Loading...
HomeMy WebLinkAbout02-18-2002 Port of Houston Expansion Review Committee Meeting MINUTES OF THE BAYPORT EXPANSION OPPOSITION COMMITTEE FEBRUARY 18, 2002 1. CALL TO ORDER The meeting was called to order by Chairman Engelken at 6:00 p.m. Members of the Committee Present: Councilpersons Guy Sutherland, Chuck Engelken, Howard Ebow, and Peter Griffiths Members Absent: None Members of City Executive Staff and City Employees Present: Assistant City Manager John Joerns, Assistant City Secretary Sharon Harris, Administrative Assistant of City Manager Crystal Scott, and Mayor Norman Malone Others Present: Bill Scott, Charlie Jenkins, Richard Atherton, Diane Atherton, Tom Kornegay 2. Members considered approving the Minutes of the Committee Meeting of February 4, 2002. Motion was made b~Councilperson Sutherland to approve the minutes of the Committee Meeting on Februa~ 4, 2002 as presented. Second by Councilperson Griffiths. The motion carried. Ayes: Sutherland, Engelken, Ebow, Griffiths Nays: None Abstain: None 3. PETITIONS, REMONSTRANCES, COMMUNICATIONS, AND CITIZENS AND TAXPAYERS WISHING TO ADDRESS THE PORT OF HOUSTON EXPANSION REVIEW COMMITTEE Bill Scott of 1802 Lomax School Road, La Porte, Texas 77571, addressed the Committee. Charlie Jenkins, Project Manager of the Port of Houston Authority, answered questions from the Bayport Expansion Review Committee. 3. NEW BUSINESS There was no new business. 4. COMMITTEE COMMENTS Councilperson Sutherland is concerned about the effect the Expansion would have on Highway 146. Chairman Engelken is concerned about the noise, light and air pollution. Bayport Expansion Opposition Committee - 2/18/02 (Cont'd) Page 2 5. ADJOURNMENT There being no further business to come before the Committee, this meeting was duly adjourned at 9:08 p.m. Respectfully submitted, Martha A. illett, TRMC City Secretary Passed and approved on this day of 2002. C.~.~~- Chairman Chuck Engelken The committee was an Adhoc Committee formed for the purpose of preparing a letter. The City Council was to approve the letter and then send to the Port of Houston Officials opposing the Bayport Expansion. The chairperson approved these minutes since this was the final committee meeting. ®~ r .A 1 ~ ~ ~ ~~ ~ ~~~ /, ~~ ~-..~ L' TEXA`-~ January 10, 2002 Mr. Kerry M. Stanley U.S. Army Corps of Engineers Galveston District Regulatory Branch P.O. Box 1229 Galveston, Texas 77553-1229 Dear Mr. Stanley: • City of i~a forte EstaGlished 1892 Certified Mail 7000 1670 0002 2104 0259 On behalf of the City of La Porte, please accept, record, and file this letter as the City of La Porte's comments regarding the Draft Environmental Impact Statement (DEIS) for the proposed Bayport Marine Terminal. The City of La Porte appreciates the time and effort the U.S. Army Corps of Engineers has given to study the permit application received from the Port of Houston. We recognize that the review was complex and voluminous. We also believe that the Port of Houston has made a genuine effort to understand some of the concerns raised by residents of East Harris County and the communities they reside in. Our City has participated with the work group developed by the Port Authority (Community Advisory Group) and has attended several public heazings and scoping 'meetings. The Port Authority continues to work in good faith with the Community Advisory Group in addressing elements of the DEIS and other issues raised during this process. However, it is the view of the Council, who represent the community, that concerns raised in the August 199.9 position paper have been heard but not acted upon or resolved. Consequently, the City is opposed to the Bayport site, or any combination including Bayport, because we firmly believe the DEIS reinforces our concerns that this site would have substantial long term negative environmental impacts for our community. We would hope that before you consider issuing a permit for this location, you will follow all adopted procedures to insure the public's due process and interests are held at the highest degree of accountability. In addition, we would request that all issues raised during the scoping process, that may not have been analyzed in the current DEIS, be looked at diligently and reported in the final EIS along with all comments received on the circumstances we have no c ntrol over. We further believe that the applicant has a duty P.O. Box 1115 • La Porte, Texas 77572-1117 (251) -171-5020 • • and stewardship responsibilities to the community that is not yet evident in their permit application. The DEIS Executive Summary established two categories, non-environmental and environmental, for comparison of alternate sites. In general, our review finds that the proposed Bayport site ranked either favorably or equal to other sites in the non- environmental categories of availability, operational effectiveness and site constraints. However, within the environmental category, the Bayport site displayed many negative environmental impacts that were more significant than alternate sites. We sincerely hope that convenience, ease of construction and infrastructure costs for the PHA does not prevail over real environmental impacts to adjacent and nearby homes and communities. Another great concern is the comment on air quality. Except for the No Action Alternative, the comments on Airshed Atmosphere Loading are the same for all alternative sites. Especially disturbing is the statement that, "2007 NOX and VOC emissions generated by terminal construction and operations are included in the HGA ozone attainment plan. Therefore, the impact on the region's plan to attain the ozone standard is a long term, less than significant adverse impact." In effect, this is saying that the increased emissions from Bayport can be spread out or balanced over an eight county region while in reality the impacts will be a loading to be borne by the adjacent communities. Please explain why other environmental impacts were site specific while this impact was assumed to be spread out over a region? In La Porte we remember the traffic problems which resulted when Barbours Cut was being built. We remember the discussions and compromises by both sides, which resulted in a grudging acceptance of Barbours Cut by its neighbors. Today, we continue to live with those environmental impacts and lack of planning and public/community involvement in the development of Barbours Cut. We are familiar with the much stricter environmental regulations that exist today and trust that the Corps of Engineers will recognize that Bayport is not the appropriate site. 2 • ADDITIONAL CONCERNS WE REQUEST BE ADDRESSED BY YOUR AGENCYARE LISTED BELOW NOISE POLLUTION Homes to the north side of the Channel will experience disruptive amounts of noise. The DEIS notes that construction noise alone during the nighttime would exceed 55 dBA (decibels, A-weighted sound level) at the nearest residences for dredging, and the nighttime pile construction would exceed 55 dBA at the nearest residences. Operation sound levels at the residences north of the Channel would increase 16 to 22 dBA and exceed 65 Dba Ldn. Two of the alternate sites listed would not increase noise pollution or disturb area residents. AIR POLLUTION DEIS Statement The DEIS states "emissions of NOX [Nitrogen Oxides (NO + NOZ) + the nitrate radical (N03)], S02 (Sulfur Dioxides), and PMIO (Particulate Matter less than 10 microns in diameter) will be generated by construction equipment engines as well as fugitive dust emissions. This is a short-term adverse impact. Comment - The EIS lacks discussion of fine particulate matter that will be discharged. Although this area currently is in compliance at 10 microns, a small increase from the port may cause it to be non compliant. DEIS Statement Fugitive dust PMIO emissions would be mitigated by use of dust control measures. Emissions of NOx, SOs and PMIO will be generated both offsite and onsite due to container and cruise terminal operations. These emissions represent a long-term adverse impact. Comment - The EPA is lowering the standard from 10.0 to 2.5, which mandates that the EIS address this issue. 3 • • DEIS Statement The impact on the Ozone Attainment Plan is stated as "2007 NOX and VOC (Volatile Organic Compounds) emissions generated by terminal construction and operations are included in the HGA (Houston-Galveston Non-attainment Area) ozone attainment plan. Therefore, the impact on the region's plans to attain the ozone standard is a long-term, less than significant adverse impact. • Less than significant impact is represented by an increase in pollutant loading that is incorporated into the HGA ozone attainment plan modeling and is not expected to jeopardize the ability of the area to reach attainment by 2007. • Significant impact is represented by an increase in pollutant loading that has not been incorporated into, the HGA ozone attainment plan modeling and may risk the ability of the area to come into attainment. • Emissions incorporated into the HGA ozone attainment plan modeling for the terminal development in 2007 are: ^ Vessels - 3 tons per day (tpd) of NOX and 0.076 tpd of VOC; ^ Non-road - 0.51 tpd of NOX and 0.26 tpd of VOC; ^ Construction - 0.07 tpd of NOX and 0.008 tpd of V OC; ^ Dredging - 0.24 tpd of NOX and 0.003 tpd of VOC; and ^ On-road -not identified specifically but accommodated for as growth to the area. • Emissions loading estimates past 2007 have not been evaluated. Comment - What about impacts after 2007 (Less than 5 Years) when increased operations and future expansions occur? - Vessels emissions -does the modeling include both trips to and from port and while vessels are in port? - Emissions from railroad activity is not included (and currently not subject to state regulations) 4 • • - Emissions from on-road activity is not identified specifically but accommodated for as growth to the area. Did the future growth include estimates for Bayport construction and future expansions -for the 2007 State Implementation Plan? After 2007? Again, currently commercial truck activity (and heavy equipment) is federally regulated and falls outside the TNRCC's Pollution Control Plan. - The less than significant impact definition avoids the true impact to the communities adjacent to and near the Bayport site. It assumes it's not significant because a number has been plugged into an attainment plan that covers an eight county area. Airshed Impacts should be site specific and not assumed to be less than significant because it was spread out or balanced over an eight county area. There are alternative sites where the Airshed Impacts would not affect such a large population. - The entire eight county region is being subjected to rules related to heavy construction limitations, landscape and lawn mowing limitations and new speed limits. Even though small in their total effect, we've all been asked to share the load while this proposed activity is a point sowce and a real impact borne by a few people, not fully projected for year 2007 and not projected at all beyond 2007. A All of these concerns are amplified by the fact that the 2007 State Implementation Plan still falls short of needed NOX reductions. Therefore, any increase in NOX is unjustified and unreasonable. ^ Hams County officials have recently indicated they may take action on the proposed 55 mph speed limit. If this occurs and the 55 mph restriction is removed then the projected NOX 2007 shortfall would be even greater. ^ Furthermore, five petitions filed with the 5th U. S. Circuit Court of Appeals cite different flaws in the plan as reasons the court should review and set aside the EPA's approval. The petition argues that the 2007 SIP Plan did not account for the future growth of emissions expected for entities like the Port of Houston. Please advise what the petition claims was not accounted for. LIGHT POLLUTION • Homes to the north side of the channel will experience disruptive amounts of light pollution. The DEIS states "Development of the Terminal complexes would change the visual character at any of the terminal location alternatives from a low level undeveloped area to awell-lighted, 24-how transportation facility with high- mast lighting." 5 • • The DEIS indicates the residential areas north of Bayport Terminal would not experience an increase in nighttime ambient light due to the distance from the light sources. However, operational lighting at Bayport could lead to nightglow that would be visible by virtually all the residential areas adjacent to Bayport. There are several alternative sites where there are no residential areas in the vicinity of the site. EROSION • The information on shoreline erosion at the Bayport Channel is documented in the DEIS. It was noted that, on the average, each bank has been retreating at a rate of 4.3 feet per yeaz. This would be expected to increase because of increased traffic. • The DEIS summary states that there is no short-term or long-term impact relating to shoreline erosion. We assume this is attributed to another statement that "unprotected shoreline to be protected as part of the project construction." • Please confirm that plans for shoreline protection were part of the application and that they include protection of the private property at and around the northeast corner of the channel entrance to Bayport. TRANSPORTATION ISSUES • Delays will be caused at rail crossings and major thoroughfares due to increased vehicular and rail traffic. The DEIS presents references to roadways that will need to be improved upon but does little to discuss the actual additional traffic and the burden it would place on area residents. No consideration has apparently been given to conflicts with existing vehicular traffic. The only suggestions made are the widening of Port Road from the project site to SH 146 and "proposed interchange and ramp improvements in the vicinity of the Port Road and SH 146 interchange." The DEIS acknowledges that Red Bluff Road, Port Road, and SH 146 will need improvements in future years based on projected growth with or without the Bayport Terminal. As for rail traffic, the DEIS is even more vague, stating only that "The site is located so that trains from the site could easily be consolidated with those from the Barbours Cut Terminal" and suggests "road/rail grade separation at new rail crossings at SH 146." • The DEIS addressed the impact to the transportation system on an area basis but does not address localized impacts. Local communities, which are already subject 6 LJ to the worst environmental impacts, will thus realize immediate impact on their surface transportation and this must be discussed. • An overpass must be constructed where Fairmont Parkway, a major thoroughfare, crosses the new inter port railway. This overpass and the highway modifications at the entrance to the port must be in place by the date the port begins operation. • The DEIS en oneously implies that the Fairmont Parkway grade separation is fully funded by the Transportation Implementation Plan and Port of Houston Authority commitments. Hams County, also a party to this improvement, only recently agreed to the funding arrangements. The Texas Department of Transportation Agreements have yet to be signed. SHIPPING • The distance between ships moving into position at the docks may be inadequate to prevent collision and erosion. • Ships entering the Bayport Terminal do not have to comply with the State air emissions reduction efforts and will bring their emissions into close proximity to a highly urbanized, residential area. • The DEIS does not speak to reducing or mitigating the increased levels of pollution from marine vessel coatings and materials, which will come from the additional increase of foreign flagged vessels entering Galveston Bay. Use of antifouling coatings to reduce the organic growth of marine life by foreign vessels do not fall under and are immune to U. S. laws and regulations against the deposition of trace amounts ofanti-fouling coating products in the U. S. waters. These coatings, designed deliberately to kill or slow marine growths on hulls, are leaked into the surrounding environment. Certain pollutants contained in these products have long been recognized as destructive to natural reefs and entire ecosystems. The permit application continues to be silent on the impact of deepening the channel from 45 feet to 50 feet even though the Bayport wharves are being designed fora 56-foot depth. We believe it is better to understand the incremental change from 45 feet to SO feet today rather than hear the Port has decided to seek a permit for a SO-foot channel within the next five years. 7 • A potential exists for conflicts between commercial vessels and recreational boats between Bayport and the Houston Ship Channel. The DEIS does not develop any actions to mitigate this potential conflict except to suggest that recreational boaters will voluntarily relocate to less congested areas. The sailing distance from the Galveston sea buoy to the Bayport Terminal is approximately 36 miles. Two alternative terminal locations, Pelican Island and Shoal Point, have significantly less sailing distances. The DEIS indicates there would be less risk of ship collisions and groundings associated with development of the sites with shorter sailing distances. SEWAGE • Sewage from the ships and the port must be handled in a manner whereby there is no chance that it will enter Galveston Bay. A system approved by the TNRCC should be in place by the time operations begin. WATER QUALITY • The DEIS lacks discussion of current water quality for the portion of the bay that would be affected by the constn.iction of this project and subsequent increase in shipping. It noted a few stations with data collected in 1997-1998 but the majority is from Galveston Bay Estuary Program reports dated 1992 and 1994. • The DEIS lacks reference to ongoing projects and water quality results from current studies that address dioxin and bacteria, which could help, deternune whether or not the Bayport Ship Channel will be added to the state list of impaired waters. • The DEIS lacks discussion on the impact of dredging on water quality for the short or long term. If dredging causes re-suspension of contaminants, the Channel would be placed on a list that would require Total Maximum Daily Load studies. • The DEIS lacks discussion on the potential impact of increased shipping activity and storm water runoff on water quality. • The DEIS lacks discussion on the effects of ballast water on the Galveston Bay System. ! ~ WETLAND S/HABITAT • Wetlands in the Galveston Bay watershed provide treatment of storm water runoff and buffer floods to reduce storm surges and additionally serve as habitat for wildlife and commercially valuable species. • The DEIS describes 2.5 acres of wetlands under the jurisdiction of the Corps that will be destroyed and require mitigation and 103.5 acres of non jurisdictional wetlands. The DEIS lacks adequate discussion on the impact of losing these wetlands. • The DEIS lacks adequate discussion on the value of wetlands, specific mitigation requirements, or the location of mitigation. BAYFRONT DEVELOPMENT/RECREATION • The permit is silent in addressing the impact that Bayport development will have on future recreation and bayfront developments in La Porte. In 1993, the City adopted a Bayfront Master Plan. The primary aims of this study are to stimulate economic development within the City, to diversify the City's economic base through the stimulation of its tourist industry, and to create a more desirable physical environment through the enhancement of its waterfront assets. A copy of this report was given to the Port of Houston Authority consultants. They indicated that it was good we had plans for waterfront development and that they would study what impact the Bayport development would have on our vision and respond to us. No response has been afforded to us. The Corps should look at all plans which were adopted before Bayport was conceived to determine how the proposed development will hinder growth, redevelopment, and the ability for beautification and visual enhancement of the waterfront as well as of the waterfront district itself. Approximately 2 '/z years ago we issued a position paper on the expansion. For the purpose of record keeping, we are resubmitting it to you as it was written and delivered to your agency on August 17, 1999 at a scoping meeting held in Pasadena, Texas. 9 WE BELIEVE THAT OUR ORIGINAL CONCERNS REMAIN VALID AND REQUEST THE CORPS RESPOND TO THESE OBSERYATIONSAS WELL. 1) The development will bring about changes in our community which are disruptive and more than just a nuisance. Homes on the north side of the Channel to Bayport will experience noise, air pollution, lighting, and shoreline erosion problems. These issues, if not addressed, will cause the property owners' land values to be lowered, and their ability to sell their homes would be very difficult without taking a loss. If the Port Authority cannot correct these real estate concerns, then consideration from the Port Authority should be given to buy out the homes at fair market value, which abut the development. 2) The proposed development will bring with it major rail and vehicle transportation issues which will impact the City of La Porte and will affect neighboring communities. The proposed development will cause delays at rail crossings of major thoroughfares such as Fairmont Parkway, Shoreacres Boulevard, and Red Bluff Drive. Consideration from the Port of Houston must be given to working with local jurisdictions to resolve traffic concerns. In addition, the Port Authority should petition the State of Texas Highway Department to insure that State Highway 146 and State Highway 225 roadways are designed and constructed in advance to provide for the growth of the area and this development. It is recommended the Port Authority approach the State Highway Department to create a specialized truck lane on State Highway 146 to isolate the truck traffic to and from port facilities. The Port Authority should actively take a lead role in insuring rail crossings have overpasses and should also seek ways to fund these overpasses and their construction before the proposed development occurs. 3) The proposed development will add significant air pollution issues that cannot be ignored. The Bayport facility will generate additional air pollution from its use of diesel trucks, diesel ships, diesel cranes, and diesel vehicles that will operate at this location. The Port Authority should study the impact of this air pollution to the surrounding communities and to Harris County. Consideration should be given to using equipment that uses a cleaner burning fuel alternative. In addition, consideration should be given to the placement of air monitoring devices along the site boundaries to measure the air quality leaving the site. East Harris County is under orders of the EPA that our region must reduce nitrogen oxides (Nox) emissions by as much as 85 percent to come into compliance with the national ozone standard by the year 2007. Adding this facility at this location contradicts any state goal adopted to reduce Nox emissions in our region. 10 4) The Port of Houston should require a complete Environmental Impact. Study be performed by the Army Corps of Engineers and require the Corps of Engineers to seek input from all communities and agencies which adjoin or may play some role in protecting the waters of Galveston Bay as a nationally important estuary. The Port Authority should also engage a consultant to study the existing shipping traffic patterns that enter and use the Bayport Channel and apply this usage to their traffic models. Furthermore, it is recommended that the same consultant study the water area of the Bayport Channel as it relates to the use of water recreational activities such as sailing, fishing, and shrimping. 5) The proposed development may bring about detrimental mazine changes whose impact must be understood. The operation of a facility of this type will cause additional erosion to the north boundary of the Bayport Channel. Measures must be in place to protect and eliminate the continual loss of shoreline to ship activity visiting and leaving the development. As larger ships come into play, the Port of Houston should attempt to understand the impact to Galveston Bay marine ecosystem if the channel is ever dredged to a depth~of 50 feet. The Port Authority should require the Army Corps of Engineers to look at this depth as well as the 45-foot depth, which is proposed, to better understand the incremental change that may occur, if any. If you should require any additional information, please let me know. Sinc ely, ri-- `~ Mayor Norman L. Ma one Peter ' fiths, Councilman At-Large A Alton/,~Port~e~rJ, Councilman At-Large B Guy C~~~. Chuck Engelken, J .Councilman District 2 Hov t games Warren, Councilman District 4 (~ ~ y ~ ~ l Je%~~Iazke, uncilir3an District 6 ~, , cc: Rob rt T. Herrera, City Manager Knox W. Askins, City Attorney District 1 >v~ r~ c,J Ebow, Councilman istrict 3 ~~~~ ~ ~~ Charlie Your , Counc~. an District 5 2/ 15/2002 • 8:30 am Draft January 10, 2002 Mr. Kerry M. Stanley U. S. Army Corps of Engineers Galveston District Regulatory Branch P.O. Box 1229 Galveston, Texas 77553-1229 Dear Mr. Stanley: On behalf of the City of La Porte, please accept, record, and file this letter as the City of La Porte's comments regarding the Draft Environmental Impact Statement (DEIS) for the proposed Bayport Marine Terminal. The City of La Porte appreciates the time and effort the U. S. Army Corps of Engineers has given to study the permit application received from the Port of Houston. We recognize that the review was complex and voluminous. We also believe that the Port of Houston has made a genuine effort to understand some of the concerns raised by residents of East Harris County and the communities they reside in. Our City has participated with the work group developed by the Port Authority (Community Advisory Group) and has attended several public hearings and scoping meetings. The Port Authority continues to work in good faith with the Community Advisory Group in addressing elements of the DEIS and other issues raised during this process. However, it is the view of my Council and my community that concerns raised in the August 1999 position paper have been heard but not acted upon or resolved. Consequently, the City is opposed to the Bayport site, or any combination including Bayport, because we firmly believe the DEIS reinforces our concerns that this site would have substantial long term negative environmental impacts for our community. We would hope that before you consider issuing a permit for this location, you will follow all adopted procedures to insure the public's due process and interests are held at the highest degree of accountability. In addition, we would request that all issues raised during the scoping process, that may not have been analyzed in the current DEIS, be looked at diligently and reported in the final EIS along with all comments received on the circumstances we have no control over. We further believe that the applicant has a duty 2/15/2002 g:3o am Draft and stewardship responsibilities to the community that is not yet evident in their permit application. The DEIS Executive Summary established two categories, non-environmental and environmental, for comparison of alternate sites. In general, our review finds that the proposed Bayport site ranked either favorably or equal to other sites in the non- environmental categories of availability, operational effectiveness and site constraints. However, within the environmental category, the Bayport site displayed many negative environmental impacts that were more significant than alternate sites. We sincerely hope that convenience, ease of construction and infrastructure costs for the PHA does not prevail over real environmental impacts to adjacent and nearby homes and communities. Another great concern is the comment on air quality. Except for the No Action Alternative, the comments on Airshed Atmosphere Loading are the same for all alternative sites. Especially disturbing in the statement that, "2007 NOX and VOC emissions generated by terminal construction and operations are included in the HGA ozone attainment plan. Therefore, the impact on the region's plan to attain the ozone standard is a long term, less than significant adverse impact. " In effect, this is saying that the increased emissions from Bayport can be spread out or balanced over an eight county region while in reality the impacts will be a loading to be borne by the adjacent communities. Please explain why other environmental impacts were site specific while this impact was assumed to be spread out over a region? In La Porte we remember the traffic problems which resulted when Barbours Cut was being built. We remember the discussions and compromises by both sides, which resulted in a grudging acceptance of Barbours Cut by its neighbors. Today, we continue to live with those environmental impacts and lack of planning and public/community involvement in the development of Barbours Cut. We are familiar with the much stricter environmental regulations that exist today and trust that the Corps of Engineers will recognize that Bayport is not the appropriate site. ADDITIONAL CONCERNS WE REQ UEST BE ADDRESSED BY YOUR AGENCYARE LISTED BELOW 2/ 15/2002 • 8:30 am Draft NOISE POLLUTION • Homes to the north side of the channel will experience disruptive amounts of noise. The DEIS notes that construction noise alone during the nighttime would exceed 55 dBA (decibels, A-weighted sound level) at the nearest residences for dredging, and the nighttime pile construction would exceed 55 dBA at the nearest residences. Operation sound levels at the residences north of the channel would increase 16 to 22 dBA and exceed 65 Dba Ldn. Two of the alternate sites listed would not increase noise pollution or disturb area residents. AIR POLLUTION DEIS Statement The DEIS states "emissions of NOX [Nitrogen Oxides (NO + N02) + the nitrate radical (N03)], SOZ (Sulfur Dioxides), and PMIO (Particulate Matter less than. l0 microns in diameter) will be generated by construction equipment engines as well as fugitive dust emissions. This is a short-term adverse impact. Comment - The EIS lacks discussion of fine particulate matter that will be discharged. Although this area currently is in compliance at 10 microns, a small increase from the port may cause it to be non compliant. DEIS Statement Fugitive dust PM,o emissions would be mitigated by use of dust control measures. Emissions of NOX, SOZ and PMIO will be generated both offsite and onsite due to container and cruise terminal operations. These emissions represent a long-term adverse impact. Comment Y The EPA is mo~~ing towards lowering the standard from 10.0 to 2. S, which mandates that the EIS address this issue. DEIS Statement The impact on the Ozone Attainment Plan is stated as "2007 NOX and VOC (Volatile Organic Compounds) emissions generated by terminal construction and operations are included in the HGA (Houston-Galveston Non-attainment Area) ozone attainment plan. Therefore, the impact on the region's plans to attain the ozone standard is a long-term, less than significant adverse impact. 2/15/2002 8:30 am Draft • Less than significant impact is represented by an increase in pollutant loading that is incorporated into the HGA ozone attainment plan modeling and is not expected to jeopardize the ability of the area to reach attainment by 2007. • Significant impact is represented by an increase in pollutant loading that_has not been incorporated into the HGA ozone attainment plan modeling and may risk the ability of the area to come into attainment. Emissions incorporated into the HGA ozone attainment plan modeling for the terminal development in 2007 are: ^ Vessels - 3 tons per day (tpd) of NOX and 0.076 tpd of VOC; ^ Non-road - 0.51 tpd of NOx and 0.26 tpd of VOC; ^ Construction - 0.07 tpd of NOa and 0.008 tpd of VOC; ^ Dredging - 0.24 tpd of NOX and 0.003 tpd of VOC; and ^ On-road -not identified specifically but accommodated for as growth to the area. • Emissions loading estimates past 2007 have not been evaluated. Comment - What about impacts after 2007 (Less than 5 Years) when increased operations and future expansions occur? - Vessels emissions -does the modeling include both trips to and from port and while vessels are in port? - Emissions from railroad activity is not included (and currently not subject to state regulations) - Emissions from ona'oad activity is not identified specifically but accommodated fog' as growth to the area. Did the future growth include estimates. for BaypOYt COYlstl'ucti017 and fulul'e expansions -for the 2007 SIP? After 2007? Again, currently commercial n'uck activity (and heavy equipment) is federally regulated and falls outside the TNRCC's Pollution Control Plan. - The less than significant impact definition avoids the true impact to the communities adjacent to and near the Bayport site. It assumes it 's not significant because a number has been plugged into an attainment plan that covers an eight county area. Airshed Impacts should be site specific Z/l 5/2002 8:30 am Draft acid not assumed to be less than signijicarzt because it was spread out or balanced over an eight county area. There are alternative sites where the Airshed Impacts would not affect such a large population. - The entire eight county region is being subjected to rules related to heavy construction limitations, landscape and lawn mowing limitations and new speed limits. Even though small in their total effect, we 've all been asked to share the load while this proposed activity is a point source aizd a real impact borne by a few people, not fully projected for year 2007 and not projected at all beyond 2007. - All of these concerns are amplified by the fact that the 200. 7 SIP Plan still falls 56 tons per day short of needed NOX reductions ^ Harris County officials have recently indicated they may take action on the proposed SS mph speed limit. If this occurs and the ~5 mph restriction is removed then the projected NOx 2007 shortfall would be 68 tons per day. ^ Furthermore, five petitions filed with the S`" U.S. Circuit Court of Appeals cite d~erent flaws in the plan as reasons the court should review and set aside the EPA 's approval. The petition argues that the 2007 SIP Plan did not account for the future growth of emissions expected for entities like the Port of Houston. Please advise what the petition claims was not accounted for. LIGHT POLLUTION Homes to the north side of the channel will experience disruptive amounts of light pollution. The DEIS states "Development of the terminal complexes would change the visual character at any of the terminal location alternatives from a low level undeveloped area to awell-lighted, 24-hour transportation facility with high-mast lighting." • The DEIS indicates the residential areas north of Bayport terminal would not experience cnz increase in nighttime ambient light due to the distance from the light sources. However, operational lighting at Bayport could lead to nightglow that would be visible by virtually all the residential areas adjacent to Bayport. There are several alternative sites where there are no residential areas in the vicinity of the site. TRANSPORTATION ISSUES 2/15/2002 g:3o am Draft • Delays will be caused at rail crossings and major thoroughfares due to increased vehicular and rail traffic. The DEIS presents references to roadways that will need to be improved upon but does little to discuss the actual additional traffic and the burden it would place on area residents. No consideration has apparently been given to conflicts with existing vehicular traffic. The only suggestions made are the widening of Port Road from the project site to SH 146 and "proposed interchange and ramp improvements in the vicinity of the Port Road and SH 146 interchange." The DEIS acknowledges that Red Bluff Road, Port Road, and SH 146 will need improvements in future years based on projected growth with or without the Bayport Terminal. As for rail traffic, the DEIS is even more vague, stating only that "The site is located so that trains from the site could easily be consolidated with those from the Barbours Cut Terminal" and suggests "road/rail grade separation at new rail crossings at SH 146." • The EIS addressed the impact to the transportation system on an area basis but does not address localized impacts. Local communities, which are already subject to the worst environmental impacts, will thus realize immediate impact on their surface transportation and this must be discussed. • An overpass must be constructed where Fairmont Parkway, a major thoroughfare, crosses the new inter port railway. This overpass and the highway modifications at the entrance to the port must be in place by the date the port begins operation. The DEIS erroneously implies that the Fairmont Parkway grade separation is fully funded by the TIP and PHA commitments. Harris County only recently agreed to the funding arrangements. The TxDot Agreements have yet to be signed. SHIPPING • The distance between ships moving into position at the docks may be inadequate to prevent collision and erosion. • Ships entering the Bayport Terminal do not have to comply with the State air emissions reduction efforts and will bring their emissions into close proximity to a highly urbanized, residential area. • The DEIS does not speak to reducing or mitigating the increased levels or organotin pollution and other marine vessel coatings and materials, which will come from the additional increase of foreign flagged vessels entering Galveston Bay. Use of antifouling coatings to reduce the organic growth of marine life by 2/15/2002 • 8:30 am Draft foreign vessels do not fall under and are immune to U.S laws and regulations against the deposition of trace organotin products in the U.S. waters. These organic tin compounds are leaked into the surrounding em~ironment by ablative and contaminative causes designed deliberately to kill or slow marine growths on hulls. Certain pollutants such as lead and organic tin conzplea:es have long been recognized as destructive to natural reefs and entire ecosystems. The permit application continues to be silent on the impact of deepening the channel from 45 feet to SO feet even though the Bayport wharves are being designed fora 56 foot depth We believe it is better to understand the incremental change from 45 feet to SO feet today rather than hear the Port has decided to seek a permit fora 50 foot channel within the next ftve years. • A potential exists for conflicts between commercial vessels and recreational boats ira the reach of the Bayport Ship Channel between Bayport and the Houston Ship Channel due to the increase in both commercial vessels and recreational boats. The DEIS does not develop arly actions to mitigate this potential conflict except to suggest that recreational boaters will voluntarily relocate to less congested a~°eas. • The sailing distance from the Galveston sea buoy to the Bayport terminal is approximately 36 miles. Two alternative terminal locations, Pelican Island and Shoal Point have significantly less sailing distances. The DEIS indicates there would be less risk of ship collisions and groundings associated with development of the sites with shorter sailing distances. SEWAGE • Sewage from the ships and the port must be handled in a manner whereby there is no chance that it will enter Galveston Bay. A system approved by the TNRCC should be in place by the time operations begin. WATER QUALITY • The DEIS lacks discussion of current water quality for the portion of the bay that would be affected by the construction of this project and subsequent increase in shipping. It noted a few stations with data collected in 1997-1998 but the majority is from Galveston Bay Estuary Program reports dated 1992 and 1994. 2/15/2002 ~ • 8.30 am Draft • The DEIS lacks reference to ongoing projects and water quality results from current studies that address dioxin and bacteria, which could help, determine whether or not the Bayport Ship Channel will be added to the state list of impaired waters. • The DEIS lacks discussion on the impact of dredging on water quality for the short or long term. If dredging causes re-suspension of contaminants, the channel would be placed on a list that would require Total Maximum Daily Load studies. • The DEIS lacks discussion on the potential impact of increased shipping activity and storm water runoff on water quality. • The DEIS lacks discussion on the effects of ballast water on the Galveston Bay System. WETLANDS/HABTTAT~ • Wetlands in the Galveston Bay watershed provide treatment of storm water runoff and buffer floods to reduce storm surges and additionally serve as habitat for wildlife and commercially valuable species. • The DEIS describes 2.5 acres of wetlands under the jurisdiction of the Corps that will be destroyed and require mitigation and 103.5 acres ofnon-jurisdictional wetlands. The DEIS lacks adequate discussion on the impact of losing these wetlands. • The DEIS lacks adequate discussion on the value of wetlands, specific mitigation requirements, or the location of mitigation. BAYFRONT DEVELOPMENT/RECREATION The permit is silent in addressing the impact that Bayport development will have on future recreation and bayfront developments in La Porte. In 1993, the City adopted a Bayfront Master Plan. The primary aims of this study are to stimulate economic development within the City, to diversify the City's economic base through the stimulation of its tourist industry, and to create a more desirable physical em~ironment through the enhancement of its waterfront assets. A copy of this report was given to the Port of Houston Authority consultants. They indicated that it was good ive had plans for waterfront development and that they would study what impact the Bayport development would have on our vision and respond to us. No response has been afforded to us. The Corps should look at all plans which were adopted before Bayport was 2/ 15/2002 • 8:30 am Draft conceived to determine haw the proposed deti~elopntent will hinder growth, redevelopment, and the ability for beautification and risual enhancement of the waterfront as well as of the waterfront district itself. Approximately 2 '/z years ago we issued a position paper on the expansion. For the purpose of record keeping, we are resubmitting it to you as it was written and delivered to your agency on August 17, 1999 at a scoping meeting held in Pasadena, Texas. WE BELIEVE THAT OUR ORIGINAL CONCERNS REMAIN VALID AND REQUEST THE CORPS RESPOND TO THESE OBSERVATIONS AS WELL. 1) The development will bring about changes in our community which are disruptive and more than just a nuisance. Homes on the north side of the channel to Bayport will experience noise, air pollution, lighting, and shoreline erosion problems. These issues, if not addressed, will cause the property owners' land values to be Lowered, and their ability to sell their homes would be very difficult without taking a loss. If the Port Authority cannot correct these real estate concerns, then consideration from the Port Authority should be given to buy out the homes at fair market value, which abut the development. 2) The proposed development will bring with it major rail and vehicle transportation issues which will impact the City of La Porte and will affect neighboring communities. The proposed development will cause delays at rail crossings of major thoroughfares such as Fairmont Parkway, Shoreacres Boulevard, and Red BluffDrive. Consideration from the Port of Houston must be given to working with local jurisdictions to resolve traffic concerns.. In addition, the Port Authority should petition the State of Texas Highway Department to insure that State Highway 146 and State Highway 225 roadways are designed and constructed in advance to provide for the growth of the area and this development. It is recommended the Port Authority approach the State Highway Department to create a specialized truck lane on State Highway 146 to isolate the truck traffic to and from port facilities. The Port Authority should actively take a lead role in insuring rail crossings have overpasses and should also seek ways to fund these overpasses and their construction before the proposed development occurs. 3) The proposed development will add significant air pollution issues that cannot be ignored. The Bayport facility will generate additional air pollution from its use of diesel trucks, diesel ships, diesel cranes, and diesel vehicles that will operate at this location. The Port Authority should study the impact of this air pollution to the surrounding communities and to Harris County. Consideration should be given to using equipment that uses a cleaner burning fuel alternative. In addition, consideration should be given to the placement of air monitoring devices along 2,1 si2oo2 • w 8:30 am~` Draft the„~~te boundaries to measure the air quality leaving the site. East Harris County is u~der orders of the EPA that our region must reduce nitrogen oxides (Nox) emisons by as much as 85 percent to come into compliance with the national .~. ozoh~ standard by the year 2007. Adding this facility at this location contradicts any ~{ate goal adopted to reduce Nox emissions in our region. ;:,. The Fort of Houston should require a complete Environmental Impact Study be performed by the Army Corps of Engineers and require the Corps of Engineers to seek input from all communities and agencies which adjoin or may play some role in protecting the waters of Galveston Bay as a nationally important estuary. The Port Authority should also engage a consultant to study the existing shipping traffic patterns that enter and use the Bayport channel and apply this usage to their traffic models. Furthermore, it is recommended that the same consultant study the water area of the Bayport channel as it relates to the use of water recreational activities such as sailing, fishing, and shrimping. 5) The proposed development may bring about detrimental marine changes whose impact must be understood. The operation of a facility of this type will cause additional erosion to the north boundary of the Bayport channel. Measures must be in place to protect and eliminate the continual loss of shoreline to ship activity visiting and leaving the development. As larger ships come into play, the Port of Houston should attempt to understand the impact to Galveston Bay marine ecosystem if the channel is ever dredged to a depth of 50 feet. The Port Authority should require the Army Corps of Engineers to look at this depth as well as the 45-foot depth, which is proposed, to better understand the incremental change that may occur, if any. If you should require any additional information, please let me know. Sincerely, Mayor Norman L. Malone cc: City Council Robert T. Herrera, City Manager Knox W. Askins, City Attorney . Tp t ~ y~ .I' ^~r~ i ~~~9~'~. CJ~riir'r V~fh`~ i ~~'~~? '' .. ' ~ `~ ~f _. ---.. _ - - - ~ 1 . ~; LpT OF X'$ AND 0'$ . STAYING, ON .1100. Et TOES ~ :, ~ . _ :. ~ ; -. ;~ oachin `.deal ever. S orts I ~ Looking to improve the oi',,ticker? Well, walk -this .way :;Houston . dive Spurrier the; richest NFL c g P cry-, ~sy ,~ ~~ ~ .r l ttt~ 1" ~a, `? n .h 4. Si. ~~' - l,li ~j - Y~,eU w b ~e (.~D. fe. Y - H d-. C~< <2 " ~~ .. ,,,.... l ~{ 1 ;.,. F.~1 '-'!. Y. ._~'yW.~. .::' Y,. ,Fv:~n 1. iw ••~, `;.r. .~; .t ' t' .i~'- .7.~. _ 'd ~ 4' N~l e '~ ., -.,. . .,,r-:..: -F.. 5, .,s. ,, .. _" ~.<: q -<'>_.. ~. , ,. .._ ~~r. 1 1 '~ ~-e, ,. , _ .«.,ar `a~.~ '~' < -.~r°-. '2~~.9 '~`~ fi ,~ .`• 3 ,E.Ei ~ yc>a~'~Ja .. ~...... ~~ - 7 +'t A - .~ r ~ q.~ -_ ~ '~ ,aA~r ~ _: _~ , c , i4~ ': s' „~&•, , s ~ r ~ . ~ i ~ ,f ~;i _ ;.3ur3,~~t c ~ _ ~rSNE ~ 0~+'!}ti ~ 4 i ".!>~; F 4'~ . 1.. ~" +~',F~n~~~~~~~ .. ~ ~~ _ ~' _"f~.~._..S_., p _~;~:. ~r..,-.2 ~ ~: ,npu~ ~-~ f .a:~ ~'~:i, :r*i; ~. F. _.."2 ~ _ .i_ .t .. .....~ _.JW z ~:h.k:i " .' ,. ~ "G: - - .. ._ `~°"~~.~k .,'z~'~P7"YL~~~~' r"•~'~x. `.~r "~'~ $Y-«Pa2'~^.ra tl ~Ac<'.,~~ ~ c, t,',:Ir ~?d+~~~~~~t'a~f~ .~{~~~~ISW'. TS by alify state only gout IAY qua ...: 2D ... 7C 20A 13A ~.~, ~n ~. „ : ; ; ~ - - ~ John Stufflebeem said bombing in recent • • . days had destroyed about 60 buildings and ~~®~ ~ ~ n~~ ~®~~~'! ~~~~`~, ~~ ~~+ "~~g~ Plosed off 50 caves atg awar. He said military ~!,~ ,j` ,jJ~ Tanners were endin their focus on the area :..~„i W ~~ ~ in the hunt for intelligence on al-Qaida and -'~ . -~. ~~ ~- ~~~ ~ ~ ~ ~ ~ ~; :. - bin:~~I,aden, chief suspect in the Sept. 11 at- B TONY FREEMANTLE ~' -" ' ' ~ ~ ~ - • ~ member spinoff of the Greater Houston tacks: "It's now time to go look elsewhere," Y ^ The state's air~qual' ro ram will • • ~ ~. Houston Chronicle cut greenhouse-gas emissions, but Partnership.: :_ : _ he said E' ~~r ~ ~ F~ ~ k . ~ .should 6e 'expanded and.improved, the , : Years ,m, the malting, the plan: is de- In khe capital, Kabul, where fighting ended fir' ~ , d~r~'vrr _ , . signed to bring the Houston/Galveston re- in November after the Taliban militia fled, Ebur Qp p11t~1;~rganizations and a TNRCC says: Page 13A: ~ gion, -with one of •the worst smog pmb- the spokesman for U.N. Afghanistan envoy pup of local business leaders asked a . ^ Montgomery County commissioners lem§ in the nation - into'compliance with Lakhdar Brahimi beseeched nations who ederal appeals"'court Monday to review will mount a lobbying effort against the national ozone standards by 2007. as, re- have pledged aid money to Afghanistan to an ambitious, but they say ultimately ,new air quality rules: Page 13A. quu~ed by the federal Clean Air Act.'•,_ come through "immediately, not next year." flawed, state plan to force Houston to; - « Ozone` the principal ingredient of smog It is time for the international community comply with national air quality stan- The petitions were brought by the is.formed when volatile organic comb to stop talking and start delivering help," Bards. Sierra Clubs°Environmental Defense, the powids mix with nitrogen oxides in the Ahmed Fawzi said `.`This country. needs mil- - The.five petitions filed with the 5th U.S. National,.Resources Defense; Council, the: presence . of sunlight. and. is associated lions of dollars tomorrow. Otherwise, there Circuit Court of Appeals .in. New. Orleans Galveston-Houston Association for- Smog ~~ a number of adverse healtH condi- will be no country when the billions are each cite different flaws in the plan as rea- Prevention ~(GHASI?) together with the tions,''including chest pains, coughing and ready." sons the court should review and set aside., Galveston :Bay Conservation and l?reser- nausea. It also aggravates conditions such He said donor nations have agreed to con- the Environmental Protection Agenc}~s . vatiori Assochation, and the Business Coa- decision to approve the plan Oct. 15. lition for Clean"Air Appeal Groun. a 12- See AIR on Page 6A. See WAR on Page 6A. .. _ _',; _ l~,ew state rule makes Col®nlbi~n eta in fit elenlentar~ _ e~.~e tal~~ 4. ~~edding fattest city label starts :in school 1 ge$ ~.~~ ~~ ~' B 'SALATHEIA°BRYANT ent-.activities, including'-soccer, ~ track, gymnastics, softbah and By DUDLEY ALTHAUS Houston Chronicle" the h sisal p y Houston Chronicle bowlin as art of , " " .~~s , ,,.. ".,. .,~ ..: . , g. P •. ,. l~ ' out ana-w'~ere's-no qucs~.~,~ lion, en -'he~'"ta t~"~8!~ny~~`~.-"'° -'"°^ The exercises also improve thee'.,., Hergenroeder, ;director o a o- . -. o1n ~ make a difference " l nt sports medicine chnics at it's g .. g flexibility; strength and cardio- esce 4 . ' tected, not just promises;" said ; 'set .aside because th lean the l ° John D. Wilson; ,executive direr- wlll.not, as written, 1 % by;the deadline of 2007. ~.' for of GRASP: ,' h icier I believe I have For residents in Houston ,and- "As' a P Ys onsibility to help ei ht surroundinghat something create healthy environment for, D Continued from Page 1A. most visible sign as bronchitis and`astlima and can is being done about the region's the people of Houston," Marraclr , ~ air will be the gradual intro- ,said: "We will not get there by reduce lung,capacity• dirty the next few•, 2007:,We've left it too late." ~, The petitions argue, among ducti.on during. h s eed limit r other'issues; that~the clean-.air mon ewaf aThe pplanalsowillre- The lawsuits r'isedand weref"''~,a plan submitted to the EPA T °~ a con oveisial new vehicle jargely anticipated by all Parties ~ December::2000 'falls 56 tons p q day short of .needed nitrogen ox- .inspection and maintenance Pro' to the plan, which was hit by a ide reductions. The EPA aclaiowl- gram scheduled to begin May. i sag of suits before it even made au roved that will cost motorists $35 -- it.off the drafting table. ve~ edges. the shortfall, but app the plan sa3'ing'that "enforceable $12.50 for the inspection and One of those suits was brought commitments," voluntary efto~ $22.50 for the emissions test. by the Business Coalition for and other incentive programs will Industry will be requu'ed to cut Clean Air Appel Group, an in- the make: up the deficit: emissions of nitrogen oxides by dustry group that argued the plan aclz to :90 percent. wouldn't reach its goal by 2007. be- the In their filings, environmental" uP cause it is based on flawed calcu- ate fists argue that a consent decree Uther Pttie use of cl ceaner diesel lations in a complex ;computer pub between the EPA and the Na- :requiring model of gouston's emissions and tional Resources Defense Council mereial use Hof gasoline-powered a~osphenc conditions: That suit ~y in a previous lawsuit ordered the ment between 6 am: ~ was settled out of court. : qu EPA to approve a plan that shows lawn equip the 5th Circuit on mo' exactly how the region intends to and noon from April 1 to Oct. 31 In petitioning ears to bad` meet the national standards- The starting in 2005; and a ban on ex- Monday, the coalition app large be challenging the scientific mod- red` ' plan the agency approved in Octo- cessive engine idling by ber does not do this, they say. commercial 1i-izcks- eling for ozone .formation in the. T they are Hous onwhich the mar, "It is unlawful for.the (EPA) to .Environmentalists say ton area up approve the State Implementa- increasingly concerned about P~ is based. The group says_a pan lion Plan (SIP) for-the fIOuston- provisions ~ measures,asuch as "collaborative" effort among it, ;Hate Galveston!,:., area because the "voluntary and e-commuting, the EPA and the Texas Natural Dec: g,eSOUrce Conservation Commis- JoB control measures ... ~ short by car pooling ~ not impos- lion, the state agency that drew for 56 tons, per day of reductions of .which are d~~~ the plan,• nitrogen oxide emissions," law- . Bible; to enforce. Such provisions up lead to an "unPrec recei yers wrote in the petition filed by .are supposed to reduce nitrogen edented" scientific investigation, lion Con- oxide emissions by 23 tons Per into the root causes of ozone. ::I GRASP, the Galveston. Bay g,egardless: o~u'hat the 5th Cir-. men ' servation and Preservation Also- ~ The Clean Air Act requires cuit judges decide; the current -view; ciation and Jane W: Elioseff, a rn- to th ozone P~ will; m some form, still"p Houston resident who says that a state air pollution plan whatever.•w;Hous causes her health problems. must account fox the reductions, vide the' basis o f , , es it was said David McIntosh, an attorney ended plan,ti1ay emerge, said A k • The petition also argu Jim Marston, executive director ~ now , unlawful for, the EPA to accept en for the National Resources De- of Environmental Defense and an =. -w'liat ; ; forceable".coiYimitments ``ui heu of • fence Council "What the state of attorney. ;about. actual emi5sxbTis'reductGOns" and ' 'Dexas has done is account for 23 situat that it wasp unlawful for~the EPA w~," tons and ~enforceable~ volun- If the judges seen is nll haveAto " unrav to accept,~a plan :.that did not ac-• tary, a Houston phy- TO the ag ~ which will count for.the:"future .growth ofv David Marrack, appose a federal plan, The•~ emissions„y~P,e~d irom;entaties;' sician~who Joined Environmental .most likely use the state .plan as ~ a` ... _. the .court, P• like the Port of •Iiouston. - Defense in petitioning roval its base. chairs "We want ,public, health .pro- said he wants the EPA app and C~ .. _,'___ ~~ '~ c. . ~~~' ~Sunrooms Inc- ' dditions & Garages! ' ~ We Also Build Room A • Patio Covers • Screenrooms Sunrooms • Patio Rooms ~ ::. :=~. vinyl /- ~ , , Replacement -tt•~- ~ ~~ ~ ^T666 ~ Insulated ' .2 x` ~ !~ Windows ~~ As Low As ,, :: ~ r ~ ~ ~ $299 (minimum 6 wvdowsl UP ~ ~ United indi ,.,yam Manufacturer's suggested pnce. :: -Yisit" Our Web Site At www.coolviewsunrooms.coin mind from ployee quent Altho~ August employE month 1 ron em' felt bet fiiianCli "OuT been s~ Je caac paca,u Zoo's ~• said fie wanted to contuiue the tradition thi`s~fall, ~~ ~ .«.. - - ~e but administrators recently learned uld , ; j See BONFIR' ~ 1:.~ • -eat •~-~_ ,, • ~'_ ~ ~; -~ ., ~ , gals defend -scl~nce »~ j'~ ~ - ~ ~ r behl w - er speed liml ~. ~'-, ~. i ~, ~. 2E ~ .Benefit seems.. small but cuts add a the. , _sa m . ~B ~ p~ .: Y,,. a'~ e~~r, `~P..~~, i• '~' a t 17A~ By RAD SALLEE ~ ~ bn,aalk shows~m~ etters to'the edttor ~ .are, 5E Houston Chronicle ~~ ~ '"•`andat the water tooler,~criticisrri_,of the ~ ~'`'~~ _'3A ~ so~alled"envirgnmentalspeed limit" fol-.~`~ ~ ""' 18A ~ ~ ~ lows two lines of thought: ' 1 C As some motorists strive to change old ` ^ A? vehicle going 55 mph ;actually pol- ~E Habits and others vow,civil dySOhe~ence,; lutes more than one. oin '7U~ not .less ;"~ the new. 55-mph speed limit'- intended ~ g•' ' g ' 'm to help cure Houston's: notorious; smo because the-`slower; vehicle ~akes longer ~~ problem - is` ur-der~attack' as nothing to ~~' its destination '' `. `.~ more than junk science: g 'Same conclusion, but based on the, Is it? aI'~ent that modern engines operate ' more' effiGent),y at higher speeds, y~ ~ '~;`' ~' Err}phatically, no; state 'pollution con- While these arguments `maj~~appear to - trol authorities say: But the expected. air - make senses they're simply not true; said , quality benefits are extremely small - . ~ ~~'~ who is in charge of transpor ` -less than 2'percent of the needed amount tation planning for the'~Houston "~ ~Id - for a`measure likely to annoy so many Galveston Ama Council , ` ~',' , . nd people : so much. `When I try to explain it to folks," Clark' . ~w The new 55-mph speed lirut ~ `~``~ of said,"I remind them that i .almost ~' a broader plan to reduce•ozone,pn the everyaar and truck burns less fuel?,per r~ :",;, eight~ounty Houston metro area to a fed= .' rrvle travehng'at,55,rnph thanj;at 70 mph. ° ' ' erally mandated- level by 2007. Some of . `~' Because~~you?re burnmg!;:less fuel, ` the reductions call for, _massive ,cuts - ' you re`errutting less air pollution. There's 90 percent from industrial sources = 1a Hale bit rriorerto it than that; but'that'S . while others shave here and there.. - See SPEED on Page^~6A. ~ r ~~ ,~ ~~~~~~ .- _ d~~em rs o~,grams will I~eS ~ U S `: Con- r : , -, '.. ~ _ ~ ' SI v'~ ._: p _ . Morial of _ - d~ to Bush's and other . Cortinued from Page 1A. ~ment. the essence of it." - eve proven .Nitrogen oxides, called NOX for :helping to short, and volatile organic com- U.S. cities. pounds (VOC), are the major ter to pay components of ground-level ozone pollution, sometimes re- challenge ferred to as smog. :publicans Measuring the amount of NOX r an eco- that pours from a tailpipe is done tincludes, , , in auto engineering: laboratories tax cuts using sophisticated equipment. efits. That data can then be applied to an is too traffic in a particular urban area. is asking Randy Wood, deputy director ncies to for environmental policy at the Texas Natural Resource Conser- i group of vation Commission in Austin - by House who is both a mechanical and ~eLay, R- ~eldng to "aerospace engineer -explains .that the Texas Transportation In- ~t in the ,stitute at Texas A&M University Auld allow' has the entire Houston-area road 1 et will g ' systetri "laid out in its computer." Fbr a given route and time of day, :war on he said, the program shows aver- ' oprotect 'age traffic volume speed and mix ' attacks " > of :vehicles..:' The amount;`.. of 1VOX emitted ~,~;; per. mile varies with a vehicle's ;. • speed, Wood said. `For most, he ions .that said, these. emissions bottom out d Impact oi~ew speed limit depends. on length of trip se docu- ~ ie before ~!m 45 to 55 mph and then nse as speed increases.;. For later- pollution control plan. " ected to account for a NOX reduc- i a ear model.vehicles, the rise`is not as steep as for older ones, but it's Stop-and-go driving adds to the problem because all vehicles also tion of about 12 tons a day, the tail i e test about 36 t T cial cpom- there' ~ burn more fuel, and thus pollute p p ons. o- gether; they would achieve about released in com- Several other .factors also go mto the mix, Wood noted more, when accelerating than when running at constant speed 7 percent of the needed reduc- i g ors, law- In general, the lighter a vehicle And aerodynamic drag - t ons, set at 750 to 800 tons a day under the state's air plan s for al- and the smaller and cleaner its,. which, along with inerlaa and Eric- . ed p~_ engine, the less improvement in tion, must be overcome for a ve- In the grand scheme, going :nron's Pollution from a lower speed. hide to move at all - is twice as slower and cleaner may account d wrong- As a group, Wood said, heavy- !n'eat at 70 mph as at 55; Wood for a small ,part of fhe clean air insiders. duty vehicles, including big said. ~ plan, officials admit, but every ton. Lay for trucks and larger pickups and The 55-mph speed limit is part- counts in a plan that -despite risibility .. .sport utility vehicles, release of a two-prong plan ,to cut vehicle these drastic measures -still ~ about 10 times the NOX per mile as -light-duty vehicles which in- emissions,-which the H-GAC esti- . mates produce 24 percent of NOX fall§ 56 tons' per day short of an and ying e h , .elude. cars and smaller icku s P p emissions in there on. ~ needed reductions. The state will scramble to come up with the rest y gat~ons and SUVs. That might seem to imply that The other ron certain to also elicit howls of'complaint from mo- during the next few years. is col- ` regulators should crack down on torists, is a tightened tailpipe test- big commercial trucks, but Wood ing program scheduled to begin Additional covera a online o e board . said these are federally regulated and fall outside;the state agency's May 1. The slower s eed limit is rof- www.houstonchr nicle.com/trattic ck posting of 55- h i P dtb p p mp s gns oa y road d stock - iainina . _ .w ° _- - --- --. _ .. •