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Protect Public Health!

The letter below was used as an automatic email letter that was sent to Mr. Michael Abraczinskas, NC Division of Air Quality as comments asking the North Carolina Environmental Management Commission to remove the Combustion Source Exemption

Comment Deadline was December 31, 2008.

This proposal would exempt 1,400 pollution sources in NC.

The North Carolina Environmental Management Commission has proposed a rule which would create a permanent exemption in the state's health-protective toxic air pollution limits. The Blue Ridge Environmental Defense League believes that the NC EMC has an obligation to protect the health of all our people by removing the Combustion Source Exemption. Meeting the state's toxic air pollution limits at their property boundaries is not too much to expect from North Carolina's electric utilities and manufacturing industries.

Send comments to:
Mr. Michael Abraczinskas
Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
(919) 715-3743 (Phone)
(919) 715-7476 (Fax)

Use our sample letter below.

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 Carolina’s 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 state’s 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 children’s 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 NC’s 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.