hand so people can see it. Otherwise, if you are joining online, you can use the raise hand button as well. Alright, so I'm going to call three names, so if you guys can just raise your hand, just so busy, and see where who to go to. So the first name is going to be Claire Barrett. Claire Barrett, she's still here. Claire, so she's going to be first, and then the next person is going to be Dick Schroeder.
I'd actually like to provide
you. Like to provide yours and writing, okay, that's wonderful. No problem. So Dick Schroder is still here. Oh, Dick, if he's right behind, and we will go over the ways that y'all can submit comments afterwards too. So he's right there in the back.
As I said, you know, create a statement that I think any increase in the level of particulate matter is going to be causing a lot more health problems as particular matter is very damaging to the lining of the lungs. And if you get to the point where the lungs are damaged so much, that's the end of your ride here. I also know that particular matter that they're talking about at the 2.5 level is the particular matter that goes deeper into your respiratory system and can do more damage than the bigger particulate matter. If you give particulate matter into your body, they have studies that have shown six months later, they can still find that particular matter in biopsies of your liver, your kidneys, your screen. This isn't something that goes away quickly. And when it does damage, it does significant damage. And the idea that we've already had problems in this area and you're going to increase the particulate matter is even worse, because, as this young lady shared with us she has a child in her area that suffers from asthma, and he's the more compromised person in the area than somebody that's just an average healthy young man. So when his lungs get damaged, he's going to be very compromised, and his quality of life is going to go down dramatically. It just doesn't make any sense at all to increase the particular matter. And I know that there's ways that they can burn off even more particular matter, as I've talked to industrial engineers about this. And unfortunately, from the feeling that we're getting, this is, unfortunately, something you guys can't really control because of the standards that are set. And as long as the standards are high, we're going to get this problem, and people are going to get hurt. So whatever you can do to discourage this, go back and make them take another look, find another industrial engineer instead of, you know, the industrial engineers that are on their expense book that might give you a more, you know, over, over, overlooked, you know, give you a higher perspective. And that would be,
I think, a better way to go.
Thank you so much for your comment. The next person is Mary Rolo. Mary, I'm sorry if I pronounced your last name. If you don't mind just stating your name, sure the affiliation for the record, and then the next person is going to be Dominique decili, okay. So,
okay, so my name is Mary rulo. Sarah club member attending recently Action Coalition. I have a letter calling here. Has 70 signatures. Place. I'll just say that about breaking respect should indicate the level of interest. We are not all air quality regulatory experts. We are nearby residents. We continue to experience voters headaches. Our community has held complaints with Egle. We are aware of steel vibrations. So if protecting health should be a variety of role. Stellantis is not the only side and accumulative impacts lens, along with environmental justice principle, should frame all this current decisions made. We are grateful for the leadership of the Eastside Climate Action Coalition flagging these issues for our community, PCAC should be at the table as the terms of our negotiating we further request public discussion and consideration mitigating factors. And I've listened up and we need to read them, and I just want to say I shared this with our elected officials, our representative. Yeah, thank you so much for your comment. Okay,
the next person is Deb Moore.
Is Deb here,
Darren Riley, Darren, latitude and Okay. He knows how to make a comment, um, Rhonda, this.
Rhonda, did I say your last name?
I apologize.
Just repeat it again so it's on the record. Thank
you.
Good evening. My name is Rhonda theus, and I am resident of East Campbell Village, and I'm four blocks away from the stellantis facility. Stellantis should not be allowed to increase their admissions. We guys have given a lot of information about the permitting process and the legal limits, which I understand. However, no one has addressed the health impacts that are occurring with where the admissions, where they currently are. So I really would like for you guys to take into consider, into consideration, you know the health and safety of the residents living right near that plant, because we are having serious health issues, and I do agree that people should go back and ask them to figure out ways to not increase the emissions for Motor Company, I did some research, and they their paint process. They use E cope application which does, which has very, very low emission. They, you know, dip the paint. Dip the vehicle into the paint. So there are solutions out there, other than them polluting our community. Um, in addition, I understand that, you know, you guys are going based on the the EPA regulations, but I, you know, I talked to a few lawmakers about the fact that the paint that selectus uses is definitely illegal in a lot of other countries, and then we need to look at those things. I know you guys can't base your decision off that, but those are things that you know, there's a reason why that paint is illegal because of the impacts that it has on health. You know, this really is an environmental racism issue that is core, that no one is talking about the impacts on our health with these particular matter and these VOCs, because they get into our lungs. Also the 2.5 are small enough to get into our bloodstream. So you know, my comment is for Egle to go back and go back to salantis and work out, have them work out a way that they will not increase admissions into our community.
Thank you so much for
your comments. Mr.
Hold on. Let me see over here. Hold on one second, and if you don't mind us, maybe again for the record,
I snow, everybody is pretty much telling to say, two, no way we should give them any technical purpose. They don't include them reducing any type of needs coming out about that facility. We should be looking for it going down, not even stand status quo per Democrat, because then consider the people in the community. So now it's time for direction. I know you guys gotta follow me, whatever, but I don't see where you should allow them to process at this point that you.
Thank you so much. Okay, the next person is Loretta. Palme. Loretta, did I say your last name? Right? Loretta, yes,
thank you. I got one right tonight. But if you don't mind just stating it again for the record on the sequence, Loretta, whenever you're ready.
My name is Loretta Kyle, and I'm a member of East academic network, and I'm going to have a nonprofit organization. I have health challenges. I work at public schools, and we have a lot of asthma children, another children be absent because the high the asthma rate has went up. So I wish they're not increase it. They need to decrease it. We have a lot of seniors in our neighborhood too. It has helped counties. So I've been in this neighborhood since 1967 and I'm only three minutes away from centers. So
that's all I have to say.
Thank you so much for that comment. Eden. Eden bloom, you're next.
Eden bloom, tonight I am representing the Detroit people's platform supporting justice for Benton group, but I'm also a live here, and I've been to all these meetings, extremely expert. I've got about four months. First up, the rules of the meeting are unjust, the rules of the meeting are conscious, and this is an extension of process that has been included in environmental racism. This permit is an extension of the process rooted in environmental racism. So I've got a few demands. The first is that this is denied completely. This permit needs to be denied based upon the previous violations the consent order and the ongoing stuff I smelled on the breaking and it is getting back in my kids. I got three kids once got into just like the stats, I'll say,
right,
okay, and we've been here for 10 plus people.
So what do we got? I want to make sure I read it right. Approve whatever aspects so so deny it completely. Second option, approve what aspects that you need to get this RTO working, operational, make us super safe, protected, and everything that they say it's going to do, make sure that that happens. Do not increase the emissions. The pm 2.5 do not increase the emission. Approve the RTO. Do not increase the emissions. If you have to increase the emissions. Point two, put a time frame on it before you let them do so, to make sure the RTO is working the way that it should be working, and it's doing what it says it should be doing, and that we get some relief before that you give them permission to increase so an extension time frame where we where we verify that what they say is going to do is going to do right. Thanks, Chris.
So the third thing, based on many factors, and Detroit people's platform is not an EJ organization. We're we're an EJ economic justice organization. So we're interested in the fact that we have spent about $423 million worth plan to to reimburse the existence of this plant. So we're using our own tax dollars to do this to ourselves. So I would like that to factor into the equation somehow.
So, okay, let's claw black. Let's, let's get a call back going where we get some of that money back from some asset space, which I want to have. Finally, most important in addition to the clawbacks, I encourage people to revoke the certificate of exemption for air pollution control that provides a 100% property and sales tax exemption and the grounds for revocation are substantial non compliance, which I would call what we've witnessed over the past five years, substantial values, all the tax exemption, all their tax exemption,
their employees and their own like, get up to do the right thing, do something
to get this back into it justice, break make this process not just check And thank you, please.
Thank you. I see good points. Senator Chang please just
standing at these hearings first again. Thanks for having this hearing. I think it's always really important that we are always listening to the community members. So I am aware that earlier this year, an American Lung Association released a report giving us an F in here quality. And at the same time, we also understand that the EPA expects us to be out of achievement with pm 2.5 in less than 10 years. So that's really, really concerning. So that context, I think, is really important for the decisions that you all are making. As I entered this room, I really just thought about how this community is, again, put in just such a strange, really kind of unfair position, because we are here in many ways because of the years of issues with odor, and then there was the promise of an RTO. Well now we have the RTO, and then now, in exchange for reduction or hopefully addressing odor, we are now faced with an increase in PM, 2.5 it seems really just mind boggling that a community should be put in a position of choosing between older issues or PM, 2.5 issues, when you know really we should be talking about air quality as well and ensuring that everyone's public health is protected. So I know that Egle, in the past, has been able to work with the company to go from the permit that actually increases emissions to then later actually a permit that actually decreases emissions. Because I remember in 2016 when marathon had proposed an increase the sulfur dioxide, different substance, but they ended up actually coming up with a permit that reduced images. They found a way to do it. This is a this is a company that I think that people should really push towards finding a creative way to make sure that, if not a reduction, at least net zero when it comes to pm, 2.5 let's address the older issues, but let's never create an additional problem for the community. And I know this point has been made time and time again at every hearing, but I just really urge Egle to do everything that it possibly can to look at cumulative impact, and look at health impacts and to look at environmental justice analysis. We know from last week that this is going to be done in another division. And I would really urge Egle to make sure that that EJ analysis is done across all divisions, and not wait for a complaint and then a resolution to that process, but really to just go ahead and do that. And again, I just really hope that Egle can work with the company and force them to get to a point where they are not increasing. PM, 2.5 this community has been through so much over the past five years, and to try to resolve that issue by creating another problem just seems totally unfair to this community. So again, urge people to find a way to make senators do the right thing. Thank
you so much for your comment. So Caitlin, we're going to go into the online comments. So we're going to come back to the room after they go to online. So Nope. Did you say yes? On your part? I didn't get it. Do you need to be okay? Do you mind if we come back to you? Okay, perfect. Alright. Caitlin, if you don't mind starting folks online and then folks that are online, if you don't mind just reminding you to say
hello, come on. Go ahead, whenever you're ready.
Yeah, sorry I have Am I duplicated here? I have to mute.
Nope, you sound good on the side. You sound good over here. So you should be fine to go ahead. Monarch, are you ready? You
Yeah, you should just be able to unmute yourself now.
See if you can go to the next person.
Now, can you hear me? Now?
Yes, Simone, we can hear you.
Okay, I apologize. I hope it's not duplicating sound here. Okay, apologies. My name is Simone sagovac. I'm a 30 year resident of Detroit, and I just want to emphasize that residents health must be prioritized over anything else. There are options to reduce emissions at the facility and to improve health at homes and schools. The EPA states that particulate pollution is one of the most dangerous forms of air pollution, and egle's website acknowledges it is likely that areas in and around Detroit will be designated as being in unattainment with the new PM standard. It has been stated that the permit must maintain the health based standard, I want to urge that Egle take steps now to assure that we will not reach and exceed the new health protective level for PM. In this area, residents have already been experiencing worsened health since the stellantis facility opened. Detroit overall has twice the rate of asthma than the state of Michigan, and is higher in areas of concentrated pollution. And asthma is just one of the many health conditions from air pollution. VOCs are being admitted from this facility. You can smell them every day from the American Lung Association. Vocs can irritate the eyes, nose and throat and cause difficulty breathing and nausea, and can also damage a central nervous system and other organs. And some VOCs cause cancer. There should be remedies for residents affected in the community having to experience additional emissions, such as cumulative impact analysis and health assessment of the affected community, provide air filtration HVAC and new windows as necessary at the immediately located schools to meet air quality standards, and also indoor air filtration for homes in the impact area and measure home indoor air quality, and then also want to weigh in on the clawback of the incentives and other benefits ensure instead that these funds are invested in the community needs like these above that the community has identified. Thank you.
Thank you. So I'm sorry about the technical difficulties, but
we urge you. I appreciate the comment
that was the only one.
Okay, this gentleman up here to see if you don't mind, since we missed his card, apologies for that.
She's coming for you.
Thank you.
My name is Roshan Harris. I am director of power building and having stories network work very closely with the Eastside Climate Action Coalition. So definitely, thank everyone from the community who showed up and showed about and gave a positive public comment on what we need to do. But I know a lot of things I'm going to say have been stated so far, but there are a few things that I think will be supplemental to the signals that have been already made by community members and experts so like so, first and foremost, our fears are actually supported by people's own research and essentially a recent sampling at the Detroit assembly plant, you guys at Google tool conducted by he found about organic compound are Released during the painting process of carbs, right, with the highest measurements being observed at Site four and site one of the dacm. Now, site one is located very close to benato Street. As mentioned before, residents on Veneto street have reported particular stench that come from the area. Per Eagle study, this stench is caused by benzodehyde, ethyl benzene and MP exoline, which are found at levels exceeding their order threshold. We know that the RTO is in place to help control dplc emission, but adding the pm pollution is not a viable solution. Detroit has struggled to maintain attainment status of PM, 2.5 old standard of 12. Excuse me. Don't understand that the new standard is regulated at nine. The EPA predicts that the Wayne County is one of the mere 24 counties across the country projected to fail to reach even 10 by 2032, given the fact that the region is already far above the new standard, no further. PM, 2.5 increases should be permitted going forward. Importantly, new PA, new EPA standards for PM, 2.5 and went back may 6, 2024, so any action by able to consider this permit within the old standards is illegal, while non attainment designations haven't been finalized, legal is still required to deny her a permit if it will interfere with the attainment or maintenance of the air quality Standard for any air contained or, sorry, contaminant.
So at the very
least, evil should be requiring stellantis to make corresponding reductions to pm 2.5 at this facility. Of note, the initial expansion of this plant in 2019 was rushed and moved forward without significant regarding five years later, we're still obviously being impacted by that in both their mission and their jurisdiction under the Clean Air Act, people must uphold its duty to protect the well being of the people, not corporations continuously, grandpa, Mister pollute in the direct violation of evil's authority and responsibility to protect the health of our environment and communities. The east side climate action Action Coalition is against the approval of this permit for additional PM, 2.5 emissions from this plan. But in the event of an approval which kind of already alluded to is going to happen, there are some safeguards that we and the community members strongly recommend for the protection of public health. 30 more seconds. Okay, so I'll just go through these recommendations really, really quick. Number one, use alternative paint options. Number two, restrict production on air quality alert days. Number three, indoor air purification, especially for households on benefit to Fairview banner and other impacted areas. Also a buyout option for residents on Veneto Fairview and manner, cumulative impact consideration. We want to make sure that there is vegetative buffering, also supportive nearby residents. A community fund from violation that goes to directly impacted folks, taking into consideration climate change factors, transparency and monitoring school air filtration, which is very important because, as you know, southeastern High School sits right there on bento Street, asthma data for those corresponding schools any the surrounding areas, and also a system upgrade at Southeastern high school to Help protect those students and faculty at that institution, and with that, we just understand that, number one, we're going to put foremost the importance of the health and the safety and the duty of your agency to protect that of our community members. Thank
you very much. Thank you for your comment.
So is anyone else in the room that has not already made a comment that would like to make a comment this lady in the back, hold on one second. Let me see. Get over to you and then just don't forget to say your name for the record. I think, hi. My
name is Christine, and I'm the point car. I'm really bad. I have to be here. When I was a kid, I used to think, you know, there were always people that had your back that take care of problems. And when I started looking into, it's been years now I live in Grosse Pointe Park. What is it like, three miles away, and I don't quite need a little smell this. And I just started looking into, what do I do about this? And now I'm finding out that we're actually into, like, a new stage of running it from getting worse, my kids went to Detroit wall or school, and my friends and family still there. Belle Isle is a train service State Park, particularly across the street from the plant. Who has our bags. I don't understand how we are here in the first place, but I drive up and down Mack in Jefferson, almost every day I have to close my windows. I feel safe. It's not it's not going, Hey, children are wildlife or miles around the planet breathing in this rather day in and day out. What is it doing to us? I don't know. I'm not a scientist, but I'm hoping the scientists have our back and that our officials have our back. And I'm really glad to see some representatives here, and I hope that they're pulling some strings, and I hope people is doing its job, because this is where they get listed. I have to be here, but I'm here to represent Belle and I and the animals, the kids at the schools, the people in the neighborhood, give everybody who smells this every day, day in, day out, breathe fishing. And if they knew that this was going on, because we're all busy, we we're just trying to make ends meet. We don't have time to sit here and figure out. What do we do about the smell? Somebody else is doing this, I suppose, but, but I don't know that they are, because continue to smell it, and now we're looking at it getting words so I don't understand, but I'm here because all of the 10s of 1000s of people that are smelling this every day and breathing this in and damaging themselves aren't here. And I just want to point out they can be here if they knew how this works, if they knew that they needed to be here, we should have 1000s of people here, because we're all reading this in every day, and it's not right. So thank you.
Thank you for your comment.
So anyone else in the room right now that would like to make a comment with somebody or in front would like to keep
your comment yeah, I'm
Jocelyn Harris. I have the opportunity to represent the district four Community Advisory Council, a body of folks that were elected by the residents in District Four to serve them, to be a connect between government and officials and the people, and the fact is that we're very dedicated as volunteers in this position to the health and welfare of the people. And the fact is that we're organized to the point that we meet monthly, and we have four strong work groups. One of the strongest is the one that deals with the environmental issues and the land issues in this district four. And the fact is that we work in cooperation with our partner, the Detroit people's platform, so the things that we bring to our meetings and we operate in the work groups, is based on facts, not fiction, because we know that the facts are the facts, and so we deal with facts. And so then I asked the question, this was really mind boggling to me. I live in Jefferson, Chalmers, stellantis drew a line that identified the impacted areas and those outside of the impacted areas? Well, I don't know that that line really exists, because I live on Lake Florida. Now I'm hearing that folks over in the Grosse Pointe area are smelling the same thing that we smell. My neighborhood is mostly senior citizens such as myself, and I can tell you, person by person that the health of the seniors have led to death, between the sewage backups, the odors, environmental issues and asthma that might affect a young person in one way, I've had neighbors to die after being on ventilators, and that's a fact. And I am so glad to be opportunity to stand before you and say this, because we have talked to our mayor about the environmental issues that are impacting the health of the people. And for him, he congratulates you. Ego. He has lots of confidence in you. And the reason he has confidence is because, as we understand, you've identified 12 violators in District Four alone that are doing their business on a daily basis, and according to your own however you go about testing you have they are violators. The question I ask is, how is all this violation impacting on the health of the people? And so I'm thankful to have a voice to speak on behalf of those that would be here, some if they could, and others because they can't. And so my question is, understanding that ego is a state agency, and understanding that you're here to represent the better good of the people. How are these violators being ticketed? I want to know the process, and we're doing some research to find out and if, in fact, what they're doing is a violation, how are the people that were impacted being made whole? And I'm thankful for a senator Chang who understands, according to one meeting that we had, that stellantis, for one, is a violator. And so they were fine, $83,000 most of the people living in my neighborhood realize that equals two cars, maybe $83,000 $3,000 and the beggar question is, where does that $83,000 go? Does it go back to the people who harm was done? So there's lots of questions in our mind, but we're holding and we I only can use the word pray that those who are elected or appointed to serve the people do so and so thank you for the opportunity to speak.
Thank you so much for your comment.
So anyone else in the room would like to make a comment tonight, otherwise, we'll see if there's anyone else online,
nobody else online,
just let's give another minute in case anyone online would like to make a comment if you're calling it as a reminder, you're just going to press power to on your phone, or you can use the raise hand icon as well. Let's
give it a few more seconds to make sure nobody else wants to make a comment. Thank you. Applause. Caitlin, okay,
we're going to go ahead and close the hearing, and there are a couple other things that to go over if people want to stick around. You don't think we don't have to do but in case you're interested. So thank you so much for taking the time to participate in this meeting tonight. We do appreciate your interest in protecting Michigan's scare quality, as indicated at the beginning of the hearing, the public comment period will close at midnight on September 9, 2024 all interested parties, anyone who provided comments during the public comment period, and anyone who attended this public hearing will be notified of the final decision on this proposed permit. The hearing is now closed. Thank you again. So just a couple things, Chris, thanks for sitting up here with me. A couple things. If people are interested, if you made a comment tonight, or you didn't make a comment tonight, here's other ways that you can comment before the ninth. So we'll take comments. I like to say we'll take it on a napkin, a note card. You know, however you want to get it to us, we can also email that into our public comment mailbox. A lot of folks, just like you saw Roshan do tonight, reading a comment into the public comment voicemail. It's also a fine way to do it. So whatever that's the way you would like to make a comment. We're happy to take all of them. Information about this can be found at michigan.gov/eagle air public notice. So not only is information about air permits, but we put a lot of things out for comment, including enforcement, detox, air contaminants, rules, things like that. If you are really interested in public comment, that could be a place to go as well. So some of the things that you found outside when you came in the proposed project summary, that's a very high level overview of the project, some information about regional air quality, things like that. The technical fact sheet goes a lot more into detail about the work that Dave and the team did to evaluate the permit application. So if you're interested in learning more about rules, regulations, how they're applied, that's going to be a good place for you to go the proposed permit, terms and conditions, also something that you can comment on, where we will post the link to this recording. We will do it as soon as we possibly can. We try to have a quick turnaround time. Then what will happen is either Caitlin or myself, we'll send an email out to everybody who was here, everybody that was online, anybody who gave us an email address, and more people will probably get an email that has a lot of this information, the slides that we use tonight so that y'all can see them again, a link to the recording if you're interested in that, and then we'll post that on that public notice page. So if you are interested in talking to any of our staff, we will be here. We're happy to have one on one conversations. I know it's getting late, but you can also reach out. If you want to reach out to Dave or Jeff or one of the folks on the panel, if they can't answer your question, they will get you just a home. Who can? We're happy to do that. With that being said, thank you so much for your time and attention tonight. This was a really helpful conversation for us. I hope that it was helpful for you all as well. Caitlin if you want to go ahead and close online meeting, appreciate it, and then like I said, we'll stick around here if anybody has any other questions. Thanks so much.