Texas Clean Air Matters

Selected tag(s): Protocol

On the Record: Our Comments Submitted to TCEQ

By Matthew Tejada, PhD Executive Director Air Alliance Houston and Elena Craft, PhD Health Scientist

It’s time to wait and see.

If the Texas Commission on Environmental Quality earnestly considers comments we co-submitted this month in response to its draft “Protocol for Notification and Work Group Functions for Evaluating Potential and Active Air Pollution Watch List (APWL) Areas,” it will signal a new era in the agency’s commitment to reducing levels of air toxics around the state. We especially welcome the appointment of a dedicated staff position to manage the APWL program. [See Dec. 2 blog post for more background on the APWL and “toxic hotspots.”]

However, we wanted to go on record here expressing our concern that the program’s ultimate effectiveness could be fundamentally undermined if the agency does not adopt the APWL protocol as rule. Clean air advocates have long maintained that a program as critical as this, designed to protect the health of Texans, calls for a rulemaking. We believe that putting the APWL program in rule will provide the best possible “middle ground” for such a program – short of the rigidity of statute, yet firmer than mere agency program or directive. Read More »

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