The EPA is accepting public comments on the designation of St Bernard Parish as non-attainment for sulfur dioxide.
Comment deadline is Jan 13 2022
More information and to submit comments at link
https://www.federalregister.gov/documents/2021/12/28/2021-27934/finding-of-failure-to-attain-the-primary-2010-one-hour-sulfur-dioxide-standard-for-the-st-bernard
Council Meeting
January 4 2022
around the 28 minute mark in the video
https://sbpg.viebit.com/player.php?hash=IKrTfySE7wpD
paraphrasing some council members
anybody who's worked on a port knows the amount of traffic that exists for a port
and anyone who's worked on a port knowns the congestion that exists on a port
and recognizing that there was going to be a very strong - to put it lightly - push to bring this complex to St Bernard Parish
the first thing said [to the port ] was we don't have the infrastructure to support this
we don't even have near the infrastructure to support this
and the council member asked the port for a very specific piece of infrastructure if the port was even going to consider it
The port was told they needed to create "Florida Avenue" with road and rail all the way from Florida Avenue (in New Orleans) to the back side of the proposed project in Violet, St Bernard Parish if this was even going to be a consideration by the council member
And there's a good reason for that
Because the rail roads in St Bernard Parish go through our neighborhoods
So the homes that people buy, the rail roads and the trains go right next door to the houses, rattle the homes when the trains pass at night
And if you think we have rail traffic now, the magnitude upon which the port is talking about bringing to St Bernard Parish and the size of this container terminal would be laughable
Your talking about absolute gridlock crossing our highways
Gridlock through our neighborhoods
You would never be able to sleep
And that's just with the current rail traffic that we have now
And I respect the business opinion that I'm assuming some of the people here that are in support of the port are going to speak about
With that said, this would be an absolute tragedy if it were built as is
And I asked the port to go into the environmental study first on the infrastructure
First !
Don't buy the property first, don't do the other environmental first, don't rail road it down our throats first
Go to infrastructure first
That's not what has happened here
The port has done everything in opposition here from what the council member asked
Which means
--- in some's opinion could be a great amenity and potential economic catalyst in St Bernard Parish
but for this council member
-- It would be a great detriment because we do not -- contrary to what the port says -- have the infrastructure to support this
Not even close
S O S Save Our St Bernard
https://sostbernard.org/
EPA extends time for public comments on declaring St. Bernard's air quality out of compliance
Public comments now due by Jan. 13
Public comments on the EPA's proposed declaration of noncompliance may be filed until Jan. 13 2022 via regulations.gov, by citing Docket No. EPA-R06-OAR-2017-0558 or at this link https://www.federalregister.gov/documents/2021/12/28/2021-27934/finding-of-failure-to-attain-the-primary-2010-one-hour-sulfur-dioxide-standard-for-the-st-bernard
In August 2021, the St. Bernard Parish Council voted unanimously to oppose Port NOLA's proposal in Violet, Louisiana.
In December 2021, residents sued to preserve our community.
“Port NOLA is running roughshod over our community, completely disregarding the people who live here to force their massive container terminal on us,” said attorney Sidney Torres, III. “Literally millions of containers will be unloaded in our small town, destroying our way of life, endangering public health, damaging the environment, and decimating the economy.”
“Adding insult to injury is that there are more suitable locations that would make Louisiana more competitive, but these locations are being ignored because they fall outside of Port NOLA’s jurisdiction. It’s an age-old story of parochialism and greed, and it’s bad for the people of St. Bernard and the entire state,” he continued.
"Don't be surprised if this is the first you're heard of this. You might ask whatever happened to community engagement. Many people in St. Bernard are also just learning of the plan. Many did, however, turn out to convince the St. Bernard Parish Council to vote unanimously against this site."
"One thing is clear. This is another time when New Orleans is serving as the canary in the mines. As infrastructure plans go forward across the country, communities will need to be vigilant to the possible community and destroying impacts if the planning does not respect them."
The dark side of the coming infrastructure boom
By Jeanne Nathan, Crosstown Conversations N.E.W.S.
According to the Federal Registry The Environmental Protection Agency (EPA) is proposing to determine that the St. Bernard Parish sulfur dioxide (SO2) nonattainment area (“St. Bernard area” or “area”) failed to attain the primary 2010 one-hour SO2 national ambient air quality standard (NAAQS) under the Clean Air Act (CAA or the Act) by the applicable attainment date of October 4, 2018.
Submit public comments here on EPA's findings on sulfur dioxide concentrations in St Bernard Parish:
Given the lack of space between the plants and the neighborhoods, EPA should require stricter measures for lower emissions at all sources of sulfur dioxide and particulate matter in St Bernard Parish.
The combination of high PM and SO2 concentrations can be deadly.
According to the University of Massachusetts Political Economy Research Institute tool:
Chalmette Elementary, a school with 71% minority enrollment in St Bernard Parish, is in the 3rd percentile for air quality and Martin Luther King Charter school, a school with 100% minority enrollment in the Lower 9th Ward of Orleans Parish, is in the10th percentile for air quality. That's the environment the LDEQ and U S Senator Cassidy compromised when they convinced EPA to delay enforcement action. That's the environment the LDEQ and Senator Cassidy provided for our school children; that environment is in the 97% and 90% percentiles for WORSE air quality in our nation.
Its past time for EPA to step in and step it up.
The neighborhoods near Rain Carbon CII and PBF Energy's Chalmette Refining LLC are exposed to large amounts of particulate matter and according to the EPA EJSCREEN Map Tool, some neighborhoods are in the 95 to 100% National and State percentile NATA diesel particulate matter.
EPA should protect what good air is left in our communities and conduct both a human health risk assessment and a cumulative impact analysis for the human environments within ten miles of each site of heavy industry in St Bernard Parish; not just for sulfur dioxide, but for all emissions. EPA should consider in St Bernard Parish delay of issuance of all Title V air permits (initial, renewal, and or modification) until the analyses data are reviewed and required improvements incorporated in the air permits.
Given the numerous health and odor complaints from residents in Lower Algiers, Holy Cross, and Lower Ninth Ward neighborhoods in New Orleans, EPA should also consider that the SO2 attainment modeling data will and should designate Orleans Parish non-attainment for the one-hour health standard for SO2. Without such designations, LDEQ will not require lower emissions. The LDEQ air quality monitor network is not robust and has only 29 monitors for the entire State. EPA should consider this lack of appropriate monitoring does not prove an exceedance of the air standard can not occur. EPA should at least consider requiring LDEQ re-install the previous "Entergy" site air monitor in Lower Algiers New Orleans, across the river from Chalmette, and the previous "Arabi site air monitor or a new site monitor in the Holy Cross or Lower Ninth Ward neighborhoods.
EPA should also consider air modeling will and should designate St Bernard Parish non-attainment for particulate matter PM10 and PM2.5 levels.
Innovations in control technology business practices are always evolving and improving and have proven protective of public health and air quality. EPA should require implementation of the best technologies and business practices in both St Bernard and Orleans Parishes. EPA should require LDEQ update its State Ambient Air Standards [AAS] for air toxins, as standards should be reviewed periodically and improved as technology and best business practices improve. When was the last time Louisiana reviewed and improved its air standards?
When EPA conducts these air modeling dispersion studies, all sources should be included. Since the last time St Bernard Parish was designated non-attainment for the one-hour health standard for sulfur dioxide, major sources have re-started previously idled units, which were not likely included in the Louisiana SIP (state implementation plan) to improve air quality. One example is the additional coker unit at PBF Energy's Chalmette Refining LLC which restarted in 2018 for the first time in nine years. PBF Energy's Chalmette Refining LLC recently applied for an initial Title V Part 70 operating air permit for a proposed renewable diesel unit, and citizens who participated in the public comment opportunity for the renewable diesel unit found the application lacked modeling data, and the EAS to be insufficient, incomplete, and not even included in the LDEQ public notice link. [1]
Submit public comments here on EPA's findings on sulfur dioxide concentrations in St Bernard Parish:
[1] https://edms.deq.louisiana.gov/app/doc/view?doc=13032248
https://edms.deq.louisiana.gov/app/doc/view?doc=12993977
From cancer alley to diesel death zones, land use decisions in Louisiana fail to protect the human habitat
It seems the Louisiana Department of Environmental Quality and U S Senator Cassidy are not interested in protecting the human environment in Chalmette and Lower 9th ward and Lower Algiers.
Rain Carbon CII operated for years, spewing out sulfur dioxide in quantities so large that when combined with the emissions from other plants, the air quality in St Bernard Parish violates the one-hour health standard for sulfur dioxide. Rain CII acknowledged it was the source of the "lion's share of emissions." St Bernard Parish was designated non-attainment for sulfur dioxide and the State of Louisiana was finally required to ratchet down emissions through a “state implementation plan” which required all major sources of sulfur dioxide install more stringent control technologies and change processes to improve air quality. https://www.regulations.gov/document/EPA-R06-OAR-2017-0558-0038
"Rain balked, however, saying it was having trouble figuring out how to monitor the heat and flow of gases and other materials at its plant because conventional meters kept melting. In 2019, U.S. Sen. Bill Cassidy, R-La., intervened on behalf of the company and joined the state agency in successfully lobbying the EPA to delay implementation of the plan." NOLA Environmental News Tristan Baurick
