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2/15/2002 <br />8:30 am Draft <br />• Less than significant impact is represented by an increase in pollutant loading that <br />is incorporated into the HGA ozone attainment plan modeling and is not expected <br />to jeopardize the ability of the area to reach attainment by 2007. <br />• Significant impact is represented by an increase in pollutant loading that_has not <br />been incorporated into the HGA ozone attainment plan modeling and may risk the <br />ability of the area to come into attainment. <br />Emissions incorporated into the HGA ozone attainment plan modeling for the <br />terminal development in 2007 are: <br />^ Vessels - 3 tons per day (tpd) of NOX and 0.076 tpd of VOC; <br />^ Non-road - 0.51 tpd of NOx and 0.26 tpd of VOC; <br />^ Construction - 0.07 tpd of NOa and 0.008 tpd of VOC; <br />^ Dredging - 0.24 tpd of NOX and 0.003 tpd of VOC; and <br />^ On-road -not identified specifically but accommodated for as <br />growth to the area. <br />• Emissions loading estimates past 2007 have not been evaluated. <br />Comment <br />- What about impacts after 2007 (Less than 5 Years) when increased <br />operations and future expansions occur? <br />- Vessels emissions -does the modeling include both trips to and from port <br />and while vessels are in port? <br />- Emissions from railroad activity is not included (and currently not subject <br />to state regulations) <br />- Emissions from ona'oad activity is not identified specifically but <br />accommodated fog' as growth to the area. Did the future growth include <br />estimates. for BaypOYt COYlstl'ucti017 and fulul'e expansions -for the 2007 <br />SIP? After 2007? Again, currently commercial n'uck activity (and heavy <br />equipment) is federally regulated and falls outside the TNRCC's Pollution <br />Control Plan. <br />- The less than significant impact definition avoids the true impact to the <br />communities adjacent to and near the Bayport site. It assumes it 's not <br />significant because a number has been plugged into an attainment plan <br />that covers an eight county area. Airshed Impacts should be site specific <br />