• drrobertbullard@gmail.com

Comments of Dr. Robert D. Bullard on EPA’s Proposed Updates to Refinery Emissions Standards

August 09, 2014

Norco Kids at ParkGood morning. My name is Dr. Robert D. Bullard and I am Dean of the Barbara Jordan-Mickey Leland School of Public Affairs at Texas Southern University located in Houston.  First, I want to thank the EPA for holding this hearing and allowing the public to speak.  It is also significant where this hearing is being held in EPA Region 6—not at the regional office in Dallas but in Galena Park—a refinery community that typifies why these new proposed rule changes are desperately needed.  I have to ask, “What took you so long?” That’s a rhetorical question.  We all know the answer.

For the past three decades, I have worked with residents who live on the feneline with refineries in California, Michigan, New Jersey, Pennsylvania, Louisiana and Texas.  I have traveled in dozens of these communities and have seen with my own eyes and heard with my own ears enough “horror” stories to fill at least a dozen of my books.

Fenceline communities have waited for years for meaningful federal protection from the pollution from refineries. Many state environmental agencies have failed in providing this much needed protection.  Many environmental justice communities have little confidence in the states to lead on refinery emissions reduction.  That’s why what is being proposed by the EPA is a big deal. The agency estimates that the rules will reduce toxic air emissions by 5,600 tons a year. Many of us had hoped the agency would go even further. Nevertheless, I strongly support EPA’s effort to move forward—instead of backward when it comes to refinery emissions.  Residents who live on the fenceline with these refineries have a right to know what they are breathing and how these chemicals may affect their health. These residents also have a right to be protected from harmful pollutants.

Refineries are not randomly distributed across the American landscape and most Americans don’t live next to one.  So for too long the problems, concerns and challenges of fenceline communities have been somewhat invisible and ignored by government. We all wish emission controls and level of protection were such that the refinery CEOs and their spouses, children and grandmothers would feel safe living next door.  However, they don’t live next door to these facilities.  We know who lives next door to the refineries in the Gulf Coast in Louisiana’s petrochemical corridor along the Mississippi River from Baton Rouge to New Orleans, in Port Arthur, Houston and Corpus Christi, Texas.  The affected communities living in close proximity to refineries do not look like America.  They are disproportionately Latino, African-American, and low-income with higher percentages of children. Many of these neighborhoods have schools, parks and playgrounds, and low-income public housing next-door to these refineries which pose potential health threats to our most vulnerable population—children.

This is not a pretty picture.  The EPA should not allow any families and especially innocent children to be overburdened with pollution and their neighborhoods to become toxic “sacrifice zones.” This is unacceptable.  Requiring oil refiners to take more aggressive measures to reduce their toxic emissions from flares, storage tanks and other sources is a big deal. The impact of these new requirements will have disproportionate positive benefits to fence line communities who have too long suffered from refinery pollution. And in the end, our entire society benefits because of fewer illnesses and hospital visits.

Numerous studies, including some of my own, have documented that poor people and people of color in the United States are disproportionately impacted by environmental hazards in their homes, schools, neighborhoods, and workplace. Refinery pollution poses special health threats to community residents that generally have higher concentration of uninsured—heightening their vulnerability.

One need not be a rocket scientist to understand dumping pollution on communities that have persistent health disparities can only make matters worse.  Residents in these communities are exposed to higher levels of pollution than the rest of the nation and experience certain diseases in greater number. Residents who live on the fenceline with refineries are paying a high price in the form of higher medical bills, missed school and work days, and loss wages.  The proposed rules would require refiners for the first time to measure concentrations of benzene at their fence lines and provide the data to the public. Exposure to toxic air pollutants, such as benzene, can cause respiratory problems and other serious health issues, and can increase the risk of developing cancer.

EPA should require fence line monitoring that mandates use of the best current technology to give neighborhoods a real-time, continuous measure of pollution, and not just a snapshot or long-term average that masks peak exposure levels. To be effective, the standards also must be accessible to the public, enforceable and requiring corrective action be taken by refineries that quickly fix violations. These new rules also would require refiners to upgrade pollution controls for storage tanks and to ensure that gases are properly destroyed through flaring. EPA should also allow public access to the monitoring report of flares.

We are pleased that EPA has committed to undertaking this long overdue rulemaking and we urge the agency to use its authority to ensure equal protection from pollution for all Americans. Thank you

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