Sunday, March 30, 2025

wetlands worth saving

 



"When the last tree is cut, the last fish is caught, and the last river is polluted; when to breathe the air is sickening, you will realize, too late, that wealth is not in bank accounts and that you can't eat money" --- Nehiyawak Cree Nation of Canada

these wetlands are worth saving






Thursday, February 20, 2025

which America are we building for?

REPUBLISHED FROM JUNE 2024

Investing in America Agenda

Proposed first phases of a federal infrastructure project for a mega container port in Violet, Louisiana constructed around an elementary school , playground, ballpark, and existing residential neighborhoods



Full build-out over one thousand acres forested wetlands previously proposed for community park and natural areas with nature walks




Anyone else wondering if the Biden - Harris Administration's Investing in America Agenda was intended to repeat the past mistakes of further marginalizing underserved communities via federal infrastructure projects? 

Were USDOT discretionary grants meant to be the nail in coffin when funding mega container ports in the middle of existing residential districts? next to an elementary school, playground, and ball park?

Should the Investing in America Agenda include threats to local school districts to sell & relocate OR we'll just build around it?

Would any project that literally creates a physical divide and makes a fence line community from surrounding neighborhoods be considered a “shovel-worthy” goal of building an America for All?

Our State of Louisiana and our nation can progress in intermodal terminals without destroying the idyllic, rural-suburban community in Violet. Alternative business models with alternative sites and or the existing state ports working together would provide more efficient, safer means to meet business needs without creating new sacrifice zones.

DEMAND USACE conduct a Full EIS

DEMAND USDOT review its benefit cost analysis (BCA) 

NO PORT New Orleans

SOS Save Our St Bernard

https://www.facebook.com/SoStBernard/


Send Comments to: 

USACE wetlands permit application MVN-2021-00370-EG
Attn Project Manager Angelle V Greer
via email  angelle.v.greer@usace.army.mil 

LDEQ WQC application 240521-01
Attn Project Manager Elizabeth Hill
via email elizabeth.hill@la.gov

U.S. Department of Transportation - OST
Office of the Secretary
1200 New Jersey Ave, SE
Washington, DC 20590

Demand a Full EIS and BCA review on the significant adverse impact on the human habitat, including the disparate socio-economic affects and degrading public health and air quality from port pollution

Demand a public hearing and / or public meeting in Q&A format for decision makers to receive more input on the destruction of over one thousand acres forested wetlands and the irreparable damage to the community and our parish as a whole.

REFERENCE all Comments

MVN-2021-0270-EG
WQC 240521-01
OCM CUP20240330
MPDG Discretionary Grant INFRA
Board of Commissioners' Port of New Orleans

SOS Save our St Bernard

sostbernard.org

https://www.facebook.com/SoStBernard/


These wetlands are worth preserving




Tuesday, January 21, 2025

Transportation Public Meeting

The New Orleans Regional Planning Commission (RPC) Second Public Meeting as part of the Lower St Bernard Parish Roadway Network and Resilience Study
Share Analysis and Draft Study Alternatives

Date: February 4, 2025 
Time: 5:30 p.m. to 7:30 p.m.
Format: Open House – attendees are encouraged to arrive anytime between 5:30 p.m. and 7:30 p.m. and will be guided through materials and an exercise to collect feedback.  
Place: South Ballroom, Civic Center 
Address: 3220 Jean Lafitte Parkway, Chalmette, La 70043  
The subject building is ADA accessible. If you would like accessibility or language accommodation, please contact Jared Carter, the Chief Operations Officer at Desire Line, at 504-605-7158 or email TranslationSupport@Desire-Line.com.

The New Orleans Regional Planning Commission (RPC) will host a second public meeting to collect community and stakeholder input on findings and preliminary project alternatives under consideration as part of the Lower St. Bernard Parish, LA Roadway Network and Resilience Study (State Project No. H.015428). It is a "Stage 0" feasibility study aiming to identify future St. Bernard Parish transportation network improvements. The evaluation includes (1) an assessment of an anticipated Louisiana International Terminal (LIT) project network impacts and associated land use changes, (2) an evaluation of transportation related project alternatives to mitigate impacts, and (3) community input through the public engagement process.

Friday, January 10, 2025

USACE Wetlands Permit Public Notice

 

Published Dec. 16, 2024
 Expiration date: 1/15/2025
PUBLIC NOTICE AND DRAWINGS


PUBLIC COMMENT DEADLINE January 14 2025
email comments to Project Manager Shelby Barrett shelby.barrett@usace.army.mil
REFERENCE Application MVN 2021 00270 ESG

LOCATION OF WORK:  6500 E St Bernard Hwy, Violet Louisiana 
APPLICANT:  Board of Commissioners of the Port of New Orleans

Suggested Comment Form below from SOS Save Our St Bernard Group Forum

DATE:

United States Army Corps of Engineers
New Orleans District
Regulatory Division 
Eastern Evaluation Branch 
Project Manager: Shelby Barrett 
shelby.barrett@usace.army.mil 
REFERENCE Application #: MVN-2021-00270-ESG


 Please accept this letter as a response to the December 16, 2024 Public Notice related to the 
above permit application.

 Please accept this letter as a formal request for:
 1. a public hearing related to the above permit application;
 2. an extension of the public comment period of at least ninety (90) days; and
 3. the U.S. Army Corps of Engineers to conduct an Environmental Impact Statement.

Given the magnitude and complexity of the wide-spread effects of the proposed Louisiana 
International Terminal, these requests are reasonable accommodations to allow the community to 
be able to fully and meaningfully participate in this process and have their voices heard.
 
Please take note of my formal objection to the permit application referenced above.  
Below are my top five specific objections to the proposed facility:

1.
2.
3.
4.
5.

There are many more objections to the proposed facility; however, due to time constraints and 
other limitations, I am submitting only my top five objections at this time.

 Sincerely,
                                                                             
(Name and Address)


Tuesday, December 17, 2024

PBF Energy's Chalmette refinery Title V Permit Renewals

LDEQ PUBLIC NOTICES

PBF Energy's Chalmette refinery 
Title V Part 70 operating air permits 
Renewals and Modifications

1-- No 1 Crude/Coker Units
AI # 1736 Permit 3018-V7 Activity No PER20210007 
Permit Renewal and Modification for the No. Crude/Coker Units
This renewal updates emissions from the units based on the current operating data; Toxic air pollutant (TAP) emissions from the heaters are speciated.

Comments and requests for public hearings must be received by 
4:30pm Thursday, December 26, 2024 
via email to LDEQ, Public Participation Group 
deq.publicnotices@la.gov
REFERENCE AI#1376 Permit 3018-V7 Activity No PER20210007
View Proposed Permit EDMS document 14554993
https://edms.deq.louisiana.gov/app/doc/view?doc=14554993


2 --  No 1 and No 2 Flares
AI # 1736 Permit 3016-V5 Activity No PER20210014 
Permit Renewal and Modification for the No 1 and No 2 Flares
This renewal permit includes 1) updates to the emissions calculations because of updated emissions factors; 2) updates to the specific requirements are applicable; and  3) reclassify No 1 Flare Startup/Shutdown (EQT0269) as an alternate operating scenario (SCN0005).

Comments and requests for public hearings must be received by 
4:30pm  Monday December 30, 2024 via email to LDEQ, Public Participation Group deq.publicnotices@la.gov
REFERENCE AI#1376 Permit 3016-V5 Activity No PER20210014
View Proposed Permit EDMS document 14556566
https://edms.deq.louisiana.gov/app/doc/view?doc=14556566

3 -- FCC Unit and Alkylation Unit
AI# 1736 Permit 3022-V9 Activity PER20210020
Permit Renewal and Modification for the FCC Unit and Alkylation Unit
Emissions from the units were recalculated based on updated emissions factors; applicable requirements revised based on updated regulations.

Comments and requests for public hearings must be received by
4:30pm Monday, December 30, 2024 via email to LDEQ Public Participation Group
deq.publicnotices@la.gov
REFERENCE AI#1376 Permit 3022-V9 Activity PER20210020
View Proposed Permit EDMS document 14559749

4 -- HCU PT3 RF3 LEP Units
AI# 1376 Permit 3015-V6 Activity PER20210012
Permit Renewal and Modification for Hydrocracker Unit, Pretreater No 3 Unit, Reformer No 3 Unit, and Light Ends Plant (HCU PT3 RF3 LEP Units)
In addition to renewing the permit, proposes to revise/update emission factors, remove sources which were added to the PTU/RDU Units permit, segregate fugitive emissions into two source (fugitives and wastewater collection systems), remove hydrocracker splitter reboiler and revise/update for regulatory requirements.

Comments and requests for public hearings must be received by
4:30pm Monday, December 30, 2024 via email to LDEQ Public Participation Group
deq.publicnotices@la.gov
REFERENCE AI#1376 Permit 3015-V6 Activity PER20210012
View Proposed Permit EDMS document 14559745

5 -- Aromatic Units
AI# 1376 Permit 3017-V7 Activity PER20210015
Permit Renewal and Modification for Aromatics 
In addition to renewing the permit, requests to update emissions limitations of storage tanks and add hazardous air pollutant emissions limits

Comments and requests for public hearing must be received by
4:30pm Thursday, January 9, 2025 via email to LDEQ Public Participation Group
deq.publicnotices@la.gov
REFERENCE AI#1376 Permit 3017-V7 Activity PER20210015
View Proposed Permit EDMS document 14569254

6 -- Permit 2933-V8 Activity PER20210002  
Permit Renewal and Modification for No 2 Crude/Coker Units
Revise emissions based on refined calculation methods and updated emissions factors

Comments and requests for public hearing must be received by
4:30pm Thursday, January 16, 2025 via email to LDEQ Public Participation Group
deq.publicnotices@la.gov
REFERENCE AI#1376 Permit 2933-V8 Activity PER20210002
View Proposed Permit EDMS document 14572661

7 -- Permit 3011-V5 Activity PER20210008
Permit Renewal and Modification for Cat Feed Hydrotreater, No 1 Pretreater No 1 Reformer and Gasoline Hydrotreating Unit 
Update emissions rates with revised updated emission factors, and, update emissions rates and operating hours associated with increased throughput.

Comments and requests for public hearing must be received by
4:30pm Thursday, January 23, 2025 via email to LDEQ Public Participation Group
deq.publicnotices@la.gov
REFERENCE AI#1376 Permit 3011-V5 Activity PER20210008
View Proposed Permit EDMS document 14585615
https://edms.deq.louisiana.gov/app/doc/view?doc=14585615

Thursday, November 14, 2024

St Bernard Parish & Sulfur Dioxide

 



LDEQ to submit to EPA its revised State Plan for Sulfur Dioxide
Comments Due November 26th  
See LDEQ's pubic notice below

On June 2, 2010, EPA strengthened the primary National
Ambient Air Quality Standards (NAAQS) for Sulfur Dioxide (SO2).

EPA revised the primary SO2 NAAQS by establishing a new health based 1- hour standard at a level of 75 parts per billion (ppb). 

As a result, the EPA designated St. Bernard Parish as nonattainment for the new NAAQS, and the air quality in St Bernard has remained nonattainment since. 

Per a recently public noticed DRAFT revised State plan to bring air quality in St Bernard into attainment, the new air dispersion models used by LDEQ resulted in concentrations of SO2 just below the 75 ppb national standard, with the "highest total impact" reported at 74.8 ppb

With such a small margin of safety, attainment status will require strict adherence to federal air permits. The situation may be even more precarious, as this coastal parish is subjected to more frequent and intense weather events that more often result in excess emissions from shutdown, startup, and malfunction events at the major sources.

Additionally, one of the plants, Rain CII Carbon's Chalmette calciner, is often described as the "lion's share" of the sulfur dioxide emissions. Rain's Chalmette calciner has been challenged in recent years to comply with its air permit's requirement to demonstrate compliance through stack testing. Reportedly, the testing probes were prone to melting under the high temperatures at the stack. 

The focus of the revisions to the SIP for SO2 heavily rely on the Rain CII calciner's ability to comply with a new air permit in an Administrative Order of Consent (AOC) between LDEQ and Rain CII Carbon LLC - Chalmette. The AOC is located in Appendix D of the DRAFT SIP; it has not yet posted to Rain's EDMS files, nor has it pubic noticed in the local newspaper.

The modeled impact for the SO2 SIP revision is based on Rain's waste heat boiler operated at a 900 pound per hour rate. We are completely dependent on LDEQ and EPA to get this right and to ensure compliance with air permits in our parish. They've had plenty of time since the 2010 Standard was established, and meanwhile, public health in our community has suffered.



PUBLIC NOTICE  
The Secretary of Louisiana Department of Environmental Quality (LDEQ) published a public notice in the Louisiana Register that the Office of Environmental Assessment, Air Planning
and Assessment Division, will submit to the Environmental
Protection Agency (EPA) a revision to the Louisiana State
Implementation Plan (SIP) for sulfur dioxide. 
(2410Pot3 located at 1592 or page 176 of link https://www.doa.la.gov/media/3xcacocu/2410.pdf )

The revision is available for review via LDEQ’s electronic
document management service (EDMS), AI# 174156
document number 14513604 dated 10/18/2024
https://edms.deq.louisiana.gov/app/doc/view?doc=14513604

or at LDEQ Headquarters, 602 North 5th Street in Baton Rouge

The SIP revision will implement standards required by the Clean Air Act for the nonattainment area. All interested persons may submit written comments concerning the revision no later than 4:30 p.m., Tuesday, November 26, 2024, to Arlys Dalton, Office of Environmental Assessment, P.O. Box 4314, Baton Rouge, LA. 70821-4314, or by E-mail at arlys.dalton@la.gov


Friday, September 6, 2024

EPA EJScreen Mapping Tools Update

 

Use this EPA EJScreen mapping tool to help identify environmental issues and areas that are disproportionately affected.

https://www.youtube.com/watch?v=HZp3AWDJt5A

https://www.epa.gov/ejscreen

Launch the EJScreen tool  https://ejscreen.epa.gov/mapper/

The map includes 13 Environmental Burden indicators on air quality or proximity to pollution sources. 

Under the Socioeconomic indicators tab, the first indicator is the Demographic index which includes two factors: low income and people of color. The second is Supplemental Demographic index, which includes low income, person with disabilities, education less than high school, limited English speaking, and low life expectancy. There are other Socioeconomic indicators such as, under age 5 and over age 64.

Looking at the Socioeconomic indicators together or individually will help identify socioeconomic issues the community might already be experiencing, and how susceptible the community might be to the environmental burdens.

There are supplemental indexes which combine the environmental and socioeconomic indicators; the intention of these indexes is to show where both environmental and socioeconomic conditions are disproportionately high. There are also indexes that show health disparities, climate related burdens, and, critical service gaps.

The map and indexes can be printed or shared in a pdf report.

Such reports could help decision makers better protect public health, safety, wellbeing, and quality of life in the communities they represent.

As an example:

In St Bernard Parish, the residential district around the Will Smith, Jr Elementary School, has a high national percentile of both the population under age 5 and the population over age 64.




Residents in Violet, Louisiana already experience low life expectancy, as indicated by the 90 to 95 national percentile.  



Currently, this residential district is subjected to diesel exhaust (NATA diesel PM) and PM2.5 particulate matter pollution above the national percentile 80 to 90 percent; some areas are exposed to these pollutants at the 90 to 95 national percentile. Each of these pollutants, diesel exhaust and PM2.5 particulate matter, are known lung carcinogens. Diesel exhaust and PM2.5 reduce lung function growth in children, are linked to premature death, and are linked higher risk to other cancers, including breast, liver, and lymphohematopoietic malignancies. 


 






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