Revision/Renewal of the Air Curtain Incinerator (ACI) General Operating Permit (GOP No. 518) - RPN 2024-044-OTH-NR

Re: non-rule project number 2024-044-OTH-NR_General Operating Permit for Incinerators (Permit Number 518)

Dear Ms. Ricco, and air quality division staff,

This is the second part of the submission on behalf of Air Alliance Houston and the Coalition...↓ for Environment Equity and Resilience. I look forward to your response to comments. Best wishes, Jen Powis↓

Re: Non-Rule Project Number 2024-044-OTH-NR—General Operating Permit for Incinerators (Permit Number 518)

Dear Ms. Ricco, and air quality division staff:

On behalf of Air Alliance Houston and the Coalition for Environment, Equity and Resilience, al...↓ong with the Texas Appleseed and the Citizens Environmental Coalition in Houston as signatories in support, I submit these comments on the Texas Commission on Environmental Quality's (TCEQ) proposed renewal and amendment for the General Operating Permit (GOP) 518 for Air Curtain Incinerators (Incinerators). This amendment to the GOP comes as the federal Environmental Protection Agency has sought to erode public health protections for communities after disasters by authorizing greater use of Incinerators as a way to deal with mixed disaster waste. We urge TCEQ not to make that same mistake, and instead focus greater attention on disaster recovery that works to aid communities after the storm, as opposed to deepening the environmental harms after natural disasters. Please see the attached documents in full that support our requests to amend this GOP to eliminate its use for disaster recovery activities, or in the alternative, to put special conditions on any use of Incinerators after a disaster. Our comments are submitted in two parts due to the file restriction for submission. Thank you, Jen Powis, Earthjustice, Attorney on behalf of AAH and CEER.
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