Clean Air Council Testimony regarding S02 emissions from Portland Generating Station
TESTIMONY OF CLEAN AIR COUNCIL REGARDING RESPONSE TO PETITION FROM NEW JERSEY REGARDING SO2 EMISSIONS FROM THE PORTLAND GENERATING STATION, DOCKET ID No. EPA-HQ-OAR-2011-0081.
April 27, 2011
Oxford, Warren County, New Jersey, 07863
Good Afternoon,
My name is Katie Feeney and I am the Global Warming Policy Analyst for Clean Air Council in Philadelphia. The Council works through public education, community advocacy, and government oversight to ensure enforcement of environmental laws. The Council works primarily in Pennsylvania, New Jersey and Delaware where most of our members live. For more than 40 years, the Council has fought to improve the air quality in the Greater Philadelphia area, across Pennsylvania and the Mid-Atlantic region. The Council’s mission is to protect everyone’s right to breathe clean air. Specifically, Clean Air Council’s air toxics work is multi-pronged and includes advocating tighter laws for facilities that release toxics into the environment; taking legal action to force toxics reductions; and educating policy makers and the public about the threat from air toxics and existing solutions.
I am happy to have the opportunity to voice the Council’s support for EPA’s proposed finding that the coal-fired Portland Generating Station in Upper Mount Bethel Township, Pennsylvania, is emitting air pollutants in violation of the interstate transport provisions of the Clean Air Act. These violations are significantly contributing to nonattainment and interfering with the 1-hour SO2 national ambient air quality standard (NAAQS) in New Jersey. It is vital that the United States Environmental Protection Agency take proactive measures to ensure that the Portland Plant quickly remedy its emissions problems or otherwise close down with renewable sources of energy established in its stead.
The emissions from Portland are clearly a problem for both New Jersey and Pennsylvania. Portland emits up to triple the amount of SO2 that all seven coal units combined in New Jersey emit. According to a 2009 EIP study, Portland ranks fifth in the country for SO2 emissions, measured in lbs/MWh. The advocacy group Clean Air Task Force says pollution from coal-burning power plants will cause over 500 deaths in New Jersey this year alone.
The proposed reductions in sulfur dioxide from the Portland Plant will benefit the environment and benefit public health. Fossil fuel combustion at power plants just like Portland is responsible for the majority of SO2 emissions. SO2 is a major precursor of acid rain and fine particulate soot. SO2 emissions and their mixture with other pollutants to form fine particulates cause adverse respiratory health effects, including worsening emphysema, bronchitis, and asthma. High concentrations of sulfur dioxide can result in breathing problems with asthmatic children and adults who are active outdoors. Short-term exposure has been linked to wheezing, chest tightness and shortness of breath.
While the Council stands firmly behind the EPA’s section 126 finding, we acknowledge that this finding will only have a positive impact if Portland is held accountable under the terms of the finding. The Council urges the EPA to ensure that Portland meets the proposed emissions requirements as expeditiously as possible. Progress should be visible within Portland’s 3 month post-finding period. If there is no progress in this period, the Council recommends the EPA consider closing the facility as allowed by statute and move to renewable sources of energy such as wind and solar. This section 126 finding will be meaningless unless the Portland Plant makes progress in reducing its emissions sooner rather than later. Further, this finding should evidence the need for states such as New Jersey and Pennsylvania to accelerate their production of renewable sources of energy so that air and natural resources can be protected from harms both in state and from across state lines.
Clean Air Council reserves the right to submit further comments prior to the May 27, 2011 submission deadline.
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