Review of Documents for LPDES Permit Application

Industry: Environmental

Formosa Plastics - Planned Petrochemical Complex -Welcome, St. James Parish, Louisiana

Sunset over lake

CHANGE Environmental, LLC prepared an expert summary report for Environmental Integrity Project (EIP) regarding project and document review conducted associated with the planned Louisiana Pollution discharge Elimination System, (LPDES) individual discharge permit (per Louisiana Dept. Of Environmental Quality {LDEQ} requirements for the proposed Formosa Plastics {FG LA LLC} petrochemical industrial facility complex in Welcome, St James Parish, Louisiana. The proposed site is to be located along the St. James Canal and Mississippi River. The proposed site for the petrochemical complex would be beyond current naturally occurring conditions at the undeveloped site. LPDES permitting includes regulatory requirements under 40 CFR 122 and Chapter IX of Section 33 of Louisiana Administrative Code, intending to protect surface water quality for pollutant discharges.

It is CHANGEs’ expert conclusion at current time that St. Parish is a heavy Industrial area that already has elevated risks to human health and environment from existing industrial operations, without the addition of FG LA LLC’s proposed- 2,400-acre petrochemical facility complex. CHANGEs’ general expert opinion is that ongoing compliance/implementation with future LPDES permit conditions will be greater risk for adverse environmental impacts, as opposed to LDEQ issuing a LPDES permit failing to meet minimum state and federal regulatory requirements.