05-29-2003 Bayport Expansion Review Committee Meeting

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. . . .. e e Any of the alternative sites would have air impacts that are equal to or greater than Bayport. Operational emissions from all of the alternative sites .would have the same level of impacts for ozone, carbon monoxide (CO), nitrogen oxide (NOx), sulfur dioxide (S02), diesel particulate and PMI0 (particles with a diameter of 10 rom or less) . During the construction phase, the alternative sites would be likely to have PM2.5 (particles with a diameter' of 2.5 rom or less) emissions that are greater than at Bayport, and that could exceed the NAAQS. The FEIS states that construction-related impacts at the other alternatives "would, in general, be greater than those related to the Bayport terminal location alternative since these locations would require additional stabilization and/or increase in elevation." The Bayport facility will be more protective of public health and the environment than the FEIS shows because the analysis used overstated emissions. The FEIS states, "Assumptions were generally made that would result in an estimate of the worst case scenario that could result from the terminal operation." The study used very high estimates of emissions from construction and operations, like trucks and cranes. The FEIS states, "The emissions inventory presented for the terminal development is intended to be an order of magnitude of emissions greater than what would actually result from terminal operations." The analysis in the FEIS did not include significant components of the PHA's air mitigation plan. The study includes the first-ever model in Texas of the impact of such a facility under the new PM 2.5 air quality standard, as well as the impact of diesel particulate emissions. The FEIS did not consider all of the benefits of several upcoming environmental regulations that will improve air quality in the region, includi~g the new diesel and fuel standards announced by EPA, new Tier II and Tier III diesel equipment, and other r.u1es relating to the Houston clean air plan. The FEIS states, "This study did not fully account for future regulations and technological advances that would potentially reduce emissions from operations related to the terminal project." The FEIS states, "Therefore, actual, emissions related to the project are likely to be lower than those presented in this assessment." The FEIS states, "Background levels of PM 2.5 should decrease over time as this pollutant is further controlled. This positive impact was not included in the analysis since it was 5/19/2003 Page 4 of9