This is the full text of Governor Douglas' letter to Senator Clinton
on October 25, 2005. Please see the links in the left column by both
Governor Douglas and Senator Jeffords to Governor Pataki of New York opposing IP's unsafe test burn of tires without and ESP.

The Honorable Hillary Rodham Clinton
United States Senate
476 Russell Senate Office Building
Washington, DC 20510

Dear Senator Clinton:

I am writing to follow up on my letter to you dated April 27, 2005, regarding the proposal by International Paper (IP) to burn processed waste tires at their facility in Ticonderoga, New York.

As you know, the New York Department of Environmental Conservation has issued a draft Title V Air Quality Permit amendment which would allow IP to conduct a test burn using tire derived fuel (TDF). While I recognize the economic importance of IP to our states – Vermonters are employed there as well as New Yorkers – I join with thousands of other Vermonters in opposing this plan, especially in light of IP's persistent refusal to upgrade the pollution controls at the Ticonderoga facility by installing an Electrostatic Precipitator (ESP) on the power boiler before proceeding with any plan to burn TDF. Notably, IP has ESPs installed on every boiler that regularly burns TDF across the nation and on another smaller boiler at the Ticonderoga facility. That is the right thing to do: ESP control devices are considered the industry standard pollution control device when using TDF.

EPA is just now phasing in new standards for fine particulate matter (PM2.5), based on a better scientific understanding of how these tiny particles affect human health. Particularly at-risk are young children who breathe much more rapidly than adults, tend to be more active and risk much longer exposure to contaminants due to their longer expected lifetimes. The underlying permit for IP was written before these new requirements went into effect and is wholly inadequate in its requirements relative to PM2.5. Indeed, even the draft permit issued by NY DEC fails to require the stack testing necessary to document these emissions during the proposed test.

IP maintains that burning processed waste tires is critical to their future viability, as it will provide a significant source of low-cost energy for the plant. However, IP also maintains that the cost of an ESP is prohibitively expensive for the Ticonderoga facility. Those are not strong enough reasons for us to ignore the impacts that burning TDF will have on air quality in Vermont, especially the impact it will have on the communities in Addison County, Vermont, directly across Lake Champlain from Ticonderoga. If IP continues to refuse to install an ESP, and if the New York Department of Environmental Conservation refuses to require them to do so, I will stand with my fellow Vermonters and explore all available options, including legal challenges to IP's underlying air quality permit.

Senator, leadership is needed here. From my perspective, if the use of TDF is so

important to the future success of IP's Ticonderoga plant, New York officials – state and federal should encourage IP to install an ESP pollution control device, and perhaps tax credits or similar financial incentives can be devised that will help IP acquire that necessary technology.

I can assure you that this is a very serious issue for those of us who live downwind of the IP facility. The winds blowing east will carry the emissions from the IP plant across beautiful Lake Champlain, over the fertile fields of Addison County, the Green Mountain National Forest, and ultimately the Connecticut River and into New Hampshire. Over the years, New England and New York have vigorously fought pollution traveling into our region from midwestem smoke stacks; to think that a new source of pollution might arise just a few miles from the Vermont/New York border is unthinkable to the citizens of my state, and unacceptable to me.

If you would like to discuss this matter, either in person or over the phone, please feel free to contact my office. I do hope you will see fit to intervene in this manner.

James Douglas

More about the permit application and tire burn (follow the link for more information)

Why burning tires for fuel is unsafe (follow the link for more information)

International Paper Company of Ticonderoga, NY has a long history (click here to see IP's environmental track record) of being the largest polluter of Lake Champlain, the Champlain Valley and Vermont.

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