1. The approval of an air quality plan for the proposed I-80 South Quarry in Parleys Canyon is premature since the Third District Court has not yet ruled on whether the land is subject to Salt Lake County’s zoning ordinance which would deny the quarry a conditional use permit.
2. The plan only covers the emission estimates for a 20-acre open pit quarry and Granite has stated in public meetings that their ultimate intent is to expand it to a 635-acre pit.
3. Nowhere in Granite’s plan does it specify how much water will be required to suppress the fugitive dust.  DAQ does not require operators to estimate the amount of water they will need or demonstrate that they have access to the volume of water required.  This is water that will be diverted from flowing to the Great Salt Lake.  
4. Utah’s regulation of fugitive dust from gravel pits is extremely weak.

a. DAQ does not routinely inspect quarries and gravel pits for dust control compliance or monitor their dust emissions more often than every 12-18 months.

b. DAQ’s method of assessing dust control can’t be performed at night or under other low light conditions.   

c. Gravel pits and rock quarries are not required to prevent dust plumes from blowing off their property when wind speeds exceed 25 mph.

d. While quarry operators are required to maintain documentation of dust control activities for DAQ review, these records are not available for public inspection and, in any case, do not include information that would allow the public to determine whether the gravel pits are complying with the law.