Speaking Up Against TEP's Proposed Gas-fired Generators

As I mentioned in a previous blog, TEP is proposing modernizing the Sundt Generating Station by replacing two 1950's era steam units with ten natural gas fired combustion engines. The RICE units are fossil-fuel based generating units that would create significant greenhouse gas emissions. According to the Pima Department of Environmental Quality, the project expects to cause an increase in emissions of carbon monoxide, particulate matter and volatile organic compounds.

Last night 30 people from the Irvington neighborhood and our Tucson community attended the march to protest the gas-fired engines being installed in their neck of the woods. 50 people showed up to show support at PDEQ's public hearing. 30 of those, myself included, spoke up.

Some people explained how carbon dioxide from the engines would accelerate climate change and how that would devastate our city. But I'm afraid those comments about green house emissions won't have any impact. We were limited to commenting on how TEP's permit meets the criteria for issuance prescribed in the Arizona Revised Statutes, Section § 49-481 of the Pima County Code.  All of those important comments about climate change were disregarded because CO₂ isn't included in Pima's code. (I know! I couldn't believe it either!)

A few of us from Sustainable Tucson's advocacy group and the Sierra Club have been combing through Pima's code - trying to find some inconsistencies or ANYTHING we can use stop the PDEQ from issuing a permit for the RICE engines.  The deadline for comments to the PDEQ was Thursday, March 29th.  Here are some angles that our team member uncovered. 

But what I found to be really powerful was how the people from the neighborhood spoke their truth to power. They bravely told stories about how TEP's environmental racism had impacted the health of their loved ones. I think that might just be the angle we need for our comments to the PDEQ. On their letter announcing this hearing,  they wrote:

Pima County has completed an extensive review of the permit application, examined the air quality impact analysis of the project and considered environmental justice to protect the health and environment of minority, low-income, tribal and indigenous populations.

After hearing the heartfelt comments from people in the neighborhood, something occurred to me.  I believe that PDEQ did not take into account the special circumstances of how the pollutants from the new gas-fired engines would impact the vulnerable population that is already suffering from cancer, lupus, asthma, heart valve defects, birth defects, arthritis, and central nervous system disorders from decades of dioxane in  their water and the pollution from Sundt's coal-fired plants. 

A 2010 study by the Clean Air Task Force showed the burning of coal at Sundt causes approximately 68 asthma attacks, 6 heart attacks and 4 deaths every year. Built in 1967, the Sundt plant ranked 13th worst in the NAACP’s environmental justice performance ranking.

https://www.sierraclub.org/planet/2015/09/h-wilson-sundt-generating-station-stops-burning-coal

If you're a member of one of the families who suffered from any of these diseases, you might want to use this angle and share your story for the record.  I encourage you to back it up with data (included on this blog and the links provided). (The deadline  has expired. It was Thursday, March 29th.)  Here are the directions. 

TEP’s environmental justice argument leaves things to argue with:

TEP’s Environmental Justice Analysis duly notes the goal of Executive Order 12898, that “each Federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations.”

TEP notes the stark socioeconomic divide between the population in its 38 square-mile Impact Area – a full 18% of our City’s population – and the 82% of Tucsonans who live outside the plant’s shadow. “Minority” (i.e. global majority) 85% (Tucson 56%); Low income 63% (Tucson 51%); Linguistically isolated: 15% (Tucson 6%); % w/o HS diploma 32% (Tucson 17%). Although asthma rates are not broken down to a small scale, TEP noted that between 2012 and 2014, CDC recorded a nationwide increase from 7.0% to 8.4% while Arizona’s statewide number climbed from 8.9% to 9.6%.

For inconsistencies in TEP's Environmental Justice Analysis, scroll down to:

TEP’s environmental justice argument leaves things to argue with with on this page:

I will leave you with Oscar Medina's speech for inspiration:

"My name is Oscar Medina. I am a father, an educator, member of Sierra Club, and a community organizer with Tierra y Libertad Organization. I am here today to express my concern and opposition to TEP’s proposal for 10 new Reciprocating Internal Combustion Engine (RICE) natural gas units at the Sundt Plant location.

I live less than 2 miles away from the TEP’s Sundt Plant location. I have three children: One who attends the Tucson Gymnastics center located near the intersection of Irvington and Alvernon Way. We drive by the plant at least three times a week and the facility does not appear to look the healthiest. My daughter’s school is located just one mile from the intersections of Drexel and Alvernon Way. This is only a few hundred feet from location of the proposed RICE units.

I attended the neighborhood meetings that were hosted by TEP and gave my testimony in opposition to their application at the Arizona Corporation Commission hearing. TEP is framing this project as a campus modernization project. This is deceiving to our community. This expansion project is not about people or the environment, this is about cutting cost and putting profit into the pockets of the TEP investors. At the open house meeting Feb. 15th, I learned from the Pima County Department of Environmental Quality that in the past, TEP has not always complied with the air quality regulations, and that air monitoring reports demonstrated excessive carbon monoxide emission. This demonstrates that TEP is not afraid the break the rules again and pollute our neighborhoods.

The open houses that were held before this hearing were not only missing people from the surrounding neighborhoods but they were missing the pictures of children suffering from respiratory illness in parts of south Tucson. The open house was missing pictures of the effects that emissions of carbon monoxide have on people's health. Let's put the bar graphs and data to the side and paint a clear picture. Our children can see right through TEP’s dirty data. This is another clear example of the ongoing environmental racism still occurring in 2018. This fight against pollution that goes years back to the San Juan and Navajo generating stations. Where are the reparations for harming our Dine* brothers and sisters? That is a dark history that TEP does not wish remember. TEP’s plans and their time frame to expand renewable energy resources to 30 percent by 2030 has expired for our neighborhoods. The stakes are too high. TEP’s polluting practices are not welcome in our backyards. Remember that we are the people that breath this dirty air. Let's keep it clean and simple, divest from coal and gas, keep it renewable and let the future be wind and solar energy."

*The word Dine' is from their own language and means "the people." 

The time for action is NOW - while we still have this little window of opportunity. This is something concrete we can do to leave a better life for our children in Tucson. Let's make those brave speeches count!