September 21, 2016
| Legal Document
Please accept these comments submitted on behalf of Sierra Club and Earthjustice regarding the Michigan Department of Environmental Quality’s (“MDEQ’s”) Sulfur Dioxide One-Hour National Ambient Air Quality Standard State Implementation Plan (“Submitted NSIP” or “Plan”), submitted to EPA on May 31, 2016 for approval and amended with an addendum on June 30, 2016. The Plan is required to address the portion of Wayne County that has been designated as out of attainment (“nonattainment area”) with the 1-hour sulfur dioxide (“SO2”) National Ambient Air Quality Standards (“NAAQS”). MDEQ’s Plan falls short of bringing the area into attainment, and does not require enforceable, sufficient reduction in actual SO2 emissions from major sources in the area. As a result, EPA must deny approval of the Submitted NSIP.