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o During the construction phase, the alternative sites would be likely to have PM 2.5 <br />(particles with a diameter of 2.5 microns or less) emissions that are greater than at <br />Bayport, and that could exceed the NAAQS. <br />o The FEIS states that construction-related impacts at the other alternatives "would, in <br />general, be greater than those related to the Bayport terminal location alternative <br />since these locations would require additional stabilization and/or increase in <br />elevation." <br />e The Bayport facility will be more protective of public health and the environment than <br />the FEIS shows because the analysis used overstated emissions. <br />o The FEIS states, "Assumptions were generally made that would result in an estimate <br />of the worst case scenario that could result from the terminal operation." <br />o The study used very high estimates of emissions from construction and operations, <br />like trucks and cranes. The FEIS states, "The emissions inventory presented for the <br />terminal development is intended to be an order of magnitude of emissions greater <br />than what would actually result from terminal operations." <br />o The analysis in the FEIS did not include significant components of the PHA's air <br />mitigation plan. <br />o The study includes the first-ever model in Texas of the impact of such a facility under <br />the new PM 2.5 air quality standard, as well as the impact of diesel particulate . <br />emissions. <br />o The FEIS did not consider all of the benefits of several upcoming environmental <br />regulations that will improve air quality in the region, including the new diesel and <br />fuel standards announced by EPA, new Tier II and Tier III diesel equipment, and <br />other rules relating to the Houston clean air plan. The FEIS states, "This study did <br />not fully account for future regulations and technological advances that would <br />potentially reduce emissions from operations related to the terminal project." <br />o The FEIS states, "Therefore, actual emissions related to the project are likely to be <br />lower than those presented in this assessment." <br />o The FEIS states, "Background levels of PM 2.5 should decrease over time as this <br />pollutant is further controlled. This positive impact was not included in the analysis <br />since it was not possible to determine the degree to which future background levels <br />might decrease." <br />• The Port has also committed to controls that will reduce emissions from Bayport, <br />and further minimize the chance of any harm to citizens living near the facility. <br />o The Port has committed to reducing emissions of ozone-forming chemicals well <br />beyond what is required in the Houston clean air plan. <br />HAYPORT POSITION PAPER <br />page 2 of 7 <br />May 2003 <br />