Your public comments CAN and WILL make a difference. There WERE changes made to GCGV’s industrial wastewater permit in response to comments.
So, why submit public comment? Because you care about the air you breathe, you care about the health of your neighbors and children, you or a loved one have asthma and other respiratory problems, and cancer-causing emissions are permitted (see our prior post on what emissions are allowed). Any public comments you make will require a written response from TCEQ.
You may have thought about what you might say. Others may wonder what I can say to the TCEQ.
First, you do not have to be technical or cite regulations; e.g. I have lived here for years and don’t want this plant here; my son (or mom) has asthma [or other health conditions] and the emissions will affect his/her health; I am now surrounded by industry, these combined emissions will affect health; Our region is close to non-attainment in air quality standards (ozone), how will almost 3 million tons of greenhouse gases per year affect us?; I have asthma and the emissions would send me to the Emergency Room and I don’t get sick leave so that would cost me my job or “I have only one set of lungs”.
Over the past 18 months, we have provided many reasons to oppose this facility. These are simply a summary of some thoughts to express in your public comments.
- We already have heavy industry to our east; now, it will be on our west. While the total emissions for this single plant are being assessed, the air quality will be lessened because of the existence of other industries within two or three miles of each other. And it is the same population that will be impacted by all. Additionally, it does little to alleviate air quality concerns, to have TCEQ consider and make decisions on each of these plants separately, without also providing a cumulative air quality impact analysis for the entire north bay area.
- The location is too close to the high school, middle school, and Austin Elementary
- The permit allows the release of sulfuric acid mist and particulate matter that is small enough to enter the lungs in a single breath.
- Sulfuric acid mist would degrade the local estuaries, parks, beaches, and fishing that depend on the seagrasses (for clean air and water) to support them as necessary eco-infrastructure. In view of the linking reactions of air and water with an added mixture of hazardous pollutants that will be emitted, I request that the air and water permits be co-joined. The air quality permit should not stand alone and neither should the water permit stand alone. Both of these permits should be combined for a total evaluation due to the fragile ecosystem that supports our area. The seagrasses on the coast are dwindling due to heavy industrialization by petrochemical industries and our area depends on the seagrasses for income and quality of life for our communities.
- How were mobile source air toxins coming from increased automobile and diesel traffic, a thousand railcars, taken onto account?
- Whether you live next door, upwind, or downwind, you will be affected. The winds will blow emissions over Portland 30% of the time every year, 51% in December and 53% in January alone. Taft will get it the rest of the year. And calm days, it will simply hover over us.
- Water use of 7.3 Billion gallons a year will create adverse health and safety during drought. All seven counties that rely on the water Exxon will use are in a Moderate Drought as of May 15, 2018.
- Flooding nuisance from stormwater runoff will affect health and safety
- Railcars nuisance will affect health and safety
- The polyethylene pellets cannot be contained using best management practices and will disperse into our streams, mudflats, estuaries and bays to be consumed by fish and birds, and will negatively impact endangered species such as the red knot, piping plover, and whooping crane
- This facility is being built primarily to produce plastics. The world is saturated with plastics and the only reason to build another petrochemical plant is profits, at the expense of our lands and oceans.
- If built, this facility will generate industrial effluent at temperatures of 110 degrees, 15 degrees higher than allowed
- If built, this facility will be the first industrial facility to send process and equipment stormwater runoff and pellets into Copano Bay
- Emission limits are excessive and need to be lowered especially for cancer-causing pollutants like benzene and formaldehyde
- The permit does not take into account the impact of the heavy haul road that GCGV has to build in order to bring in the components to build the facility; a heavy haul road that cuts right through our communities and directly behind homes in Bay Ridge
- Several thousands of existing jobs will be threatened by massive industrialization and pollution; Fishermen, oystermen, shrimpers and beach and nature tourism depend on clean air, clean water and a high-quality fish and wildlife habitat
- The project would be damaging aesthetically, environmentally and economically, detrimental to tourism and the recreational fishing industry and threatening to health and safety.
Ready to submit a public comment? Visit our QUICK GUIDE | Submitting a Public Comment to the TCEQ page to get started.
Below you will find a comment submitted to TCEQs website. As you can see, your comments do not have to be technical or cite regulations. Let them know how you will be impacted.
I am an avid outdoor recreation enthusiast (birding, fishing, paddle sports, biking, hiking, etc.) My wife and I chose to become residents in Portland, Texas because of the Aransas National Wildlife Refuge, the rich wildlife and habitat diversity, climate, friendly residents, affordability, laid-back lifestyle. Our home and community will be susceptible to the effects and health risks of all airborne emissions and pollutants emitted from this facility. Both children and elderly are especially susceptible to airborne pollutants. The health and safety of thousands of annual visitors and countless flora and fauna is also of great concern considering the known and unknown health risks from air pollution.
Birding is a major part of local revenue stream as the area is an internationally known destination for birders due to the geographic location, diversity of habitats, pristine wetlands and convergence of two major bird migration routes. Any disruption such as increased air pollution or flaring on the magnitude of this facility would have serious impacts on ecotourism. Granting this permit will compound a decline in ecotourism and upsetting a way of life and quality of life in the area.
Our area is home to numerous species, many of which are endangered, threatened, or special status species. The habitats found within our estuaries are considered one of the most biologically diverse regions in North America including federally listed endangered or threatened animal species and state listed species, including the red knot, piping plover, whooping crane, Kemp’s Ridley sea turtle. Granting this permit will significantly increase the negative known and unknown impacts of this wildlife rich area.
Globally: In south Texas and around the world, wildlife and natural ecosystems (terrestrial, fresh water and marine) are the voiceless victims of human development, including airborne pollutants. Worldwide, with few exceptions, wildlife populations of most species are in rapid decline. Scientists refer to this decline as the Sixth Major Extinction since life on Earth began, the undeniable result of human activity. A major contributor to this worldwide decline is global warming, the result of airborne emissions from the use of fossil fuels. The entire process, from exploration and extraction of fossil fuels to their delivery, refining, compressing, and burning contributes significantly to global warming and its worldwide consequences to life on Earth.
Maximum Achievable Control Technology is “economically reasonable” to install in every facet of operations to reduce emissions. Due to the enormity of emissions, economics should not disway protecting my health.
Finally, we will share excerpts of one comment submitted to TCEQs website to further illustrate the range of impacts and to demonstrate how one individual considered the impacts on Taft.
I am expressing my concerns over the operation of this facility; specifically, the emissions proposed to be released and the manner they will be introduced into the atmosphere. Agriculture is Taft’s main industry and it produces row crops such as grain sorghum, corn, and cotton. Amongst these vast farm fields are close to 200 wind energy turbines that are managed by E. ON known as the Papalote Creek Wind Farm. Taft main populous consists of small business owners, middle class workers, retirees, and children. It is a small town, but it has a very active and important role in the economic establishment along the Coastal Bend. The wind rose chart available from NOAA has Taft in the direct prevailing SE winds coming from off the coast which has created a concern for this community.
A recent news article in the Texas Tribune reports about a Federal Judge had ruled that the same entity that makes up 50% of GCGV Asset Holding, ExxonMobil, had illegally and intentionally emitted over a 5 year period hazardous chemicals and other contaminants from its Baytown Facility in April 2017. Additionally, in 2016 an ExxonMobil refinery located in Beaumont, TX exploded and released hazardous bi-products from the fire into the atmosphere and caused the deaths of several workers. There have been multiple other tragic events the has originated at ExxonMobil facilities just in the past 5 years such as the incident in Torrance, CA, the broken pipeline near Little Rock, AR, and an another incident at the Beaumont Refinery. These events as well as the recent ruling supports and only adds to this concern.
Emissions released from this facility has the potential to degrade the air that travels from this facility by the prevailing SE winds of Taft. The application did not address the height or distance of the emissions travels in the atmosphere. The first thing the emissions will encounter is the wind farm. Over time the emitted corrosives may cumulatively inflict harmful damage by to the metallic turbines by mixing with the very humid air and causing corrosion which ultimately would cause failure. This would make the agriculture fields unsafe for the local farmers to work which in turn would cripple the main industries in Taft.
The lack of information over how the emissions travel also cause concerns for the children in the community. Just past the wind farm facility is the juvenile center and elementary school. Given the simple chemistry of the emissions released one must understand that these chemicals do weigh more than oxygen. The emissions would sink low enough in the breathable air and may eventually cause health related impairments. ExxonMobil has a reputation of denying this (e.g., the Baytown Facility); however; the recent ruling on that facility and the growing health problems of the surrounding community provides evidence that the emissions may potentially inflict new health concerns in Taft.
As the emissions travel over Taft, it is also introduced into our water supply. There are several streams listed on the TCEQ 303d list that occupy San Patricio County, including Papalote Creek. This facility will only add to the contaminants released into the watershed and will only further degrade water quality which is of National Importance. Our port is amongst the biggest in the nation and if water quality degrades further we will ultimately see lees commerce shipped from this area impacting our local economy. Degraded water will also impact the amount of crops Taft can produce which would adversely impact this town. Furthermore, the impact of poor water quality on the human environment and taking into consideration the history of ExxonMobil, it should be considered extremely detrimental; however, we can only state that it would be detrimental as no base data from this facility exists other than hypothetical mathematical and chemical equations.
The proposed monitoring is insufficient. Monitoring should be conducted within a 15 mile radius. With modern technology GCGV should install several monitors in the Papalote Wind Farm that stream real time air quality data to a centralized database that can be accessed by TCEQ at any given time. Additionally, air monitors should be installed throughout Taft, especially near schools and on top of the water tower, that stream the exact air quality data to the same database. This should be implemented throughout the suggested monitoring radius.
Ready to submit a public comment? Visit our QUICK GUIDE | Submitting a Public Comment to the TCEQ page to get started.