TCEQ Sunset Public Comments: Tips

Our experience is that it is important to get a variety of individuals and groups to submit different comments that tell local stories but reflect common positions. To read ACT’s comments, click here. Your comments can be e-mailed to pen_rule@tceq.texas.gov, and are due by August 30, 2011.

Here are the big points to make:

1.     Every violation and every day of violation matters and should be counted separately.

2.     Each pollutant emitted is a separate violation.

3.     Economic Benefit:

a.     The economic benefit of having excessive emissions should be considered when assessing penalties, as should the avoided and deferred costs of not having installed proper equipment to minimize pollution.

b.     The cost to polluters of complying should not be considered.

4.     Penalty policy should be included in the rules so they are less easily manipulated by staff or commissioners.

If you can think of ways these improvements in enforcement policy would have made a difference in your community, please tell that story in your comments. E-mail comments to pen_rule@tceq.texas.gov.