NEXT Renewables' diesel facility

Submit feedback to DEQ on the Renewable Diesel facility!

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I SUPPORT Approving the NEXT Renewable Fuels Standard Air Containment Discharge Permit – Application No: 32808

I am writing to express my strong support for NEXT Renewable Fuels and urge the Oregon Department of Environmental Quality to approve their Standard Air Containment Discharge permit (Application No. 32808). NEXT meets the stringent regulations for an air permit and in its public notice, the Department of Environmental Quality states that “NEXT Renewable Fuels Oregon, LLC is not a major source of EPA-listed hazardous air pollutants” and “DEQ has concluded the potential emissions meet health risk standards for the community and do not require additional controls to be protective of public health.”

The DEQ has proposed measures in the draft permit that ensure NEXT adheres to some of the highest air quality standards in the nation. In particular, I am supportive of the following DEQ measures:

I appreciate the proposed resolution procedures listed under condition 3.7.d.iii. By requiring NEXT to collect multiple representative waste samples, the community can be certain the wastestreams from NEXT will not contain elevated benzene levels.   The DEQ requirement for NEXT to install non-resettable hour meters on stationary RICE protects the community and environment under condition 4.2.f.   DEQ is doing the right thing by requiring NEXT to install many SCR and oxidation catalyst control devices, and the level of monitoring required, under condition 4.3.a and 4.3.b. That will be sufficient to reduce NOx emissions and confirm that the control devices are always operating as required under the permit.

I am impressed with the environmental benefits beyond the facility itself. Studies and a lifecycle analysis show that the NEXT facility will be responsible for a net elimination of roughly 7 million tons of greenhouse gases annually. Displacing petroleum diesel with NEXT renewable diesel slashes particular matter and black carbon emissions from long-haulers, farm equipment and other large vehicles, which will in turn protect vital snow pack in Oregon, clean our rivers, lakes and streams, and decrease respiratory illnesses for those living and working around diesel equipment. Further, NEXT is proposing a nearly 500-acre wetland restoration program that will function as a carbon sink in Columbia County (in addition to providing critical habitat to local flora, fauna and pollinators).As I read through the DEQ draft permit, I have the following questions for the agency:

Oregon has the strictest air toxics program in the country, particularly for new sources like NEXT. While I understand that NEXT’s facility will manufacture a liquid fuel with very low Carbon Intensity, why does it not need a Cleaner Air Oregon permit?  Did DEQ review the toxic air emissions from NEXT’s proposed facility? If so, why does it not have a Cleaner Air Oregon permit?  I understand toxic emissions from the NEXT facility will be so low that they don’t need a Cleaner Air Oregon permit. If that’s the case what right does DEQ have to include terms in the permit related to Cleaner Air Oregon? It seems DEQ is acting beyond its authority.

In DEQ’s own words, “if a facility meets all legal requirements, DEQ will issue the facility’s air quality permit.” I firmly believe the NEXT Renewable Fuels clean fuels proposal meets all legal requirements – and goes above and beyond in design to protect air, water and health – and should be granted approval without delay.

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