WASHINGTON, Jan. 5, 2015 -- The National Grain and Feed Association (NGFA) and five other national agribusinesses are urging EPA to rethink its proposed rules related to construction or modification of grain elevators, saying the proposals would cost much more than the agency has estimated and require a burdensome amount of record-keeping.

NGFA’s comments were in response to an EPA “new source performance standards” rulemaking proposal, which would apply to facilities on which construction, modification or reconstruction commenced after July 9, 2014. NGFA and the other groups said EPA should withdraw the present proposal, with the effect of removing July 9, 2014, as the dividing line between “new” and “existing” facilities, and then repropose once it has established an adequate record.

“More work is needed to develop a sustainable proposal,” the groups said.

The organizations argue that EPA’s plan for governing particulate matter emissions from new or renovated elevators “lacks a rational basis for concluding” that the work could present a “significant risk to human health and welfare on a national scale.”

They also contend that the costs of installing the maintaining the new technologies involved, especially those related to temporary storage facilities, “are exorbitant in relation to the benefits.” Additionally, they say the plan would “significantly” increase the burden of performance testing, parameter monitoring, notifications, reporting and recordkeeping.


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