Public Comments

Joint Technical Comments – Concrete Batch Plant Standard Permit Amendment

The TCEQ initiated an amendment process for the Concrete Batch Plant (CBP) Air Quality Standard Permit in November 2022, held public meetings in May 2023, and accepted public comments until June 14, 2023.

TRAM partnered with Air Alliance Houston, Public Citizen, Environmental Defense Fund, Lone Star Chapter Sierra Club, and Environment Texas to submit joint technical comments to the TCEQ. Below is an excerpt and summary of our comments.

TRAM also submitted separate comments expanding on the BMPs we feel should be included in the TCEQ permitting process. View those comments at the link below.

We recognize the importance of CBPs in supporting economic growth and infrastructure development but firmly believe that their operation must not compromise the health and well-being of Texas residents. It is in this spirit of collaboration and shared commitment to the well-being of our communities that we offer our technical comments, providing evidence-based analysis, recommendations, and solutions to address the potential environmental impacts of the proposed amendment.

We believe that the proposed amendments to the CBP Standard Permit process are timely and needed. However, the amendments do not go far enough to protect the public given the massive growth in many areas of Texas and the concentration of Aggregate Production Operations (APOs), including CBPs next to many of these high population growth areas.

Here is a summary of the significant and essential changes we recommended:

  • The TCEQ should immediately use AERMOD for dispersion modeling instead of the older ISCST3 (Version 02035) model that was used for the Protectiveness Review.
  • The addition of best management practices (BMPs) is good, but again the proposed BMPs do not go far enough. We offer a listing of additional BMPS related to air management in a section below.
  • Fenceline monitoring devices should be installed to confirm that model results align with actual air quality once the CBP is operational. The Protectiveness Reviews should also include up-to-date data on PM10 and PM2.5 background levels including new levels proposed in the updates National Ambient Air Quality Standards (NAAQS) for PM expected later this year.
  • It is crucial to resolve the confusion surrounding the standard permit application process for “regular” CBPs…and the application for standard permits for “certain concrete plants” under Texas Clean Air Act ยง382.05198.
  • The inclusion of cumulative impacts from PM emissions should be an integral part of Protectiveness Reviews.