ORCAA/SIMPSON HEARING STATEMENT

Katherine Price speaking at 9/27/11 ORCAA Hearing:

"Where are we to turn for protection when the agencies
which we believe exist to protect the health of the citizens
really exist to help protect the profits of industry?"

"SEPARATE SOURCE" DETERMINATION SHELL GAME

Submitted to Shelton Blog by Katherine Price Mason County Progressive

Thank you for providing us this opportunity comment on the five year renewal of the Simpson Timber Company Air Operating Permit.

To begin, I would like to read ORCAA’s Mission Statement and their Vision Statement:

ORCAA’S Mission

We promote air quality and take actions that protect the health and welfare of people and the natural environment in ORCAA’s jurisdiction (Clallam, Grays Harbor, Jefferson, Mason, Pacific, and Thurston Counties).

ORCAA’S Vision

All Individuals in ORCAA’s jurisdiction-especially children and the elderly-can live, work, and play in a healthful and clean environment, free from the harmful and destructive effects of air pollution.

On January 31, 2011, ORCAA held a public hearing in connection with the ADAGE permit application. During that hearing, six hours of testimony was submitted to ORCAA by scientists, doctors, and concerned citizens who had familiarized themselves with the dangers presented by an ADAGE facility.

I respectfully request that the contents of that hearing, and the comments and questions presented to ORCAA at that hearing, be incorporated into this hearing by reference, and that especially the scientific and medical testimony be included in the record of this hearing. The science does not change from Johns Prairie to the Shelton Harbor, and ORCAA was given a pass on having to respond to our questions and comments when ADAGE withdrew their application.

ORCAA should not be allowed to ignore those questions, or the six hours of citizen testimony, and I hope that you will include it in your record of this hearing and respond at this time to the citizens concerns presented to you on January 31, 2011. The concerns expressed about the ADAGE facility apply equally to the Simpson facility.

In my review of the Technical Support Document associated with the Simpson Air Operating Permit, I learned that Olympic Panel Products bought the plywood mill in 2003; thereby making Simpson Timber Company and Olympic Panel Products “separate source” polluters for purposes of the pollution generated in the harbor from these two entities.

Because of this, the total amount of pollution which is generated in this one industrial site is considered to be from two sources: Simpson Timber Company and Olympic Panel Products.

Because Simpson Timber Co. and Olympic Panel exist in a symbiotic relationship, with each providing product and services to the other, and also because of their close physical proximity, this “separate source” determination is really just a shell game.

This shell game allows two businesses who are dependent on each other, and who operate in a single location, to pollute our community simultaneously while the effects of their pollution are calculated separately.

The result is that the total sum of their pollution is not added together to arrive at the actual tons per year of pollution the public is being subjected to by these combined operations in the harbor.

This shell game is condoned by ORCAA and sustained by legislation written for industry.

This shell game is extended even further when we look at the planned Solomon Renewable Energy Company, and the determination by the Department of Ecology that Simpson Timber Co. and Solomon Renewal Energy Company are separate sources for pollution.

As if to prove the nature of the shell game, in its four page reply to my inquiry in connection with their separate source determination for Simpson and Solomon, the Department of Ecology writes:

“The apparent family ownership of SREC by Reed family members, who individually are also part owners of Simpson Investment or one of the other Simpson companies, is another aspect that gives an appearance of common control and ownership.

"In further investigating common employment or other common control by Mr. Douglas Reed over Solomon and Simpson, Mr. Dave McIntee of Simpson contacted me and stated that at no time was Mr. Reed an employee of both Simpson and Solomon. Mr. Reed resigned his position with Simpson to work exclusively for Solomon…”

This is the sort of gaming of the rules that the citizens find disturbing.

This is the sort of gaming of the rules that ORCAA condones when it allows these industries to operate within a stones throw of one another while not considering their pollution as a single source.

If Solomon Renewable Energy Company decides to get back into the game, ORCAA and Ecology will accept that there will be three distinct “separate source” polluters in the harbor.

The total volume of the tons of pollutants will not be added together for purposes of future permitting, but will be separated, allowing the various entities in the harbor to come in under the wire for some pollutants which will allow them to continue to pollute over the City of Shelton and it’s neighborhoods.

By the rules conveniently established through years of legislation favoring industry’s profits over the citizens’ health, the game is stacked in favor of the polluting industries.

When ORCAA, whose Vision Statement says: "All individuals in ORCAA’s jurisdiction – especially children and the elderly – can live, work, and play in a healthful and clean environment, free from the harmful and destructive effects of air pollution,” when ORCAA looks upon the industries in the harbor as separate sources, and all but denies the “harmful and destructive effects of air pollution,” what are the citizens to think?

Where are we to turn for protection when the agencies which we believe exist to protect the health of the citizens really exist to help protect the profits of industry?

Simpson is requesting that it’s air operating permit be renewed for another five years.

It is the expectation of the citizens that in the next year or two the Environmental Protection Agency will increase standards for air pollution, making the issuance of a five year air operating permit to Simpson at this time inappropriate as it would allow Simpson Timber Company to continue to pollute at the present standards until its permit expires.

I respectfully request that ORCAA issue the permit for a time period less than five years in order to allow agencies to revisit the Simpson AOP when the pollution limits are revised by the EPA.

Katherine A. Price
Shelton, WA

Photo by Christine