Today, Earthjustice and Sierra Club submitted comments regarding the Michigan Department of Environmental Quality’s (MDEQ’s) Sulfur Dioxide (SO2) One-Hour National Ambient Air Quality Standard State Implementation Plan. The groups argue that the plan fails to bring parts of Wayne County into attainment with basic clean air protection standards, and does not require enforceable or sufficient reductions in actual sulfur dioxide emissions from major sources of pollution. As a result, the groups are asking the U.S. Environmental Protection Agency to deny approval of the plan, and move quickly to create and adopt a federal plan that would actually bring the areas into attainment as required by the Clean Air Act.

The River Rouge and Trenton Channel coal-fired power plants are located in eastern Michigan.

SO2 pollution poses a serious public health threat in Detroit and Downriver communities. Even short term exposure to elevated levels of SO2 pollution can cause respiratory problems, reduced lung function, and asthma attacks. The areas of Wayne County that fail to satisfy the SO2 standard include Michigan’s most polluted zip code—48217 — with levels of asthma and asthma attacks that are far higher than the state average.

After the EPA designated portions of Wayne County as out of attainment with the SO2 standard in 2013, the state of Michigan was required to develop a plan to bring the area into attainment.  Unfortunately, the plan proposed by MDEQ falls far short of addressing the pollution problem. Rather than requiring significant reductions in SO2 emissions from major polluters such as the remaining units at the River Rouge and Trenton Channel coal plants, MDEQ’s proposal largely relies on the inadequate steps that polluters in the area were already planning to take.

In addition, MDEQ failed to ensure that the pollution limits included in the plan are permanent and enforceable.  As a result, SO2 levels in Wayne County would continue to violate public health standards.

“MDEQ has missed a great opportunity to clear the air and protect public health in Detroit and Downriver communities,” said Shannon Fisk, Managing Attorney with the non-profit environmental law firm Earthjustice. “We need real reductions in pollution from River Rouge Unit 3, Trenton Channel Unit 9, and other pollution sources, rather than simply accepting what the polluters were already planning to do.”

When a state fails to submit a plan that would bring the area into attainment with federal standards, the U.S. EPA has the authority to issue its own plan. Here, MDEQ’s plan is not only inadequate, but it was also submitted more than 13 months after the deadline the Clean Air Act sets for such plan. As such, the groups argue that it is incumbent on EPA to create its own plan to protect the health of families and communities in Wayne County.

“EPA must not only reject MDEQ’s submitted plan as legally inadequate, but also quickly issue a federal plan that will address the pressing health problems posed by excessive SO2 pollution in Detroit and Downriver communities,” said Rhonda Anderson, Organizer for the Sierra Club’s Beyond Coal Campaign in Michigan. “Every week of delay means more hospitalizations and missed school and work for Wayne County residents.”

Earthjustice and Sierra Club intend to continue to push EPA and MDEQ to develop and implement a plan that will bring Wayne County into attainment with the SO2 standards as expeditiously as possible. 

Read the comments.