ACTION ALERT! Speak Up for Clean Air
Date: Nov. 20, 2017
To: All League Members and Oregonians
From: Norman Turrill, LWVOR President;
Marilyn Koenitzer, LWVOR Air Quality Portfolio
League of Women Voters of Oregon
ACTION ALERT! WE NEED YOUR SUPPORT!
Speak Up for Clean Air
Since 1968, LWVOR has been a voice on behalf of air quality “…in support of Adequate standards for control of all sources of pollution and strict enforcement of established rules and regulations; A comprehensive, coordinated program for management of air as a natural resource; Adequate financing for air pollution abatement programs…”.
The Environmental Quality Commission is considering new draft regulations to address Oregon’s air quality. You can find complete materials at cleanerair.oregon.gov, including an updated rule guide to help explain each section of the proposal and draft tables for how the rules would be implemented among businesses. The draft rules are ready for comment now until December 22, 2017. YOUR VOICE IS NEEDED.
Action Needed: We need League members to testify either in writing or orally at one of public hearings scheduled around the state. Two paragraphs, one about your story of how dirty air affects you and your family and a paragraph supporting strong air health and science based regulations would help get us cleaner air. If you feel comfortable, you can comment about specific sections of the draft rules and tables. But a voice for urgent implementation is needed.
Here are some important points you can make: The first chart in the Draft Rules Tables gives you important numbers for the amount of allowable emissions for various categories of emissions sources. The draft rules have different requirements depending on whether or not a facility is a new or existing facility.
For existing facilities, the draft proposes a risk action level of 25 in a million (cancer risk), the same risk action level that California uses for existing sources. (Our previous Alert was in error.) For new sources, the draft proposes a risk action level of 10 as opposed to 25 for existing sources. For new sources, the draft proposes a permit denial risk action level of 50 excess cancer risk per million as opposed to 500 excess cancer risk per million for existing sources.
Existing facilities whose emissions exceed 25 in a million excess cancer risk will need to reduce risks to below that number, unless they are already using all the best controls possible. If they are using the best controls, they may be allowed to operate over 25 if certain conditions are met. That allowance to operate above the Risk Action level is also not indefinite. If they have the best controls and want to operate over 100 in a million, it must be approved through a Director Consultation process, triggering consultations with Oregon Health Authority, local elected officials, and local impacted community. The League has concerns with any allowances over 25 in a million. Operating over 100 in a million, even with a public process, does not meet our view of “health-based” regulations. We do note that, under current rules, emissions that cause an “imminent threat” (unlike long term cancer risk) to public health can be immediately addressed.
Although we recognize that no other state has a “Risk Action Level cap” proposed in the rules (of 500 in a million cancer risk) and we commend that concept, we believe that this risk ceiling is too high. We continue to ask for rules that are grounded in science, informed by data and health-based.
The timeline to bring all companies under the Cleaner Air Oregon tent is too long. Only 80 of Oregon’s over 2,500 companies will be included in the first five years. The Department of Environmental Quality has not gotten enough funding to hire necessary personnel to enact the new rules or to finish a vital statewide emissions inventory. Cleaner Air Oregon cannot happen without funding and political will.
The League believes that progress has been made with this draft to cover areas of air quality that haven’t been regulated, but more needs to be done. The rules need to be grounded in science, informed by data and health-based. And the work needs to be funded in order to meet those standards.
Attend one or more statewide public hearings listed below.
Hearing 1 – Medford
Wednesday Nov. 15, 2017, 5:30 p.m. – 7:30 p.m.
Hearing 2 – Coos Bay
Thursday Nov. 16, 2017, 5:30 p.m. – 7:30 p.m.
Hearing 3 – Corvallis
Monday Nov. 20, 2017, 5:30 p.m. – 8 p.m.
Hearing 4 – Pendleton
Tuesday Nov. 28, 2017, 5:30 p.m. – 7:30 p.m.
Hearing 5 – Portland
Wednesday Nov. 29, 2017, 5:30 p.m. – 9:30 p.m.
Hearing 6 – Portland
Saturday Dec. 2, 2017, 10 a.m. – 3 p.m.
Thursday Dec. 7, 2017, 5:30 p.m. – 8 p.m.
Location TBDHearing 8 – Salem, in conjunction with the Environmental Justice Task Force
Friday, Dec. 8, 2017, 9 a.m. – 11 a.m.
If you have any questions please contact Marilyn Koenitzer @ firstname.lastname@example.org or LWVOR at email@example.com.