Rep. Chang's testimony concerning DTE at the MDEQ March 11 public hearing

Wednesday, March 11, 2015

Below is Rep. Chang’s testimony given at The Michigan Department of Environmental Quality (MDEQ) information session and public hearing on Wednesday, March 11 concerning DTE Electric Company’s proposed new sulfur dioxide limits.                                         

Air quality is a major concern in Southwest Detroit, River Rouge, and Ecorse. Our district includes 48217, the most polluted zip code in the state of Michigan. Countless residents have talked with me about the air pollution in this area as well as family member after family member and friend after friend who has suffered from asthma, COPD, and various forms of cancer due to the cumulative impacts of air pollution from various sources in this region. As we all know, this region is in non-attainment for SO2 and I hope the MDEQ will work as hard as possible to make sure we have a state implementation plan that truly works. I know that DTE’s proposed plan includes a reduction in SO2 emissions. I hope this first step can be strengthened even further.

The EPA revised the former 24 hour SO2 standard to a new one hour standard of 75 parts per billion in 2010. Yes, the one hour standard for SO2 is more restrictive, but it can only be more restrictive if the companies who must abide by the standard actually is held to a reasonable standard of time. As is currently presented in DTE’s permit, the new SO2 emission limits that they add for 2017 and beyond are to use the time period of “720 clock hour rolling average, as determined at the end of each calendar day.”

It doesn’t take a rocket scientist to know that over 30 days there will be high points and lower points for emissions especially if a company knows it has had a spike in emissions and has more than enough time to correct. Averaging emissions over such a long period of time when the EPA’s revised standard is actually for a shorter period of time only serves to give DTE more flexibility instead of giving residents the reassurance that their health will not be put at risk on day one, two or 29 of that 30-day period. Any time at which the SO2 emissions are over a one hour limit, we should know and any company should be held accountable.

Sulfur dioxide can be harmful to human health for short-term exposures, not just for the 30 day range that DTE proposes. On the EPA’s website[i], it says “Current scientific evidence links short-term exposures to SO2, ranging from five minutes to 24 hours, with an array of adverse respiratory effects including bronchoconstriction and increased asthma symptoms.” The EPA goes on to say “Sox (sulfur oxides, which is related to SO2) can react with other compounds in the atmosphere to form small particles. These particles penetrate deeply into sensitive parts of the lungs and can cause or worsen respiratory disease, such as emphysema and bronchitis, and can aggravate existing heart disease, leading to increased hospital admissions and premature death.”

It is my understanding that DTE will be changing what types of coal they use and switch to a type of western coal that has a lower sulfur content and that in the future, additional steps may be taken. That is clearly a step in the right direction but I urge the MDEQ to hold DTE to a high standard. I want to reiterate that the state implementation plan that MDEQ is working on needs to be strong and this permit review needs to reflect that. We all deserve clean air to breathe and an assurance that our public health will be protected. Our residents deserve better.