I think it would be nice to provide comments to the State Implementation
Plan (SIP) on behalf of HREG. We should suggest the role of renewable
energy in helping to clean the air in our region. Please read the notice
below. I will draft some comments by February 8. I attended some of the
RAQPC On Road Task Force meetings, and have written materials relating to
vehicles and emission control measures. I can fax info upon request.
Comment letters DUE February 14.
Jonathan A. Clemens
>From: Frank Blake <frankblake@...>
>Reply-To: Frank Blake <frankblake@...>
>Subject: PRIORITY Clean Air Letter Action
>Date: Tue, 1 Feb 2000 20:33:27 -0600
>Houston Sierra Club Alert: E-mail letter action!
>SPEAK UP NOW FOR CLEAN AIR OR FOREVER HOLD YOUR BREATH!!
>It is VITALLY important for Houston Citizens to speak out NOW for clean
>VOICE your support for a strong State Implementation Plan (SIP) that will
>lead to a reduction in air pollution!
>The Houston Sierra Club website now features an electronic letter which you
>can email directly to the Texas Natural Resource Conservation Commission
>(TNRCC), which is currently taking public comment. Go to:
>The above letter can be modified with your own comments.
>NOTE: COMMENT LETTERS MUST BE SUBMITTED BY 5PM, FEB. 14.
>Please CIRCULATE this information to others!
>It is vitally important that we demonstrate public support for cleaner air.
>You may also submit WRITTEN COMMENTS to:
>Lola Brown, TNRCC, Office of Environmental Policy, Analysis, and Assessment
>P.O. Box 13087Austin, TX 78711-3089
>(Note: COMMENTS DUE BY 2/14/00)
>Please make the following points in your comments. TNRCC must:
>1. Demand 90% NOx reduction from industrial, commercial, utility, and
>institutional combustion sources (like boilers and furnaces) in HGA and all
>of East Texas (this is the only way that the HGA will get into national
>compliance for ozone pollution).
>2. Require that industrial sources make additional cuts in emissions,
>� More stringently enforce leak detection programs for valves and similar
>� Audit grandfathered plants (those that were built before 1971 and have
>no major modifications and/or increase in emissions). We believe many
>are defining themselves as "grandfathered" to escape pollution regulations.
>� Require an "upset" emissions reduction plan to reduce unauthorized
>industry air pollution (either due to operational issues, or mistakes,
>We also need to ensure that these "upsets" are included in the TNRCC
>� Require better detection of evaporation emissions from storage tanks or
>� Require LAER pollution control technology (lowest achievable emissions
>rates, the best control technology in the nation) for our area.
>3. Submit a State Implementation Plan on 12/31/00 with all air pollution
>control rules adopted. EPA must NOT give TNRCC another 7 months (7/31/2001)
>to submit adopted rules. TNRCC has already missed the clean air plan
>deadline by 4 years.
>4. Demonstrate clearly through air modeling HOW HGA will meet the ozone
>standard by 2007. No "weight-of-evidence" analysis should be allowed to
>that the ozone standard would be reached by 2007.
>5. Commit NOW to implement pollution control measures that will ensure the
>HGA reaches attainment of the ozone standard by 2007. (TNRCC should not be
>allowed to delay until 12/31/2000).
>6. Implement California standards for cars, trucks, SUVs, diesel engines,
>and sulfur in diesel and gasoline fuels. Now that NY and CA are requiring
>more stringent standards, automobile companies would be forced to make low
>emissions vehicles on a national level. This could reduce NOx emissions by
>25% if adopted. This would cost about $107 per car and $209 per truck.
>For additional information, contact Gavin Dillingham,
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