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  • RE: Federal Operating Permit Title V Draft Permit #02771 Building Materials Investment Corporation/GAF 2600 Singleton Blvd. Dallas Tx 75212 RN100788959

    Dear Chief Clerk, TCEQ Commissioners, EPA, City of Dallas, and Dallas County,

    I object to the issuance of a new federal operating permit for the GAF asphalt shingle factory located in West Dallas. This facility is too old, too polluting, and too much of a public health menace to remain operating in its current location.

    GAF is the largest industrial Sulfur Dioxide polluter in Dallas County, comparable to the emissions of a giant cement plant or utility power station. It is the 4th largest source of industrial Particulate Matter pollution.

    Over the past year independent air monitoring has shown levels of Particulate Matter pollution in violation of the Clean Air Act, and far above the World Health Organization recommended level of concern, making its operation an on-going threat to public health. EPA should place its own Particulate Matter monitors around GAF to capture these violations and force GAF to reduce its pollution.

    Much of GAF's air pollution is "grandfathered," or exempt from modern controls, including scrubbers that could eliminate most of its Sulfur Dioxide pollution. This is unacceptable in the middle of urban residential neighborhoods. EPA must require GAF to install the best, most protective pollution control technologies or shut it down.

    It was recently learned that GAF doesn't have a Certificate of Occupancy or the correct zoning status to be operating in the City of Dallas, and yet it continues to do so. A federal operating permit should consider whether a polluting factory is complying with all applicable state and local laws before granting its own permit. If GAF doesn’t have the necessary permits, it shouldn’t be operating.

    GAF operates in a central Dallas census tract with over 5000 people. An overwhelming majority are People of Color with a median income approximately one third of the Dallas average. 20% of the population is nine year of age or younger, 45% is 19 or younger - among the most vulnerable to the impacts of GAF’s air pollution. At least three early childhood program or day care centers and six school campuses are near this factory. GAF’s continued operation represents a major environmental health and justice insult to West Dallas residents.

    GAF’s factory was originally located in West Dallas as part of an industrial corridor meant to steer undesirable industries to Black and Brown neighborhoods. It’s now a dangerous and obsolete leftover from that racist past. It should not be allowed to obtain a new federal operating permit.