As Midlothian residents, we’ve been asked to look the other way as local industry increases pollution. Already, for at least an hour almost every day and for multiple days each month, Midlothian does not meet safe air quality standards set by the EPA.
Why should we sit by as industry continues to make air quality worse?
Part of that “sitting by” means accepting the science endorsed by the Texas Commission on Environmental Quality (TCEQ). Why is that bad?
In our interaction with TCEQ staff, they acknowledge they are not familiar with all technical aspects of the permit (i.e., air modeling, engineering aspects, best available control technology, in-depth knowledge of cement industry).
In the early 2000s, when Holcim last asked to increase emissions, TCEQ withheld knowledge that better technology was available to reduce emissions. They also tried to protect Holcim from having to submit a New Source Review (NSR) permit.
TCEQ repeatedly fails to forcefully enforce permit violations.
In 2018, there were 4,950 unauthorized air pollution events in Texas, resulting in double the unauthorized emissions over the previous year. However, only 57 penalties were issued. Over the past five years, TCEQ has issued similarly low rates of penalties.
When fines are issued, the dollar figure of the penalty is so low (well below what TCEQ is authorized to issue) that it is more profitable for companies to continue to violate their permits and pay the fines than correct the problem. In 2018, TCEQ fined companies just $0.013 per pound of unauthorized emissions.
That’s why we hired Dr. Ron Sahu
We wanted an independent expert review of Holcim’s most recent permit application. Here are Dr. Sahu's credentials:
Doctorate in Mechanical Engineering
Qualified Environmental Professional (QEP)
Confirms that he has in-depth knowledge of his profession, has demonstrated the ability to solve complex environmental problems and has a broad understanding of environmental issues
Certified in Energy Management (CEM)
29 years in engineering (environmental, mechanical and chemical)
25 years in project management and consulting, representing public sector (i.e., EPA, Department of Justice, state governments) and private sector (i.e., cement manufacturers, petroleum refineries)
Has followed Midlothian’s challenges with the cement industry for decades
Has written many articles and expert reports and given many presentations and depositions every year for situations such as ours in Midlothian
Email and phone correspondence with Dr. Ron Sahu and reviewers at TCEQ
Review of past email correspondence from TCEQ obtained through the Freedom of Information Act
EPA letter to TCEQ regarding Holcim Permit 8996 and PSD-TX-454M3 February 20, 2004
“Illegal Air Pollution in Texas: Air pollution from startups, shutdowns, malfunctions and maintenance at industrial facilities in Texas in 2018.” Emma Pabst and Luke Metger (Environment Texas) in collaboration with the Frontier Group. December 2019. https://environmenttexas.org/sites/environment/files/reports/TX_Pollution_scrn (1).pdf
“Air pollution and early deaths in the United States. Part I: Quantifying the impacts of major sectors in 2005.” Caizzo, Fabio, Ashok, Waitz, Yim and Barrett.