To: North West Region Air Quality Permit Coordinator at the Department of Environmental Quality
Oregon Physicians for Social Responsibility and the undersigned health professionals and public health advocates are writing to the Department of Environmental Quality (DEQ) with regard to Houston-based NEXT Renewables LLC’s proposed air permit for a renewable diesel facility in Port Westward.
Guided by the values and expertise of medicine and public health, Oregon Physicians for Social Responsibility (PSR) is a statewide organization of more than 2,000 health professionals and public health advocates working to protect human life from the gravest threats to health and survival, including environmental pollution. We have an almost 40-year history of advocating for environmental health for all Oregonians.
We urge you to reject the proposed air permit for the NEXT refinery proposal at Port Westward, Oregon. The proposed air pollution permit will allow harmful pollution to adversely impact nearby farmland, ecosystems, and residents. DEQ’s draft permit would allow the project to emit significant hazardous air pollution, particulate matter, and smog-forming volatile organic compounds (VOCs). Many of these pollutants are known to have adverse effects on both health and the environment, and given the proposed location, it is especially imperative that the air permit not be approved.
- NEXT’s Proposed refinery and its pollution would have a major impact on the community near Port Westward. This is a community with residents, family farmers, businesses, and a nearby Buddhist monastery. We are concerned for the surrounding community and environment as hazardous chemicals, particulates, and other pollution will come from the refinery and rail yard. Additionally, the proposed air permit does not provide for a clear resolution process if the pollution has a negative impact on neighboring communities' health or crops.
- The proposed permit fails to establish adequate limits or monitoring for particulate matter. The World Health Organization (WHO) has noted in September of 2021 that “no threshold has been identified below which no damage to health is observed.” (1) Chronic exposure to these small particles in the air we breathe contributes to the risk of developing or dying from serious diseases including cancer, cardiovascular, and pulmonary disease. (2) We thus urge you to say no to the proposed 27 tons of particulate matter per year.
- The constraints on air pollutants such as benzene, toluene, naphthalene, and hydrogen sulfide are inadequate. For instance, the proposed limits for hazardous pollutants such as 9 tons per year of hydrogen sulfide (characteristic odor of rotten eggs) are too high. Exposure to low concentrations of hydrogen sulfide has the potential to harm the human respiratory system and make breathing difficult. (3)
- DEQ should provide a clear description of the facility’s overall fracked gas use. The facility will include gas burning equipment. How will DEQ hold NEXT accountable for limiting methane leaks and emissions?
-Additionally, the permit doesn’t show how DEQ will enforce limits on volatile organic compounds (VOCs) during startup and shut down events. Without proper controls, the facility could become a major emitter of VOCs. The proposed VOC levels will contribute to the formation of ground-level ozone in the area and beyond, along with NOx. Breathing ozone causes respiratory harm and is likely to cause cardiovascular harm and early death. (4)
-Finally, we strongly urge DEQ to consider the local air quality context when considering an increase to local hazardous air pollution, particulate matter, and smog-forming volatile organic compounds (VOCs). NEXT will add to local air pollution and combine with existing pollution from other sources such as an oil/ethanol/diesel terminal and nearby power plant. As air pollution combines and is carried over long distances by the wind, the project will impact residents of Cowlitz County, who will also face diminished air quality.
Amidst this climate crisis, we need to take into account communities who will be the most impacted by hazards and be cognizant of compounding threats to health and the environment. We urge DEQ to reject the air permit proposed for NEXT.
Thank you for your attention to our concerns.
(1) World Health Organization Factsheet https://www.who.int/news-room/fact-sheets/detail/ambient-(outdoor)-air-quality-and-health
(2) Kyung, S. Y., & Jeong, S. H. (2020). Particulate-Matter Related Respiratory Diseases. Tuberculosis and respiratory diseases, 83(2), 116–121. https://doi.org/10.4046/trd.2019.0025
; Pope CA, III, Burnett RT, Thun MJ et al. Lung cancer, cardiopulmonary mortality, and long term exposure to fine particulate air pollution. JAMA 2002; 287(9):1132-1141.
(3) Environmental Protection Agency https://www.epa.gov/so2-pollution/sulfur-dioxide-basics#effects
(4) U.S. EPA. Integrated Science Assessment (ISA) for Ozone and Related Photochemical Oxidants (Final Report, Apr 2020). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-20/012, 2020; Gent, J. F., Triche, E. W., Holford, T. R., Belanger, K., Bracken, M. B., Beckett, W. S., & Leaderer, B. P. (2003). Association of low-level ozone and fine particles with respiratory symptoms in children with asthma. Jama, 290(14), 1859-1867.