Another Public Comment, Stellantis Pollution Increase Request, Fall 2024

Here we go again. I believe I’ve attended every public meeting on the Detroit Assembly Complex. Due to COVID EGLE moved to online hearings. This is the first in-person meeting in some time. The meeting was well attended with about 30 residents. The EGLE recording of the meeting can be found here.

Robert Shobe of Justice for Beniteau lives ajacent to the plant and has attended every public meeting. He has been vocal about doing things RIGHT, NOT BETTER for the residents whose health and quality of life have been impacted by this project that is funded with our tax dollars.

Note: The public comment period for this permit is now closed.

September 9, 2024

Department of Environment, Great Lakes and Energy
Air Quality Division, Permit Section
P.O. Box 30260
Lansing, MI 48909–7760

Sent by email to EGLE-AQD-PTIpubliccomments@Michigan.gov

Re: Proposed Air Permit for FCA Mack Assembly

Please find this letter an addition to and clarification of my September 5th, 2024, in-person public comment regarding the Stellantis permit to install. I work with Detroit People’s Platform who have signed on the ECAC letter in support of the Justice for Beniteau group. My family and I also live in Stellantis’ Detroit Assembly Complex “impact area.”

It is important to begin by stating clearly that the rules of engagement for this permit and the decision-making process are unjust. This project does not exist in a vacuum and for environmental and public health issues to be disregarded in in this process perpetuates historical injustice. It is also vital to note that this permit to install is an extension of a process rooted in environmental racism documented in the related Title VI Civil Rights complaint. Based on this injustice, please consider these four requests/demands.

1. Approve the RTO, deny the increase in emissions. If it is possible to parse the Permit to Install, it would be a movement in the right direction to approve all aspects of the permit that related to pollution control, the second Regenerative Thermal Oxidizer (RTO), but DO NOT increase the limits for PM2.5 or any other emissions.
2. Approve the RTO, but delay the emissions increase for a year. If the approval of the permit to install must include the increase, add a period of at least one year before the increase is activated. This time frame will allow for verification of compliance. Due to Stellantis’ history of failure to properly install and run their pollution control equipment it would be right to verify the equipment is properly running first. While models may suggest positive outcomes, residents have experienced increased emissions when the models have failed.
3. Rather than increase emissions limits, pursue claw backs of public funding. Based upon serial air quality violations and the failure of Stellantis to provide promised employment opportunities to Detroiters it would be right for the state of Michigan and the city of Detroit to consider clawing back a portion of tax abatements, incentives, captures and other financial assistance requested by Stellantis for the Detroit Assembly Complex. We believe EGLE have a role in determining access to brownfield funds and based on violations by Stellantis, this funding opportunity should be renegotiated. Our tax dollars should not be used on projects that negatively impact our health.
4. Revoke Stellantis’ Pollution Control Exemption Certificate*. In addition to the consideration of claw backs, EGLE is encouraged to further research and revoke the certificates of exemption for air pollution control. These certificates can provide a 100% property and sales tax exemption based upon the installation of pollution control equipment. The grounds for revocation are substantial non-compliance and serial air quality violations by Stellantis should be considered.

Stellantis have been bad neighbors to East Side Detroiters by negatively impacting our health and quality of life. I encourage EGLE to pursue corrective action through active reduction in emissions, not increase. Thank you for providing an opportunity to weigh in on the decision-making process. (END)

The public comment period for this permit is now closed.

*A note on Pollution Control Exemptions from Good Jobs First: “In the last 50 years, companies have used this program to shield over $17 billion in taxable property from state and local taxes, most of which is owned by just six of the state’s largest and most powerful corporations: DTE Energy ($5.3 billion), Consumers Energy ($2.9 billion), General Motors ($1.1 billion), Ford Motor ($783 million), Marathon Petroleum ($696 million), and Stellantis ($685 million).

Media

WXYZ: https://www.wxyz.com/news/egle-holds-air-quality-meeting-with-residents-over-stellantis-permit-request-at-mack-plant

Bridge Detroit: https://www.bridgedetroit.com/community-speaks-against-stellantis-permit-request-to-increase-emissions/

Senator Chang’s letter to EGLE: https://senatedems.com/chang/2024/09/10/stellantis-air-quality-permit/

View the Recording: The recording of the September 9, 2024, informational session and hearing is now available to view. The slides used during the presentation are also attached to this e-mail for viewing. You may also view the slides presented at the session.

Additional Information: Additional information on the proposed air permit can be found at Michigan.gov/EGLEStellantis and Michigan.gov/EGLEAirPublicNotice. Scroll down to the section on the FCA USA LLC — Detroit Assembly Complex — Mack.

Questions:

• On the proposed permit may be directed to Dave Thompson (ThompsonD22@Michigan.gov or 517–582–5095).
• On compliance at the facility or complaints may be directed to Jonathan Lamb(LambJ1@Michigan.gov or 313–348–2527).
• Complaints may also be submitted using the online complaint form or by calling 1–800–292–4706.

Next Steps: After the comment period closes, the decision maker will review all comments received to make a decision on all three permits included in the project. The response to comments document and the final decision will be shared on EGLE’s Final Decision Page.