BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
           4617 Pearl Rd. ~ Raleigh N.C. 27610 ~ Phone (919) 345-3673 ~ Email: therese.vick@gmail.com

Ms. Sheila Holman
Director, North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh, North Carolina 27699-1641
January 26, 2013

Dear Ms. Holman:

Because of the General Assembly’s action in the 2012 session, many sources will now be exempt from North Carolina’s health based Air Toxics standards. The Division of Air Quality (DAQ) was tasked with reporting to the Legislature concerning what changes would be enacted in order to meet the requirement of the amended law. Under recommendations in the December 4, 2012 report to the Environmental Review Commission it is stated that DAQ would:

“1. Develop an additional set of toxic permitting emission rates (TPERs) in 15A NCAC 02Q.0711 for situations where air pollutant emission release points at a given facility are non-obstructed and vertically oriented.” (Page 9)

In addition, that “The DAQ estimates that at a minimum, one?third of all facilities subject to the air toxics rules could use this additional set of TPERs. The DAQ anticipates that use of the new TPERS would relieve a number of those facilities from the need to model toxic air emissions.”

On behalf of Blue Ridge Environmental Defense League (BREDL), I have some questions and concerns about this process:

• How will the development of the new toxic permitting emission rates (TPERs) be conducted? Will this be a public process with opportunities for public participation and comment?

• Where can the information used to establish those facilities that could use the new TPER’s, which “would relieve a number of those facilities from the need to model toxic air emissions.” be obtained?

• The proposed changes to reporting requirements from permitted emission rates to actual emission rates are concerning. Will all of the facilities these changes apply to be required to have continuous emission monitors? It stands to reason that this would be the only way to get a real sense of what is being emitted.

• Who will be able to request/initiate a Director’s Call?

I appreciate your attention to this important area of public concern. Thank you for all you do to protect the people of North Carolina.

Sincerely,

Therese Vick
North Carolina Healthy, Sustainable Communities Campaign Coordinator

Cc: Lou Zeller, Executive Director