Transcript of the Public Hearing on the Proposed 2007 Methyl
Bromide Critical Use Exemption Rule
1 U.S. ENVIRONMENTAL PROTECTION AGENCY
2 * * *
3 PUBLIC HEARING
4 * * *
5 NOTICE OF PROPOSED RULEMAKING:
6 THE 2007 CRITICAL USE
7 EXEMPTION FROM THE PHASEOUT OF METHYL BROMIDE
8 DOCKET NO.: 2005-0538
11 EPA East Building
12 1201 Constitution Ave., NW
13 Room 1153
14 Washington, DC
15 Friday, July 21, 2006
16 11:10 a.m.
19 The meeting was held on Friday, July 21,
20 2006, at 1201 Constitution Ave., NW, commencing at
21 11:10 a.m., Marta E. Montoro, presiding.
1 P R O C E E D I N G S
2 (11:10 a.m.)
3 MS. MONTORO: Good morning. Thank you to
4 all of you for coming today. This is the hearing on
5 the methyl bromide critical use exemption Proposed
7 I think we can go ahead and start.
8 Certainly, if other people come, they can sign in and
9 volunteer to speak, as well.
10 My name is Marta Montoro. I know that
11 most of you know me. I'm filling in for Jodaya
12 Finman, who was originally the point of contact. She
13 couldn't be here today. As most of you know, she got
14 her clearance to go work at the State Department, and
15 she is winding things down back at the office.
16 I work on the Methyl Bromide Team with her
17 in the Office of Atmospheric Programs at EPA. Our
18 Office is responsible for the phaseout of ozone-
19 depleting substances.
20 I do want to say thank you to all of you
21 for attending on such short notice, and make just a
22 few general remarks.
1 Specifically, the Proposed Rule that is
2 the subject of today's hearing, is the 2007 Critical
3 Use Exemption Allocation Pool, which was published in
4 the Federal Register on July 6, 2006, Docket Number
6 The Proposed Rule, as you know, would
7 allocate 6,237,890 kilograms of methyl bromide for
8 2007, and that amounts to 24.4 percent of baseline.
9 Again, as you probably know, the purpose
10 of this hearing is to allow interested parties to
11 comment on the Proposed Rule. This would be
12 providing verbal comments to EPA, and we would
13 consider these verbal comments in the same way we
14 consider written comments that are provided us during
15 the comment period.
16 In just a couple of weeks, we should have
17 the transcript available on the Methyl Bromide
18 website and on the Ozone Depletion website, as well,
19 and I can give you those, those URLs, so you can
20 check for that transcript.
21 The purpose of this hearing is really not
22 to answer individual questions, but, again, for
1 interested parties to provide comments on the
3 And as we assemble the Final Rule, we'll
4 be considering the verbal comments we receive today,
5 in the same manner that we consider the written
6 comments that we receive during the comment period.
7 If you are attending today and are
8 submitting oral comments and also wish to provide
9 written comments as a followup, that's fine, too.
10 And I want to remind you all that the
11 deadline for submitting comments is now August 21st.
12 As you know, the deadline was initially August 6, but
13 because there was this hearing requested and we want
14 people to comment on the hearing, as well, that
15 deadline is now moved to August 21st as the deadline.
16 Okay, so I hope all of you who are
17 interested in speaking, checked the speaker box in
18 the sign-in sheet, or, if not, you can let me know,
19 personally, as well. So far, we have one individual
20 who is going to speak today, and that's Peter Joyce
21 of Value Recovery.
22 Right now, I'm going to let him take the
1 floor. Again, if any of you are interested in
2 speaking, I'll open up the floor for further
3 comments, afterward.
5 MR. JOYCE: Good morning. My name is
6 Peter J. Joyce, and I am President of Value Recovery,
7 Incorporated, a small technology-based research
8 company located in Southern New Jersey.
9 We have a 3,000 square foot laboratory for
10 technology development, and have two patents. Our
11 Company invents and develops technology for customers
12 in search of novel chemical separations.
13 We have technology for removing alkyl
14 halides from air, water, and solid streams. Of
15 particular interest is our technology for removing
16 and simultaneously destroying one very important akly
17 halide, methyl bromide, from ventilation streams and
18 fumigations of soil, pre-plant, post-harvest, and
20 The technology has been described at
21 several international NBAO meetings, and, the most
22 detailed description to date, is published in the E-
1 Docket at OPP-2005-0123-205.1.
2 My comments this morning are in response
3 to the Notice of July 6, published in the Federal
4 Register. I will specifically address the request on
5 page 38,336, third column, in which the Agency states
6 "In addition, the Agency welcomes comments on the
7 implementation of emission minimization and whether
8 and how further emission minimization could be
10 We feel that the potential for emissions
11 reduction of methyl bromide is very great, and could
12 have a significant impact on the Agency's and
13 Montreal Protocol's stated goals of protecting the
14 ozone layer.
15 In our experience, we've run up against
16 many barriers in our desire to commercialize this
17 technology. These barriers are neither technical,
18 nor economic. They are barriers of power, politics,
19 common sense, leadership, and will.
20 And since you've given me the opportunity
21 to shed light on how further emission minimization
22 techniques could be achieved and how they are blocked
1 by these barriers, I've come here voluntarily here
2 today in response to your request.
3 For us, emission minimization means the
4 use of emissions controls that result in elimination
5 of at least 70 percent and up to 99 percent of the
6 methyl bromide used in a fumigation.
7 The first barrier to adoption of emissions
8 controls is that no -- and the major one -- is that
9 no commercial incentives to industry have been
10 offered by either the Montreal Protocol, or the EPA,
11 to use emissions control technology for either pre-
12 plant, post-harvest, or QPS.
13 There are incentives with regard to soil,
14 and those are in the requirement to obtain CUEs. This
15 is a matter of public record, and it's been told to
16 us numerous times. In one instance, a green
17 California grower told me point blank, that even
18 though he would love to try our technology for ozone
19 layer protection, to do so would put him at a cost
20 disadvantage to his competitor, who was under no
21 obligation to use emission controls.
22 Commercial incentives could be in the form
1 of a CUE credit on a per-pound or fraction-of-a-pound
2 basis. Thus, if an entity could verify that it had
3 used methyl bromide, but had not admitted it into the
4 atmosphere through third-party verification, then
5 that use should not be deducted from his CUE.
6 Room for this approach is stated in both
7 the Clean Air Act and in the Montreal Protocol. In
8 relating to the regulation of methyl bromide under
9 the Montreal Protocol, Section 6 of the 1997 Clean
10 Air Act, Definition 11, states: "Produce, produced,
11 and production, the terms, 'produce,' 'produced,' and
12 'production,' refer to the manufacture of a substance
13 from any raw material or feedstock chemical, but such
14 items do not include (a) the manufacture of a
15 substance that is used and entirely consumed, except
16 for trace quantities in the manufacture of other
17 chemicals, or, (b) the reuse or recycling of a
19 Clearly, the authors of the Clean Air Act,
20 intended that methyl bromide that did not reach the
21 atmosphere, should be exempt from the definition of
22 "production," due to the inclusion of the exemption
1 terms, "reuse or recycling."
2 If, to Definition B, we could add, quote,
3 "chemically destroyed in situ," then a massive
4 incentive to use emission controls would result. The
5 fact that this modification has not been implemented,
6 is a barrier characterized by a lack of leadership.
7 The amount of methyl bromide removed by
8 emission controls, can be easily measured and
9 verified through third parties. If this information
10 had value in terms of non-CUE allowances for the use
11 of methyl bromide, companies would want to collect
12 it, collect this information, and report on it.
13 Second barrier: The Montreal Protocol,
14 through Decision 17/9, and CRP-10, at the 25th OEG
15 meeting in June of 2005, asked for examples of
16 commercialization of emissions control data.
17 It took nine months for a one-page form to
18 report data on emissions control technology to become
19 available. The form never appeared on the Ozone
20 Secretary's website, even though the Director stated
21 it would be.
22 It became available to us from a
1 consultant to the EPA. The form is technically
2 inconsistent, contradictory, and poorly documented.
3 It confuses concentration and mass in the
4 way that it accounts for the methyl bromide
6 Finally, the form shows a lack of
7 fundamental understanding of basic chemical
8 principles. Despite making the requested data
9 submission, we have not heard one word from the
10 Montreal Protocol, or from Dr. Jonathan Banks, the
11 designee to oversee receipt of this information.
12 This year, emissions control was not even
13 on the Montreal Protocol OEWG agenda. In addition,
14 we were also denied the opportunity to present our
15 data, an approach to the Montreal Protocol, through
16 the use of a side session that was supposed to be
17 open to all stakeholders.
18 We can only conclude that the Montreal
19 Protocol does not believe that emissions control
20 technology companies are stakeholders in the goal of
21 reducing ozone depletion.
22 The Montreal Protocol may also be in
1 violation of Article IX, Paragraph 1(a) in denying
2 our request.
3 We suggest strongly that the EPA make a
4 point to the Protocol to provide expectations for
5 experimentation and support for emissions control
6 technologies and then foster an environment for the
7 exchange of information.
8 This is a barrier of political power to
9 reach those entities and countries who might want to
10 be on the cutting edge of introducing new technology.
11 This is further reinforced, because we
12 were also denied the opportunity to attend an
13 international meeting on ozone depletion in Lisbon,
14 Portugal, in 2004. We were told, quote, "We cannot
15 allow you to attend."
16 The third barrier, an argument that
17 rejects the advocacy of emissions controls, the third
18 barrier is an argument that rejects the advocacy of
19 emissions controls, in that it would lessen the
20 incentive to develop alternatives. This means that
21 if users had a choice between adopting alternatives
22 or using emissions controls and chose emissions
1 controls, then the desired solution to the methyl
2 bromide problem, switching to alternatives, would be
3 severely hurt, because users would not have to give
4 up methyl bromide.
5 The three points can be made to counter
6 this argument: The first is, so what? From a short-
7 term perspective, if the alternatives developers have
8 less of an incentive to develop alternatives, because
9 less methyl bromide is being emitted into the
10 atmosphere, then isn't this what is supposed to
12 The fundamental basis for the development
13 of alternatives, is that they protect the atmosphere.
14 If there is protection for the atmosphere by an
15 alternative solution like emissions controls, then
16 why is this a concern?
17 The objective is to keep methyl bromide
18 out of the atmosphere and the one-way mentality of
19 using only alternatives, should not be allowed to
20 keep emissions controls from emerging.
21 The second counter to this argument is
22 from a long-term perspective. The alternatives
1 manufacturers have been on notice since at least
2 1992, when it was obvious that a ban on methyl
3 bromide would be forthcoming.
4 They have had an open playing field and
5 have been protected from emissions advocacy for 14
6 years. If they can't get these problems solved by
7 now, then how much longer should they be given?
8 Another 14 years?
9 Is there a contractual obligation on the
10 part of the EPA to give alternative suppliers a
11 regulatory advantage at the expense of potential
12 adoption of emissions control technology?
13 The advocacy by the Agency of
14 alternatives, is well documented and understood. The
15 political support has been broad and deep, and there
16 is no reason for this support to wane.
17 However, support for alternatives should
18 not be cast as a corresponding competition with the
19 same space by emissions controls. This defies common
21 Finally, the argument is made that the use
22 of -- the counter arguments: Finally, the argument
1 is made that the use of emissions controls for methyl
2 bromide will mean that to adopt emissions control
3 methods -- that users who will adopt emissions
4 control methods, and be even more reluctant to give
5 up methyl bromide, quote, "when it becomes phased
6 out," unquote.
7 The overwhelming evidence from the CUE
8 submissions in the exempt areas of QPS and crisis
9 uses, is that it will never -- or, should I say, not
10 in our lifetimes, be completely phased out.
11 Fourteen years have gone by since the
12 Protocol was signed, and, this year, the use level
13 for 2007, is down to 29 percent of the 1991 baseline.
14 At that rate, and without a major technical
15 breakthrough or policy change, it will take another
16 14 years and another $165 million in research
17 spending, to get, potentially, down to eight percent
18 of the baseline.
19 The law of diminishing returns is setting
20 in, and policy should change to reflect reality.
21 The fear that emissions control will hurt
22 the development of alternatives, and, in turn, hurt
1 the goals of ozone depletion, are barriers that show
2 a lack of common sense and leadership.
3 Fourth, a review of the 2007 approved CUE
4 nominations, shows that the allowed-use level in the
5 U.S. is 29 percent of the 1991 baseline. A further
6 review of those nominations show that applicants have
7 requested 58 percent of the baseline.
8 If one assumes that at least five to ten
9 percent more would use methyl bromide, but did not
10 bother to go through the cumbersome application
11 process, potentially because of the stigma associated
12 with asking for more methyl bromide, then a
13 reasonable estimate for the need for methyl bromide,
14 is 65 to 70 percent of the 1991 baseline.
15 In other words, after four years and over
16 $165 million in research funding, the desire for
17 methyl bromide in the U.S. has only decreased by 30
18 to 35 percent and maybe even less.
19 Its use level is much less, due to an
20 imposed Government fiat, and not due to voluntary
21 substitutions. Methyl bromide is not going away
22 anytime soon, and policies that its use will go to
1 zero, absolute zero, serve no public purpose.
2 Often Value Recovery has asked, why aren't
3 the methyl bromide suppliers interested in emissions
4 control technology? After all, the introduction of
5 emissions controls would allow the suppliers to sell
6 more and thus make much more money, which is the
7 ultimate objective of any corporation.
8 However, a closer look at the methyl
9 supply dynamic, explains why selling less methyl
10 bromide, actually makes more money for the producers.
11 Since the Government has specified which
12 methyl bromide suppliers can sell in the U.S., and
13 the proportions they can sell, then most of the
14 competitive incentive to compete on prices, is
16 Also, since only four companies are
17 allowed to sell in the U.S., they need not fear any
18 new competition. The Government-mandated cartel of
19 methyl bromide has come into existence.
20 Since the demand far outstrips the supply,
21 the methyl bromide prices rise, instead of fall, as
22 time goes by. Methyl bromide suppliers keep raising
1 their prices to cover both their fixed and operating
2 costs, and to keep their cashflow constant, or, in
3 one case, have actually increase cashflows.
4 Thus, higher prices allow some
5 alternatives into the market, and lets the Agency and
6 the Protocol claim that alternatives are replacing
7 methyl bromide.
8 Thus, by carefully planning how much
9 global supply decrease will appease the Protocol,
10 and, simultaneously keep cashflows constant or
11 rising, by rising prices, then the suppliers are in
12 the best of both worlds.
13 The cry from the industry for relief on
14 spiraling prices, is clear, and has shown up
15 extremely recently in OAR 2005-0538-106, which was
16 submitted to this E-Docket on July 18 by Plum Creek.
17 In business valuations, one takes the
18 future cashflow of a company and discounts for the
19 risk of the business. Regarding methyl bromide
20 supply, there is no risk, thus, the valuations are
21 very high.
22 Since the value generated in any business
1 is a tug-of-war between the shareholders and the
2 consumer, excluding, of course, management's
3 salaries, then the loser in this equation is the
5 Supplier business valuations keep going
6 up, while production decreases. Thus, we believe
7 this is the reason that supplies have not erased
8 emissions control technology, because, in the
9 regulated environment, it is not in their interest to
10 do so, because they will make less money, and they
11 are merely following the directives of the
12 shareholders to maximize the returns of whom they are
13 responsible to.
14 The make less money because the higher
15 costs of emissions control, would go to someone else
16 and not to them.
17 We advocate opening up competition for
18 methyl bromide supply and providing incentives for
19 new suppliers to add value to their product through
20 emissions control.
21 To allow for the continued extraction of
22 value from the consumer in terms of higher prices,
1 along with lessened ozone depletion, is a barrier of
2 political leadership.
3 Number 5: In this testimony, I have
4 repeatedly advocated that EPA support commercial
5 incentives for the implementation of methyl bromide
6 controls as a fundamental method for supporting their
8 Our recommendation for those incentives,
9 are summarized as follows: The Clean Air Act and the
10 Montreal Protocol have allowances in their
11 definitions for production of methyl bromide, to
12 exempt methyl bromide that has been chemically
13 destroyed, post-fumigation, from the CUE allocation,
14 as I mentioned earlier.
15 In other words, if one can prove that a
16 pound of methyl bromide used in a fumigation, did not
17 enter the atmosphere, then this pound would not count
18 against the CUE. In simple terms, doesn't this make
20 After all, if protection of the ozone
21 layer is the ultimate objective of the Clean Air Act
22 and the Montreal Protocol, and it is proven that, in
1 spite of the use of methyl bromide, the ozone layer
2 was, indeed, protected from it, then why should it be
4 Both the Protocol and the EPA, need to
5 revisit the regulation of methyl bromide based on
6 use. As in most regulatory systems, it may be easier
7 to manage for the Agency, but much more painful for
8 the industry and consumers.
9 And, is managing use really easy? Based
10 on the continued drumbeat of requests for CUEs, I
11 don't believe that industry would reject a system
12 where they report on methyl bromide use, destroyed
13 after use, and also emitted, provided access to
14 increased sources of methyl bromide was available.
15 Another commercial incentive would be for
16 the EPA to publish methyl bromide emissions from
17 users on an annual basis. For some reason, the
18 vented amount of methyl bromide by users, does not
19 show up in the TRI database for hazard emissions.
20 I do not know the reason. It does for
21 some industries, but not for all. I do not know the
22 reason that this information is kept secret, and
1 wonder if it is even legal to do so.
2 The public's right to know is a well-
3 established legal principle. Publishing fumigation
4 data by user, would provide ample incentive for those
5 companies or industry groups wishing to gain a
6 marketing edge, based on using stated green
8 In addition, publishing emissions data
9 might be an incentive for companies who use methyl
10 bromide, to actually adopt alternatives, as well.
11 Another incentive that we recommend, is
12 that the EPA publish a drop-dead date, five or some
13 other years into the future, where a minimum of 50
14 percent of methyl bromide use must be contained in
15 some kind of emissions-control use, or use of methyl
16 bromide would be prohibited. In ten years or some
17 other date, a 95-percent emissions control would be
19 In the '70s and '80s, the EPA went to
20 great lengths to ensure that sulfur dioxide, nitrous
21 oxide, mercury, and a plethora of hazardous air
22 pollutants, were not allowed into the atmosphere,
2 For some reason, all of that experience
3 and policy does not seem to apply to methyl bromide
4 emissions, and there is no reason not to do this.
5 I do not know where the chemical
6 industry's Responsible Care Initiative comes into
7 play on this issue, other than to say it is absent.
8 This also could serve as an incentive for
10 Another incentive we'd recommend, is that
11 the Agency seriously consider allowing new methyl
12 bromide competition into the United States, that
13 would be linked to controlling emissions.
14 Maybe the mere threat of competition would
15 convince the suppliers to support emissions control.
16 Other points about our experience and
17 observations that may shed light on enhancing the use
18 of methyl bromide emissions controls, are as follows:
19 First, the original concept of replacing methyl
20 bromide with alternatives, followed the model used to
21 replace CFCs as refrigerants, and is not supported
22 when one does a first-principles analysis and detects
1 a technical flaw in the approach of using a methyl
2 bromide substitution in line with a CFC substitution.
3 The flaw is also evident in the need for
4 continued use of methyl bromide via CUEs, since a
5 drop-in replacement is not available.
6 If one looks at the requirements to
7 replace CFCs -- and it could be argued that this was
8 a much easier problem to solve than the one for
9 replacing methyl bromide -- first, the process of
10 replacing CFCs, required substitutes that could
11 substitute for the physical attributes of CFCs, such
12 as diffusivity, volatility, and density relative to
13 air, as well as other physical attributes.
14 And replacing methyl bromide, besides
15 replacing the physical attributes, one also has to
16 find a substitute for its reactivity, since the
17 reactivity of a fumigant is probably its most
18 critical attribute.
19 Thus, finding a substitute for methyl
20 bromide requires simultaneously matching physical and
21 reactive properties, as opposed to replacing only
22 physical attributes, as in the case of CFCs.
1 This is not a trivial technical task. In
2 looking closer at CFCs, one notices that they all
3 have at least two carbon atoms and sometimes three,
4 while methyl bromide has only one.
5 Thus, the degree of freedom available for
6 the replacement of CFCs, were much greater, due to
7 CFCs being more complex molecules than methyl
8 bromide, and thus the probability of replacement
9 success, much greater.
10 This is borne out in the numerous CUE
11 applications where there is overwhelming agreement
12 across industries and applications, that a direct
13 substitute for all of the remaining methyl bromide
14 CUEs, will be impossible to achieve.
15 This is further supported by the agreement
16 to allow an outright ban exemption for quarantine and
17 preshipment applications, where the thought of a
18 drop-in replacement for methyl bromide is sometimes
19 met with ridicule.
20 Second point: We have done two
21 commercial-scale demonstrations of approximately
22 3,000 cubic feet of fumigation volume, at Royal
1 Fumigation at the Port of Wilmington, Delaware, on
2 imported grapes and at Insects Limited in Westville,
3 Indiana, on exports.
4 Both demonstrations worked, in that we
5 were able to show through a mass balance, an in situ,
6 instantaneous destruction of 87 and 91 percent
7 destruction of methyl bromide from vent streams.
8 Both were in real-world conditions, and
9 the latter was done at 15 degrees Fahrenheit.
10 In both demonstrations, we were able to
11 verify mass balance of chemically-destroyed methyl
12 bromide. We have a design and significant market
13 interest for 100,000 and one million cubic foot
14 systems, amenable to large-scale import fumigations
15 and structural fumigations, respectively.
16 The design of these larger systems
17 overcome an inherent limitation we have on the size
18 of the scrubbers, by applying carbon absorption as an
19 intermediate step to separate out most of the air and
20 simultaneously decouple our operation from the time
21 pressure of their respective operations.
22 The waste from our process is non-
1 hazardous and benign, and waste treatment costs are
2 very low.
3 Third point: Recently, our second methyl
4 bromide patent was published. In it, we show the
5 solubilizing agent for enhancing methyl bromide
6 reactions, is polyethylene glycol, a food additive.
7 Thus, our chemical system for destroying methyl
8 bromide, consists of ammonium thiosulfate,
9 polyethylene glycol, and water.
10 Ammonium thiosulfate can be purchased in
11 bulk for 18 cents a pound, and 30 cents worth of
12 ammonium thiosulfate is enough to chemically destroy
13 a pound of methyl bromide. Our system will work
14 without the polyethylene glycol, even though a lower
15 conversion will result.
16 Thus, we claim that chemical scrubbing, as
17 practiced by our Company, is uncomplicated,
18 verifiable, cheap, easy to operate, and works on a
19 broad range of environments, and yet it still isn't
21 Lastly, often we hear the reviewers need
22 more data. Data can be a substitute for real
1 knowledge, when the operating principles are not
2 understood, or a model not available.
3 However, based our published commercial
4 trials, patent applications, and presentations at
5 national meetings, we have contributed to well
6 established mathematical process model that is in
7 plain sight, is derivable from first principles of
8 kinetics, thermodynamics, transfer phenomena, mass
9 and energy balances.
10 Only the truly incompetent reviewers need
11 more data. In our view, then need for more data is a
12 smoke screen for delays, the desire to grow a
13 regulatory or political bureaucracy, and job
15 The inability of the Montreal Protocol to
16 absorb and respond to our information, is without
18 In summary, I have presented you with our
19 experiences and frustrations in trying to provide
20 emissions control technology to those interested in
21 protecting the ozone layer from methyl bromide
1 The overall issue in this regard is that
2 there are no commercial incentives whatsoever for
3 someone to install very high levels of emissions
4 control technology.
5 Right now, only local environmental
6 regulations related to harmful pesticide exposure or
7 a sense of civic pride, are the only reasons someone
8 would install this technology.
9 It is mind-boggling that a technology can
10 be allowed to sit on the shelf, while unnecessary
11 suffering is endured by both consumers and growers.
12 To not show interest, such as the recent e-mail I
13 received, where a high-ranking member of the EPA
14 could not make it to a commercial demonstration
15 because travel to Indiana, quote, "was not in the
16 budget," unquote, and to not provide incentives for
17 this or other technologies to protect the ozone
18 layer, is unconscionable.
19 There either is or isn't a problem with
20 methyl bromide in the ozone layer. If there isn't,
21 then let's turn out the lights and forget this 14-
22 year sojourn has ever happened.
1 If there is a problem, then solve it, or
2 let those of us who have the answer, have a level
3 playing field to solve it.
4 Thirty-five years ago, this country
5 launched a determined program to put a man on the
6 moon in seven years, and did it. The lunar module
7 had less electrical sophistication than today's cell
9 Certainly, the same country can take one
10 of the most reactive and potentially harmful
11 industrial molecules, keep it contained, and force it
12 into a well known destructive chemical reaction in
13 water, and do it safely and economically.
14 It should not be up to a small
15 entrepreneurial company with extremely limited
16 resources, to have to lead this effort. When this
17 technology emerged over three years ago on May 28th,
18 2003, it should have been embraced.
19 Due to intense public pressure, the
20 chemical and process industries came to terms with
21 the air emissions over 30 years ago. It is time for
22 the agriculture industry to mature and take care of
1 their air emissions, as well.
2 Thank you very much for the invitation to
3 share with you, my views on this subject.
4 MS. MONTORO: Thank you very much, Mr.
5 Joyce, for your comments. Is there anybody else
6 today who may not have signed up to speak, but who
7 would like to provide additional comments on the
8 Notice of Proposed Rulemaking?
9 (No response.)
10 MS. MONTORO: Nobody else? Okay, then,
11 thank you all very much for coming. Again, I do
12 appreciate your attendance today, and we will be
13 posting the transcript of this hearing on
14 epa.gov\ozone and ozone\mbr, in about two weeks. You
15 can also call me, if you have any questions about the
17 Thank you very much for your attendance
19 (Whereupon, at 1:35 a.m., the hearing was
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