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RE: let's get real


Glenn Landers wrote about the complexities of commenting on a New Source permit, and said that if the process were made more understandable to ordinary people, it would be useful in the kind of case that Deborah Glover was writing about.

If the process is ever made that understandable, we'll see. Meanwhile this kind of thing does no good for the kind of people that Deborah was writing about in her example. Would the parents in her example really have been satisfied with the system if the librarian had helpfully gotten them the facility's Title V permit?

Parenthetically, the case Glenn wrote about is interesting, because it's the first time I've heard of anything coming out of a permit commenting process. However, I think it's likely that the facility is still releasing the same amount of pollution, no matter what their new permit says. Perhaps they are in the third year of ignoring their permit, are negotiating to pay a $5000 fine, and after that will have a new compliance plan that they can start to not follow. I did a study of water pollution permits and found that many major facilities have been in significant noncompliance with their permits every quarter since 1992. (To be fair to industry, many were municipal facilities.) Without continuing political pressure, a permit is just a piece of paper.

Librarians can help the process by archiving records. You'd never know from the EPA's database that facilities were in noncompliance for that long, because they carefully throw out those embarassing data. EPA's PCS water permit database only holds the last two years of quarterly noncompliance codes -- to go back further than that, I had to keep copying and archiving the data over the last decade before EPA deleted it.


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