{"id":20533,"date":"2023-08-03T16:42:44","date_gmt":"2023-08-03T16:42:44","guid":{"rendered":"https:\/\/www.insurancejournal.com\/?p=733714"},"modified":"2023-08-03T16:42:44","modified_gmt":"2023-08-03T16:42:44","slug":"texas-policy-protects-big-polluters-from-citizen-complaints","status":"publish","type":"post","link":"https:\/\/blog.lifeinsurance-orleans.ca\/index.php\/2023\/08\/03\/texas-policy-protects-big-polluters-from-citizen-complaints\/","title":{"rendered":"Texas Policy Protects Big Polluters From Citizen Complaints"},"content":{"rendered":"<ul class=\"nav nav-tabs tabs tabs-entry\">\n<li class=\"active\"><a href=\"https:\/\/www.insurancejournal.com\/news\/southcentral\/2023\/08\/03\/733714.htm\">Article<\/a><\/li>\n<li><a href=\"https:\/\/www.insurancejournal.com\/news\/southcentral\/2023\/08\/03\/733714.htm?comments\" rel=\"nofollow\">0 Comments<\/a><\/li>\n<\/ul>\n<div class=\"article-content clearfix\">\n<p>PORT LAVACA \u2014 On a rugged stretch of the Gulf Coast in Texas, environmental groups called foul in 2020 when an oil company sought pollution permits to expand its export terminal beside Lavaca Bay.<\/p>\n<p>Led by a coalition of local shrimpers and oystermen, the groups produced an analysis alleging that the company, Max Midstream, underrepresented expected emissions in order to avoid a more rigorous permitting process and stricter pollution control requirements.<\/p>\n<div class=\"bzn bzn-sized bzn-intext\">\n<ins data-revive-zoneid=\"79\" data-revive-block=\"1\" data-revive-id=\"36eb7c2bd3daa932a43cc2a8ffbed3a9\"><\/ins> <\/div>\n<p>In its response, Max Midstream did not respond to those allegations. Instead, it cited what it characterized as the \u201cquintessential one-mile test\u201d by Texas\u2019 environmental regulator, the Texas Commission on Environmental Quality, to claim that the groups and citizens involved had no right to bring forth a challenge because they lived more than 1 mile from the Seahawk Oil Terminal.<\/p>\n<p>\u201cThe well-established Commission precedent has been repeated again and again,\u201d the lawyers wrote. \u201cBased on the quintessential one-mile test relied upon by the Commission for decades, none of the Hearing Requests can be granted.\u201d<\/p>\n<p>The TCEQ agreed, rejecting all hearing requests and issued the permit as initially proposed.<\/p>\n<p>But the agency says the 1-mile test cited by the company\u2019s lawyers doesn\u2019t exist.<\/p>\n<p>\u201cThe Commission has never adopted a one-mile policy,\u201d said TCEQ spokesperson Laura Lopez. \u201cInstead, the Commission applies all factors set out in statute and rules.\u201d<\/p>\n<p>Indeed, the test is not codified in Texas law or TCEQ rules. Yet it appears consistently in TCEQ opinions going back at least 13 years as a means to restrict public challenges to air pollution permits. It has been cited repeatedly by industry lawyers and denounced by environmental advocates.<\/p>\n<div class=\"bzn bzn-sized bzn-intext-2\">\n<ins data-revive-zoneid=\"162\" data-revive-block=\"1\" data-revive-id=\"36eb7c2bd3daa932a43cc2a8ffbed3a9\"><\/ins> <\/div>\n<p>\u201cThis practice is arbitrary and unlawful,\u201d said Erin Gaines, an Austin-based senior attorney with the nonprofit Earthjustice. \u201cTCEQ\u2019s practices prevent people from having a meaningful voice in the permitting process for polluting facilities in their community.\u201d<\/p>\n<p>U.S. law requires that states provide citizens with the opportunity to challenge pollution permits in federal court. The rules regarding who may bring forth challenges are laid out in Article III of the U.S. Constitution, which doesn\u2019t say anything about a distance limit.<\/p>\n<p>Dozens of Texas environmental groups have argued in petitions before the U.S. Environmental Protection Agency that TCEQ unlawfully restricts access to judicial review, including through the 1-mile rule, and litigants in the Max Midstream case have now challenged the use of the 1-mile rule in federal court and are awaiting a hearing set for this fall.<\/p>\n<p>The TCEQ, which is responsible for implementing federal pollution laws in Texas, issued its blanket denial that the rule exists despite a list of more than 15 cases compiled by Inside Climate News that centered on the 1-mile standard. In some, it was explicitly cited by TCEQ itself, or by industry lawyers. In others, the 1-mile standard is depicted on maps produced by the TCEQ. In each case, the distance standard is the main or the only justification offered for granting or denying citizens\u2019 hearing requests.<\/p>\n<p>Last year the nonprofit Earthjustice reviewed 460 requests for air permit hearings between 2016 and 2021. It found that while requests from citizens living within 1 mile of a facility comprised 12% of the requests, they comprised 83% of the requests the agency granted; almost all of the remaining 17% of granted requests came from people who lived only slightly farther than 1 mile away.<\/p>\n<p>\u201cTCEQ\u2019s actions speak for themselves,\u201d Gaines said. \u201cTCEQ routinely denies hearing requests from members of the public unless they own property within one mile of a facility.\u201d<\/p>\n<p>The 1-mile standard<\/p>\n<p>Texans who wish to challenge TCEQ permit decisions must file a request with the agency. Its executive director reviews those requests and recommends whether or not the agency\u2019s three commissioners, all appointed by the Republican governor of Texas, should grant them.<\/p>\n<p>To do that, the executive director assesses whether the challengers qualify as \u201caffected persons\u201d with legal standing to bring forth complaints. Texas\u2019 administrative code considers an \u201caffected person\u201d anyone who will be \u201caffected by the application\u201d in a way that is not \u201ccommon to members of the general public.\u201d<\/p>\n<p>When formulating recommendations, the TCEQ\u2019s Lopez said, the executive director \u201cconsiders many factors, only one of which relates to the location of the facility.\u201d<\/p>\n<p>However, a review of the agency\u2019s recommendations shows that the distance standard is regularly the only factor used to recommend rejection of hearing requests.<\/p>\n<p>It appears in writing as far back as 2010, when 36 people challenged a permit renewal for a gas processing plant in northeast Texas, mostly complaining about odorous hydrogen sulfide gas coming from the facility\u2019s flares.<\/p>\n<p>\u201cThe Executive Director has generally determined that hearing requestors who reside greater than one mile from the facility are not likely to be impacted differently than any other member of the general public,\u201d wrote the executive director at the time, Mark Vickery, who is now a lobbyist for the Texas Association of Manufacturers. \u201cFor this permit application, the Executive Director\u2019s staff has determined that no requestors are located within one mile of the proposed facility.\u201d<\/p>\n<p>The permit renewal in question was not eligible for a hearing anyway, Vickery wrote, because it posed no changes from its original form.<\/p>\n<p>His recommendation: none of the requestors should be recognized as affected persons. The TCEQ commissioners agreed.<\/p>\n<p>\u201cAll requests for a contested case hearing are hereby DENIED,\u201d wrote then-TCEQ Chair Bryan Shaw, who is now a lobbyist for the Texas Oil and Gas Association.<\/p>\n<p>\u201cRule of thumb\u201d<\/p>\n<p>By 2014, the rule was well known among lawyers for industrial developers. That year, 16 members of the Danevang Lutheran Church in rural Wharton County requested a hearing over plans to build a gas-fired power plant in their tiny town.<\/p>\n<p>In written arguments to the TCEQ, lawyers for the plant developer, Indeck Wharton, wrote, \u201cA key factor the Commission frequently uses as guidance on the distance issue is the one-mile \u2018rule of thumb.&#8217;\u201d<\/p>\n<p>\u201cWhile it is not an immutable rule, the Commission frequently uses it as a guide,\u201d the lawyers wrote. \u201cIt is not found in any statute, regulation or guidance document. Instead, it is founded in common sense and experience.\u201d<\/p>\n<p>TCEQ\u2019s executive director at the time, Zak Covar, then invoked the 1-mile limit.<\/p>\n<p>\u201cAlthough the church is within one mile of the proposed facility, the request does not claim that any person resides at the church,\u201d Covar wrote before the commissioners denied the church members\u2019 request for a hearing and issued the permit as proposed.<\/p>\n<p>In 2017, the TCEQ received 16 hearing requests \u2014 including from local residents, a Texas A&amp;M University chemist and the Bryan Independent School District \u2014 over plans by Saint-Gobain Ceramics and Plastic Inc., to build a facility in Bryan.<\/p>\n<p>\u201cBecause distance from the facility is key to the issue of whether there is a likely impact \u2026 the ED has identified an area of approximately one mile from the plant on the provided map,\u201d wrote the executive director at the time, Richard Hyde.<\/p>\n<p>Only Jane Long Intermediate School sat within the 1-mile radius. So TCEQ denied 15 hearing requests and granted the school district\u2019s. Later, the school district withdrew its hearing request, citing a settlement agreement with Saint-Gobain, and TCEQ approved the permit application.<\/p>\n<p>Two years later, when Annova LNG applied for permits to build a gas compressor and terminal on the Rio Grande delta, the nearby city of South Padre Island requested a hearing.<\/p>\n<p>\u201cThe City stated that it is located more than one mile from the proposed terminal,\u201d wrote the executive director at the time, Toby Baker. \u201cGiven the distance of the City from the proposed terminal, the ED recommends that the Commission find that the City is not an affected person.\u201d<\/p>\n<p>The commission agreed. Hearings were denied and a permit was issued.<\/p>\n<p>Also in 2019, 36 residents requested hearings over permits for a concrete plant in Midlothian. The nearest of them, Sarah Ingram, lived 1.2 miles away and expressed concern about the health of her children when protesting the pollution permit.<\/p>\n<p>\u201cAs none of the requestors reside within one mile of the plant\u2019s emission point, they are not expected to experience any impacts different than those experienced by the general public,\u201d Baker wrote.<\/p>\n<p>Commissioners denied all requests and granted the permit as proposed.<\/p>\n<p>In 2020, the nonprofit Lone Star Legal Aid filed a hearing request on behalf of Port Arthur resident John Beard over a developer\u2019s plans to build an LNG export terminal.<\/p>\n<p>According to the request, Beard regularly spends time on Pleasure Island, an 18-mile long recreational area in Port Arthur that runs as close as 900 feet from the proposed terminal site, in his capacity as the chair of the Pleasure Island Advisory Board.<\/p>\n<p>In evaluating the request, the TCEQ only considered Beard\u2019s home address, 4 miles away.<\/p>\n<p>\u201cBeard is not an affected person in his own right because he is located almost 4 miles from the facility,\u201d wrote Baker, the executive director.<\/p>\n<p>Lone Star Legal Aid filed an 11-page response, claiming \u201csites like Port Arthur LNG require the commission to consider a larger impact area than merely a mile,\u201d and that \u201cthere are no distance restrictions imposed by law on who may be considered an affected person.\u201d<\/p>\n<p>TCEQ referred the question to the State Office of Administrative Hearings, where an administrative law judge agreed with Lone Star Legal Aid, writing, \u201cthe Applicant\u2019s own data indicated that operation of the Proposed Facility will result in increased levels of [nitrogen oxides] and [fine particulate matter] at Mr. Beard\u2019s residence.\u201d<\/p>\n<p>The administrative judge declared Beard an \u201caffected person\u201d and ordered a hearing over the pollution permit, which was held in February 2022. A second administrative judge also agreed with some of Lone Star Legal Aid\u2019s complaints and recommended that the TCEQ require Port Arthur LNG to use better pollution control technology that would lower emissions of nitrogen oxides and carbon monoxide from the facility\u2019s eight gas compressor turbines.<\/p>\n<p>But the commissioners rejected most of the judges\u2019 recommendations, calling them \u201ceconomically unreasonable,\u201d and approved the permit.<\/p>\n<p>Meanwhile, TCEQ has granted hearing requests for requestors who live within a mile. In 2015, a group called Citizens Alliance for Fairness and Progress in Corpus Christi requested a hearing over air pollution permits for a planned expansion at a Citgo Refinery, and identified group members living a few blocks from the refinery.<\/p>\n<p>Five years later, the executive director recommended granting the request \u201cbecause the Alliance identifies as members residents [sic] that reside within one mile of the proposed facility.\u201d Citgo withdrew its application before a hearing was held.<\/p>\n<p>Legal complaints<\/p>\n<p>The country\u2019s landmark environmental laws, the Clean Air and Clean Water acts, require states to provide opportunities for citizens to challenge pollution permits in court, a process known as judicial review, so a judge may evaluate if permits are consistent with federal standards.<\/p>\n<p>Texas law provides such opportunities in its health and safety code, which reads: \u201cA person affected by a ruling, order, decision, or other act of the [TCEQ]\u2026 may appeal the action by filing a petition in a district court.\u201d<\/p>\n<p>But multiple petitions to the EPA have alleged that Texas courts will only take up pollution permit complaints if the plaintiff has already been through a \u201ccontested case hearing\u201d in administrative courts run by the state. Thus, by denying complainants\u2019 requests for contested case hearings, often citing the 1-mile standard, the TCEQ controls their access to the courts.<\/p>\n<p>\u201cParticipation in the contested case hearing process is a prerequisite to seeking judicial review of a TCEQ permitting decision,\u201d reads one 38-page petition filed with the EPA in 2021 by 22 Texas environmental groups, focused on TCEQ\u2019s water pollution management. \u201cThis empowers the TCEQ full discretion to deny any person the right of judicial review.\u201d<\/p>\n<p>Where federal law is concerned, requirements for access to judicial review are laid out in Article III of the U.S. Constitution. When states are charged with enforcing federal law, they may not impose limits beyond what the Constitution says, according to Gaines, the environmental attorney with Earthjustice in Texas.<\/p>\n<p>In another 61-page petition filed last year with the EPA over TCEQ\u2019s air pollution management, 11 Texas environmental groups said the contested case hearing process is absent from the sweeping pollution management plans that Texas, like all states, must submit to the EPA for approval.<\/p>\n<p>That process, the petition says, includes \u201can arbitrary presumption that only those who own property or live within 1 mile of a proposed new or modified source are affected persons entitled to participate in a contested case hearing.\u201d<\/p>\n<p>\u201cWhile not codified anywhere, this \u2018rule of thumb\u2019 is used regardless [of] how large the source is, the character of the emissions, the size of a facility\u2019s stacks, or local meteorological conditions,\u201d the petition said.<\/p>\n<p>For that petition, an Earthjustice analysis showed that TCEQ granted only 12% of hearing requests between 2016 and 2021 \u2014 virtually all of them from people who lived within a mile or just slightly further from the applicant\u2019s location.<\/p>\n<p>Early this year, the EPA responded to the 2021 petition and said it was \u201cinformally investigating the allegations.\u201d<\/p>\n<p>\u201cIf proven to be true, the allegations outlined in the Petition are concerning,\u201d Charles Maguire, the EPA deputy regional administrator, wrote in January.<\/p>\n<p>The EPA can revoke a state\u2019s authority to implement federal environmental law if the state regulator does not meet program requirements, Maguire wrote, including \u201cfailure to comply with the public participation requirements.\u201d<\/p>\n<p>A spokesperson for EPA Region 6, Jennah Durant, told Inside Climate News, \u201cBecause both petitions are still under review, EPA cannot provide further details at this time.\u201dDurant declined requests for interviews with Region 6 administrator Earthea Nance and did not respond to questions about why only informal investigations were launched.<\/p>\n<p>\u201cIf states start to deviate too much from national expectations about good implementation enforcement, which includes access to judicial review, the EPA can disapprove of the state\u2019s plan,\u201d said Cary Coglianese, director of the Penn Program on Regulation at the University of Pennsylvania. \u201cIt\u2019s not a threat that\u2019s used often and it can\u2019t be used lightly.\u201d<\/p>\n<p>The case of Max Midstream<\/p>\n<p>Diane Wilson filed her first hearing request with the TCEQ in 1989. Since then, she\u2019s filed over a hundred more, she guesses. Only twice has she been recognized as an affected person, in 1998 and 2015.<\/p>\n<p>\u201cYou ask any activist out there, any grassroots person, and they will tell you the same thing about TCEQ,\u201d she said. \u201cThey\u2019re in a big love affair with industry.\u201d<\/p>\n<p>Wilson, who leads an organization called San Antonio Bay Estuarine Waterkeeper, filed a challenge with the TCEQ when Max Midstream sought its permit to discharge airborne toxins including \u201chazardous air pollutants\u201d such as hydrogen sulfide, carbon monoxide, nitrogen oxides, sulfur dioxide, volatile organic compounds and fine particulate matter, all known by the EPA to cause cancer and other serious health impacts.<\/p>\n<p>Her organization, together with the Environmental Integrity Project and Texas Rio Grande Legal Aid, obtained data from Max Midstream\u2019s permit application for the Seahawk Oil Terminal, analyzed it and concluded that the company underrepresented expected emissions in order to avoid a more rigorous review process for larger pollution sources.<\/p>\n<p>That was when lawyers for Max Midstream cited the 1-mile rule.<\/p>\n<p>\u201cBased on consistent Commission precedent,\u201d the lawyers wrote. \u201cOnly a property owner with an interest within one mile or slightly farther could possibly qualify for a contested case hearing.\u201d<\/p>\n<p>\u201cIt\u2019s crazy they say that,\u201d said Wilson, 75, as she sat in a bayside park in Port Lavaca. She pointed across the water to the sprawling Formosa Plastics Corp. A plant that stood prominently on the horizon, some 7 miles away \u2014 farther than Max Midstream. \u201cI have been here and watched releases from that plant come clear across the bay. It\u2019s like a fog come in.\u201d<\/p>\n<p>She submitted to the TCEQ analysis from Ranajit Sahu, a private environmental consultant in California who previously managed air quality programs and has a Ph.D. from the California Institute of Technology. He testified that harmful health impacts from the terminal could extend up to 5 miles away.<\/p>\n<p>She also pointed to a 2009 study, led by a researcher at Texas A&amp;M University and published in the journal Ecotoxicology, which linked clusters of genetic damage among cows in Calhoun County to industrial emissions up to 15 kilometers (9.3 miles) away. The largest cluster identified was 7 kilometers (4.3 miles) from the industrial facilities.<\/p>\n<p>Nevertheless, in a 2022 opinion, Baker, the TCEQ executive director, sided with Max Midstream. Although Wilson had stated that she regularly spent time near the site of the proposed facility, her home was 16 miles away in the town of Seadrift.<\/p>\n<p>Baker wrote: \u201cGiven the distance of Ms. Wilson\u2019s residence relative to the location of the terminal, her health and safety would not be impacted in a manner different from the general public. Therefore, the ED recommends that the commission find that Diane Wilson is not an affected person.\u201d<\/p>\n<p>The director used the same reasoning to recommend rejection of hearing requests from five residents in Port Lavaca, about 4 miles across the water from the Seahawk terminal \u2014 a complex of huge storage tanks, marine loading docks and a pump station to move oil through a 100-mile pipeline.<\/p>\n<p>They included Mauricio Blanco, a 51-year-old shrimper who said he spends nine hours per day on the water close to the proposed facility, even though he lives 6 miles away.<\/p>\n<p>Also included: Curtis Miller, 61, owner of Miller\u2019s Seafood, a national wholesaler of shrimp, fish and oysters started by his uncle in the 1960s, with its headquarters on the bayside in Port Lavaca.<\/p>\n<p>In official comments, he told the TCEQ he would be harmed economically by increased air emissions because carbon dioxide from the terminal will contribute to acidification of bay waters, harming the oyster population he depends on.<\/p>\n<p>Baker acknowledged Miller\u2019s economic concerns, but concluded that \u201cbased on his location relative to the terminal, Mr. Miller\u2019s health and safety would not be impacted in a manner different from the general public.\u201d<\/p>\n<p>Miller, a stout seaman covered in sunspots, said, \u201cI don\u2019t know what they base that on. I think we could be strongly affected here 4 or 5 miles away.\u201d<\/p>\n<p>From the docks at Port Lavaca, he pointed across the water at the Seahawk Terminal, the tallest feature on the horizon, looming large to the northeast.<\/p>\n<p>\u201cDoes that look far away to you?\u201d he said.<\/p>\n<p>Then he pointed at a U.S. flag that was flapping to the southwest, directly from the plant to where he stood.<\/p>\n<p>\u201cLook which way the wind is blowing,\u201d he said. \u201cThat\u2019s our prevailing summer wind.\u201d<\/p>\n<p>In April 2022, the TCEQ commissioners agreed with the executive director and denied all hearing requests.<\/p>\n<p>It issued Max Midstream a permit authorizing 61 different emissions points to release up to eight different air contaminants at a collective rate of hundreds of pounds per hour.<\/p>\n<p>\u201cEmissions from this facility must not cause or contribute to \u2018air pollution\u2019 as defined in Texas Health and Safety Code,\u201d the permit said.<\/p>\n<p>In June 2022, Wilson sued the TCEQ in federal court, alleging that it \u201cacted arbitrarily and unreasonably in determining that Plaintiffs did not qualify as affected persons\u201d based solely on distance.<\/p>\n<p>\u201cThere are no distance restrictions imposed by law for this type of permit,\u201d reads a legal brief Wilson filed for the case in July 2023.<\/p>\n<p>She claimed TCEQ issued a pollution permit that was not compliant with state and federal law and asked the court to overturn it. A first hearing in the case is set for November.<\/p>\n<p>Disclosure: Texas A&amp;M University has been a financial supporter of The Texas Tribune, a nonprofit, nonpartisan news organization that is funded in part by donations from members, foundations and corporate sponsors. Financial supporters play no role in the Tribune\u2019s journalism. Find a complete list of them here.<\/p>\n<p>The Texas Tribune is a member-supported, nonpartisan newsroom informing and engaging Texans on state politics and policy. Learn more at texastribune.org.<\/p>\n<p class=\"tagtag\"> <span class=\"tagtag\">Topics<\/span> <a href=\"https:\/\/www.insurancejournal.com\/location\/texas\/\" class=\"btn btn-sm btn-primary tagtag\">Texas<\/a> <\/p>\n<\/p><\/div>\n<div class=\"article-poll\" data-post=\"733714\">\n<div class=\"article-poll-vote\">\n<p>Was this article valuable?<\/p>\n<\/p><\/div>\n<div class=\"article-poll-feedback voted-no\">\n<form class=\"feedback-form\">\n<p>Thank you! 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