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Merck & Co., Inc.
Statement of Malcolm Cameron, Jr. on Merck Project XL Air Permit Agreement
The Merck Project XL Agreement is a definite step in the right direction for improving air quality in the Central Shenandoah Valley and for Shenandoah National Park. There are, however, some serious shortcomings.
I'd like to commend Merck and the various signatories to the agreement for a number of positive elements in the Project XL framework. These include:
- Conversion to natural gas fired boilers form the present coal-fired units
- A 20% reduction in overall emissions from recent levels including a 900 tons/year reduction in SO2 and NOx emissions
- Does not allow the sale or acquisition of emissions credits
- Annual or semi-annual reports must be submitted to agreement signatory agencies and Rockingham Co.
The agreement also has significant provisions which reduce the ability to protect the health of both area residents and the environment.
- Project XL is open-ended with no expiration date. This will make it more difficult to negotiate a new permit when regulations and other contributing factors change.
- There is no set cap on VOC emissions. (Volatile Organic Compounds) Merck would be able to increase the release of VOC's by up to 2 or 3 times recent emission levels. Since VOC's are a major source of ozone, this would have a detrimental effect on both respiratory health in the area and the health of forests in Shenandoah National Park and elsewhere. This could also effect area tourism adversely, as well as crop yields.
- The Community Representatives selected by the Rockingham County Board of Supervisors will not really have an effective voice in reviews and other decisions because their concerns can be vetoed by Merck or other signatories.