This is a copy of the Sample Letter
Mr. Michael Abraczinskas
Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
To Members of the Environmental Management Commission:
Re: 15A NCAC 02Q .0700 Toxic Air Pollution Procedures
The State of North Carolinas current rules that exempt hundreds of combustion boilers that burn unadulterated wood and fossil fuels are being proposed for revision. The original reason for the exemption was that states were waiting for federal rules to regulate toxic air emissions from combustion sources that burn unadulterated fuels. But the federal rules were never promulgated. Since that time, ten years ago, industries with these combustion sources have been given an open door to pollute!
Why the exemption must be removed:
The exemption was never meant to be permanent.
The revised rules would allow some of these pollution sources to indefinitely remain exempt from regulation and outside of North Carolina's Air Toxics Program. Such exemptions perpetuate pollution and compromise the program's purpose in protecting human health and the environment.
If the combustion source exemption is not removed residents of North Carolina will be at increased risk for illnesses and disease due to exposures to toxic pollutants including mercury, arsenic, formaldehyde, hydrogen sulfide, hydrochloric acid, cadmium, furans, dioxins, and more than a hundred others.
The states study of the health impacts of the proposed exemption on industries with existing combustion sources was fatally flawed it failed to consider bioaccumulation of toxics and multiple pollution pathways for air toxics, including ingestion, dermal contact and impacts to water, soil and food.
Children are particularly susceptible to illness and disease from toxic air pollutants because they inhale more deeply than adults and have developing respiratory systems.
A recent study published in USA Today of 128,000 public and private schools across the nation ranked North Carolina schools among the worst in the nation in terms of childrens exposures to industrial air toxics and cancer-causing chemicals. Many of the sources cited in the study included emissions from combustion sources that are currently exempt.
For new and modified permits approved after March 1, 2009, exemptions would be granted to operators that can demonstrate economic hardship or technical infeasibility. There is no exemption for the people of North Carolina whose health will be sacrificed if the exemption is made permanent.
I request that the Environmental Management Commission approve rules that require industries to meet the health-based standards in NCs Air Toxics Program. The Commission should eliminate the combustion source exemption for the sake of our health, our quality of life, our environment, and for future generations.