Michigan Department of Environment, Great Lakes, and Energy Public Hearing
May 22, 2024
MS. BUCKLER: Yep. Thank you. Hi, this is Michele. M-I-C-H-E-L-E, Buckler, B-U-C-K-L-E-R.
I'm with Detroit Diesel Corporation. So I have a general comment and then a specific comment.
The general comment is that it would be much easier if the definitions in Rule 336.1840 could
be moved to the beginning of the Part 8 rules because you're looking for those definitions as
you're reading through the rules and you're having to find them kind of midway through. So, it
gets a little confusing because we're used to going back to the beginning of the rules and now
we have to find them in middle, I know it's kind of specific to the RACT.
The second comment is we have a, and I'm not, I wrote it out in the letter, but in Rule 336.1841
subpart three it reads, this is on emergency engines, engines may utilize the following
exemptions from all provisions of this rule except subrule six D. If an exemption is utilized, all
applicable requirements of Rule 1846 must be met. All provisions of this rule apply if the
engine's not usually function below. So if an emergency engine is in place and you're within the
non-attainment area, effectively it puts you into, for lack of a better term, case by case RACT,
correct? Excuse me, for all NOx emitting sources, and that seems very punitive in you have an
emergency engine for emergency purposes, but it's sitting there. Most of the time it runs 30
minutes a month or 10 minutes a month just to test itself and only running during a power out.
So to upgrade an engine that size that would be governed by this rule, I mean that's a quarter
of a million dollars or more that you would have to invest for something that's rarely used.
Otherwise, you go, you're a large source and now you will end up taking a limit under a
hundred tons, unless I'm reading this wrong, if I'm in the non-attainment area for ozone, I have
an emergency engine. I have, let's say I have a plant wide applicable limit of 200 tons of NOx
per year. If I don't replace that engine, then it causes me to go back through a permitting
exercise and take a limit of a hundred tons per year and look at every NOx emitting source,
even if it's a small hot water, like a hot water heater or a larger hot water heater if you're an
investment facility. So that's my point. I don't know if that was the case, but it seems like a
catch all and it seems unfairly viewed. That is my comment, I'm going to send this in letter form
too.
MS. DEVRIES: Thank you, Michele for your comment. You did break up a little bit on the
end there, so if you wanted to clarify that last sentence, go ahead.
MS. BUCKLER: I'll send it in web form.
MS. DEVRIES: Okay, perfect. Thank you so much Michele. If anybody else would like to
make a comment, please go ahead and raise your hand and I will unmute you. As a reminder,
the raise hand icon is in your Zoom toolbar. Otherwise just raise your hand if you'd like to make
a comment and we will be here to listen. I'm not seeing any more hands, but go ahead and
raise it if you'd like.
At this time, I'm not seeing any more hands. We are going to be here until two o'clock, so if you
think of a comment that you'd like to make still feel free to raise your hand using the raise hand
icon in your Zoom toolbar. Otherwise, I'm going to go ahead and mute our line, but we are
going to be on until two o'clock, so again, if you have a comment, please raise your hand.
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