Breathing Easy About New Air Pollution Standards

Part III: PUBLIC COMMENTS

by
Kathryn Rowberg
Department of Chemistry
Purdue University Calumet


Town Spokesperson: Comments and suggestions will be taken now from the community regarding NOx emission reduction. Please introduce yourself and state your affiliation, if any.

Small Coal-Burning Power Plant Representative (no NOx controls installed): The price of electricity in Indiana is 5.3 cents per kilowatt-hour, which is around half of that of the East Coast, where the price ranges from 9.5 to 11.5 cents per kilowatt-hour. Our plant strained to spend millions of dollars installing flue gas scrubbers to reduce SOx emissions significantly and did so without a large increase in the cost of electricity. Since we have completed the installation of the SOx scrubbers, we would have to invest in additional technology to reduce NOx emissions that will require several additional millions.

This cost cannot be absorbed by the plant after our recent investment and will cause drastic electricity price increases. Many homeowners are already on tight budgets and should not shoulder the cost when electricity-generating plants are not the largest source of NOx. In addition, the higher cost of electricity will discourage new businesses and expansion of existing firms. That will hurt job creation and wage growth.

Although electric plants are not mobile and therefore are easier to target for restrictions, consider that utilities contribute less than one-third of the NOx problem nationally. The burden of NOx reduction should be spread around and not just targeted to electric utilities and cement kilns.

Large Coal-Burning Power Plant Representative (NOx controls installed): Although our utility has already made significant efforts to reduce NOx emissions, in light of the current situation, some NOx reductions from electric utilities are reasonable. The utility industry has endorsed a statewide, annual average NOx emission rate. We believe that all electric utilities should have the same allowed NOx emission rate that we have achieved with our NOx controls.

Driver's Union Representative: If the numbers from the EPA are lumped together, we see that 49 percent of the problem comes from transportation and 46 percent comes from utilities and industries. That is nearly even. It seems everyone should participate in reducing emissions. The city could create a bus and train rapid transit system, and people could be rewarded for carpooling or commuting to work using rapid transit. We have needed a regional transportation system for a long time and we now have a tremendous incentive to create one.

Irate Resident: Why should we have to pay for any of this? The majority of our traffic is trucks--just look at the expressway! We should require all those trucks to pay for their pollution. Also, think of how much pollution comes from Chicago! We are choking on her exhaust and emissions. Chicago should have to clean up its act first so smaller towns can determine if we are even part of the problem.

Cement Kiln Representative: I represent a large cement kiln far from any of the ozone nonattainment regions in Indiana. The cement industry has investigated reducing NOx emissions, but there are very few options for kiln operators to employ. Most of the new technology to control NOx emission has been developed for boilers and doesn't apply to kilns.

I can represent one and only one cement kiln because every cement kiln is unique in its process technology. Any NOx control technology that might be developed for my plant probably wouldn't work at another plant. It is unrealistic to specify one control technology for all cement kilns and impractical to develop different technologies for each cement kiln. An alternative approach is to allow each cement kiln autonomy to determine how best to reduce NOx emissions. A less flexible approach might reduce competitiveness and product quality at smaller kilns.

National Trucking Association Representative: Heavy duty diesel and gas trucks are mistakenly thought of as dirty. In recent years, engine technology and good maintenance have created a fleet of clean trucks used in long-distance hauling. In fact, 47 percent of NOx mobile emissions comes from cars and light duty trucks (SUVs), while only 18 percent comes from heavy-duty diesel trucks and buses. Furthermore, 30 percent of NOx mobile emission comes from off-highway diesel equipment like the equipment used in the endless road and building construction. The emissions from airports aren't even considered, although we are contemplating enlarging the airport.

Doubting Resident: How can we be sure of all this information. I can't even see NOx, so I'm not sure they're even there. My health is just fine. Every week I read about some new scare in the newspaper and the next week people are laughing about the incident. And what about all the mathematical models predicting how much we need to reduce NOx. Models are just that--models. They are not reality. How can we be sure that we truly need to go to this expense for something that isn't visible and for some predictions based on models?

Industry Lawyer: Petitions for review have been filed in federal court to challenge the EPA's action in promulgating the new ozone standards. The two major concerns are whether an "intelligible principle" was used to set the new standard for ozone and whether EPA's adoption of the new standards is within constitutional bounds. The United States Court of Appeals blocked the EPA from enforcing the new standard. The Supreme Court has agreed to examine these issues and will likely rule on them next year.

Therefore, IDEM should take care to avoid submitting a SIP based on these unaccepted stringent ozone standards. If the new ozone standard is not upheld in court, the state will likely still be held to any NOx SIP based on them. The SIP should state that Indiana's plan implements current federal laws and standards, not EPA standards, which are not upheld in court.

Business Leader: My small business is in the process of expanding and I don't need surprises. I want to be involved in the decisions being made, and I would like to be a leader in ensuring clean air for our residents and for future generations, but I need to establish my business first. If reductions are implemented across the board for all businesses, I won't be able to expand. How can I help our community if I can't get my feet on the ground?

High School Guidance Counselor: The EPA is making the assumption that our most pressing concern at this time is ground-level ozone and NOx pollution. However, if you look at the top causes of deaths to our children in this region, it is not air pollution, it is violent crime and automobile accidents. Can our community address the issues that are most pressing instead of simply responding to what the federal government mandates to be important?

Town Spokesperson: Thank you all for your valuable comments. We have recorded them for further study. Now it is time for us to determine which NOx emission sources to control. IDEM will determine the reductions for each source. Please speak up as to which sources you would like to be included and then everyone will have up to four votes. No more than one vote may be given to any one source. The votes will be tabulated and the sources listed in order of total votes and used by IDEM to create the NOx State Implementation Plan.