STAR Program Formal Comment Response Document

STAR ProgramFormal Comment/Response DocumentNote: Lists of commenters and of acronyms and abbreviations used may be found at the end of this document.Section ... Comment ... From Comment No. District ResponseOverall Comment Overall-1The rules will have a significant adverse The Louisville Metro Air Pollution Controleconomic impact on area businesses while District (District) believes thatmaking no demonstrable difference in the implementation of the initial phase of thepotential risk targeted by the rules and STAR Program will result in meaningfulduplicating federal initiatives already in place reductions in the concentrations of theto address potential risk. affected toxic air contaminants (TACs) in theACC vicinity of the affected stationary sources. The District does not agree that the STARProgram duplicates the results of federalinitiatives. See Responses to CommentsOverall-42 through -47.Overall Comment Overall-2No response is needed.We support the general framework of theSTAR Program, including its basicassumptions, health risk goal (1 in 1 millionlifetime cancer risk), regulatory rulemakingprocess, prioritization of covered chemicalaffected companies, modeling requirementsand time frame for compliance.ALAOverall Comment Overall-3The STAR program will not appreciably Cost and savings issues are addressed in thereduce air toxics, does not adequately Regulatory Impact Assessment (RIA). Theconsider the cost-benefit relationships District ...