To: NC EMC
From: Louis Zeller, Blue Ridge Environmental Defense League
Re: ozone reductions for coal-fired power plants
Date: 12 September 2000

The Blue Ridge Environmental Defense League advocates no delays on an NC rule requiring 80% NOx reduction.  The long-awaited computer modeling results produced by Dr. Harvey Jeffries for NC DAQ reveal ozone plumes extending for tens and hundreds of miles from coal-fired power plants.  The EPA's ozone standard is not the problem. We should not blame the messenger for the bad news on ozone pollution.  Moreover, economic development may be hamstrung if we continue to allow the utilities' grandfathered powerplants to continue hogging the state's NOx budget.

There is no logical reason to combine the EPA NOx-SIP and EMC NOx rulemaking.  There is no
"retooling" issue if the environmentalist rule is adopted, since our plan calls for the same reductions that the EPA mandates in the NOx-SIP call.  I think that some of the confusion over comprehensive EPA and NC NOx reduction may result from trying to bite off too much at once.

It is no surprise that North Carolina's utilities seek further delays. This pattern dates back to the original Clean Air Act.  Today thirteen coal-fired power plants in NC operate under a loophole in the 1977 law.  In 1999 the EMC granted a system-wide SOC to both utilities because they failed to meet visible emissions regulations dating back to the 1970's.    In December discussions between DENR, Duke, and CP&L on NOx reductions ended in impasse.  Duke and CP&L backed out of their commitment to address NOx emissions after a year of negotiation, refused to go along with the Governor's modest proposal, and instead petitioned to weaken the ozone standard.

I ask you to vote for changes in NCAC 2D .1400 to reduce nitrogen oxide pollution by 80% from the state's 14 coal-fired electric power plants.  The rule drafted by DAQ (Item 9) allows measures pertaining to coal-fired boilers to be carved out and passed separately.  In July the vast majority of people who spoke requested this long overdue measure to reduce smog.  Many people would find it incomprehensible if the EMC fails to act now.

Respectfully,

Louis Zeller

more info: Ozone mapping - includes photo showing "plumes" that are downwind high ozone levels created by the nitrogen oxide emissions from NC coal-fired electric plants.

Clickable map with info about North Carolina's 14 coal-fired electric power plants