A Georgia State Agency’s Recent Decision To Deny Public Comment On A New Industrial-Scale Wood Pellet Manufacturing Plant Violates The State’s Commitment To Implementing The Clean Air Act
Adel, GA — Today, the Environmental Integrity Project and eight other organizations and concerned citizens petitioned the U.S. EPA to revoke an air pollution permit for a proposed wood pellet manufacturing plant in Adel, Georgia, and to order the state to correct its practice of issuing certain air pollution permits without the opportunity for public review. Under Georgia’s Clean Air Act program, the public has the right to comment on draft air permits for proposed new and modified air pollution sources in their communities, even if such sources are classified as “minor,” as is the case with Renewable Biomass Group’s Adel wood pellet plant.
On January 28, 2021, the Environmental Protection Division (EPD) of the Georgia Department of Natural Resources denied a request by the Environmental Integrity Project, Dogwood Alliance, and a coalition of Adel residents to allow comment on a draft “minor” permit authorizing Renewable Biomass Group (RBG) to construct and operate a new wood pellet plant on the grounds that comment is only available for “major” source permits. While the Adel facility will be major for purposes of the Clean Air Act’s Title V operating permit program—emitting nearly 800 tons of regulated air pollutants each year, including nearly 100 tons of fine particulate matter, 250 tons of nitrogen oxides, and 216 tons of volatile organic compounds—the opportunity for public comment on the facility’s Title V operating permit will not arise until long after the facility is constructed and operating.
The Georgia EPD’s refusal to allow public comment on the draft RBG permit is not unique. Rather, Georgia EPD systematically issues all permits of this type without allowing for public comment on draft permits, even under circumstances where members of the public request that a draft permit be released for public comment. The petitioners include Concerned Citizens of Cook County, Dr. Treva Gear, Dr. Victoria Meredith, the Environmental Integrity Project, Dogwood Alliance, Georgia Interfaith Power and Light, Forest Keeper, Mothers & Others for Clean Air, and Sierra Club Georgia Chapter.
“Allowing this wood pellet company in to pollute our air and make our community sicker is an environmental injustice,” said Dr. Treva Gear, native of Adel, GA, and co-founder of Concerned Citizens of Cook County. “We need jobs, but not at the expense of the environment and public health. Our community has been heavily impacted by COVID-19 and the long-term effects are yet to be known. However, we do know that the pollutants caused by these pellet plants will worsen the health of our people.”
The Adel community downwind from the RBG plant is a particularly vulnerable environmental justice community. The census block within Adel, the county seat of Cook County in South-Central Georgia, closest to the facility is 94% minority and 86% low income; Adel as a whole is 51% minority population and 55% low income according to EPA’s environmental justice screening tool, EJ Screen.
“The public should have the opportunity to review draft air pollution permits—especially for permits like the one for the Adel plant, which allow the facility to avoid stringent air pollution control requirements,” said Keri Powell, an attorney with the Environmental Integrity Project. “These so-called ‘minor’ sources can still have a big impact on air quality, especially when clustered together in already overburdened communities.”
“This petition calls out Georgia’s Environmental Protection Division for their failure to abide by their own Clean Air Act State Implementation Plan, which requires that concerned citizens of Adel and Cook County have an opportunity for public comment on these types of permits,” said Vicki Weeks, Georgia State Coordinator for Dogwood Alliance. “To deny these citizens the right to speak out before issuing a permit for the RBG pellet plant, which has the potential for substantial pollution, is a disservice to the people of Adel and our great state.”
As EIP documented in a 2018 report, many industrial-scale wood pellet manufacturing facilities like the proposed RBG plant have been constructed as “minor” sources based on their agreement to comply with minor emission limits, but subsequently were found to be emitting nearly four times the agreed-upon amount. In most cases, these violations were revealed only after persistent advocacy efforts by EIP and its partners.
For example, EIP and others informed the State of Mississippi in 2017 that the Drax Amite BioEnergy Plant was emitting air pollutants at a rate that far exceeded its permit limits. EIP subsequently filed two additional sets of comments explaining why Drax’s emission calculations were flawed. Finally, in November 2020, Mississippi issued a final order requiring Drax Amite to install a new regenerative catalytic oxidizer to reduce its emissions and fining Drax $2.5 million for its Clean Air Act violations. Similar minor permit violations have been discovered and addressed at wood pellet facilities across the U.S. South.
The Environmental Integrity Project is a 19-year-old nonprofit organization, based in Washington D.C., dedicated to enforcing environmental laws and strengthening policies to protect public health and the environment.
Concerned Citizens of Cook County is a community organization that acts as a positive force for change, promoting equity and advocating for social and environmental justice. In fulfilling this purpose we provide support and information designed to lift people up and give access to people who feel excluded within our communities. Most importantly, we are advocates for the good of the Cook County community.
Dogwood Alliance is a nonprofit environmental organization based in the Southern U.S. For more than 20 years, Dogwood Alliance has worked with diverse communities, partner organizations and decision-makers to protect Southern forests across 14 states.
Forest Keeper is the only major conservation organization focused on protecting national forests. We are national forest watchdogs who protect over 20 million acres of national forests in the United States. We work in the field, in the courtroom, and in Congress to secure strong, permanent protections for forests.
Georgia Interfaith Power & Light engages communities of faith in stewardship of Creation as a direct expression of our faithfulness and as a religious response to global climate change, resource depletion, environmental injustice, pollution, and other disruptions in Creation.
Mothers & Others For Clean Air’s mission is to protect children’s health by reducing the impacts of air pollution and climate change throughout the Southeast. We create partnerships between scientists, healthcare providers, parents, teachers, youth, and organizations to facilitate collective learning and action in the southeast.
The Sierra Club is America’s largest and most influential grassroots environmental organization, with more than 3.5 million members and supporters. In addition to protecting every person’s right to get outdoors and access the healing power of nature, the Sierra Club works to promote clean energy, safeguard the health of our communities, protect wildlife, and preserve our remaining wild places through grassroots activism, public education, lobbying, and legal action. For more information, visit sierraclub.org.
Ari Phillips, Environmental Integrity Project, firstname.lastname@example.org
Scot Quaranda, Dogwood Alliance, email@example.com
Dr. Treva Gear, Concerned Citizens of Cook County, (229) 630-7752, firstname.lastname@example.org