Public Citizen Comment on Draft Renewal Title V Permit No. O74 for W.A. Parish Plant
Public Citizen Comment on Draft Renewal Title V Permit No. O74 for W.A. Parish Plant
Laurie Gharis
Office of the Chief Clerk
Texas Commission on Environmental Quality
P.O. Box 13087, MC 105
Austin, Texas 78711-3087S
Re: Comments on Public Hearing Regarding Draft Renewal Title V Permit No. O74, Authorizing Operating of NRG Texas Power LLC’s W.A. Parish Electric Generating Station in Fort Bend County, Texas
Good evening and thank you for being here tonight. My name is Haley Schulz and I oppose the renewal of FOP O74 and request the permit is denied and redrafted to better protect community members like myself.
I have always lived in Fort Bend, I grew up in Sugar Land and my husband and I started our family when we moved to Richmond, where I live today. My house is 15 miles from W.A. Parish, which may sound far away, but I see it every day when I drive south on Hwy 99, when my family visits the Sugar Land Memorial Park on University Boulevard, or when we go to the Fort Bend County Fair off of US-59. W.A. Parish has the most populated 12mi radius of any coal plant in Texas1, even being located in Thompsons, which can seem fairly remote. That radius is about to get more populated when Austin Point (Fort Bend County’s new master-planned community of 14,000 houses) starts moving in this summer.
I only found out about Parish a couple years ago, but I think my body has always known W.A. Parish was here. Growing up, I thought everyone had an inhaler, or that it was normal to live with a thick coating in your throat, or to have a coughing spell at the slightest irritation. A few years back I got costochondritis, which is the inflammation of the tissue connecting your ribs and sternum. I thought I was having a heart attack every time I had to cough. To this day, I must pay attention to air quality or what I breathe because if I have another coughing spell, my body goes back to the excruciating pain the costochondritis left with my body. Our family used to go to Brazos Bend State Park all the time. We’d go there every month to get fresh air, see the hatching alligators, and enjoy nature. But after I realized that beautiful park was mere miles away from a coal plant and my son came home with trouble breathing after a day at Brazos Bend, we stopped going. My memories of visiting George Ranch for field trips or Brazos Bend for girl scout camping and family outings are all smeared by W.A. Parish’s very existence.
Everyone has heard of NRG, but nobody knows about W.A. Parish. In my work as a community organizer, we canvassed an 8mi radius around W.A. Parish to bring people to this public hearing, just for the sake of people being informed and having the opportunity to listen, ask questions, or hear from all sides at this hearing. In that 8mi radius around Parish, do you know how many people out of the 400+ doors we knocked on has heard of W.A. Parish? Eighteen. Does that sound like a company that works in the community? I say this because NRG has previously said they are active in the community, their PR team handed out pamphlets and snacks at the back of the public meeting. We know who NRG and Reliant are: the host to our Houston Rodeo, the official energy provider of the Houston Texans, Rockets, and Astros. But nobody knows who W.A. Parish is or what you are doing TO the community.
Let me provide some insight. The EPA Toxics Release Inventory (TRI) Toxics Tracker shows W.A. Parish represents 66% of TRI releases in Fort Bend County.2 For context there are 33 TRI facilities in the county, but Parish represents about two-thirds of releases. Between 2021 and 2023, W.A. Parish’s releases into the air alone included over 2M pounds of hydrogen fluoride, ammonia, hydrochloric acid, n-hexane, and other harmful chemicals, which increased overall in 2023.2 Looking at the potential health effects of ANY of those chemicals include: cancer, cardiovascular, reproductive, respiratory, neurological impacts. I will also note that cancer (specifically lung cancer) and heart disease are the top two leading causes of death here in Fort Bend County.3 And with W.A. Parish contributing to 66% of the TRI releases in the county, we don’t have to question or wonder who is making us sick. We only need to learn the name.
Part of the Federal Operating Permit is to hold the facility accountable and “improve compliance with the rules governing air pollution control”.4 Looking at W.A. Parish’s track record, I am formally requesting the TCEQ shorten W.A. Parish’s FOP period from five years to three years to re-engage with the public on a more frequent basis, have the TCEQ review and inspect the facility on a more frequent basis, and hold Parish accountable for violations. In the three years, W.A. Parish had five violations to this very Air Operating Permit 74, including failures to maintain opacity within permitted limits (2022 and 2023), failure to comply with carbon monoxide concentration limit (2024), and failure to comply with the permitted ammonia concentration and maximum allowable emission rate (2024).5 Those two recent violations happened just over one month ago, or at least the Notice of Violation was made on December 11.
This leads me to another concern: the lack of regulated air monitoring in Fort Bend County. The TCEQ has ruled Fort Bend County as “unclassified” for PM2.5 attainment because of the lack of regulatory air monitors. How does our county not qualify for air monitoring for particulate matter, sulfur dioxide, or nitrogen when we have a top emitter of that very pollution? The data that the TCEQ and EPA rely on for compliance of permits is NRG self-report stack emission data. The TCEQ needs unbiased, regulatory air monitoring for particulate matter, sulfur dioxide, and nitrogen in order to properly monitor and hold W.A. Parish accountable for their pollution and impacts to our environment and health.
The W.A. Parish’s own plant manager, Daryl Miller, told local news KHOU 11 that keeping the facility running is like “keeping a 60-year-old Chevy roadworthy—it takes a lot of time, maintenance, and effort to keep it running.”6 The plant manager claims how much effort and resources it takes to keep W.A. Parish running – why isn’t NRG investing in a clean energy transition that will require lighter maintenance and be cost effective in the long run? It would also help better keep NRG in compliance of permits like this federal operating permit.
More and more concerned citizens are coming forward demanding clean energy from NRG and from W.A. Parish. The evidence the community and industry has given shows clear correlation between W.A. Parish and the immediate impacts to the health, environment, and lives of the community. As a community member, I want NRG to be an energy leader in Fort Bend. But to do that, they need to close down the coal (like they originally planned and reported to the EIA7), they should apply for state funding for solar and battery storage, and become a cleaner, more reliable, more profitable facility. We want NRG in the community, but not if they have coal.
Regards,
Haley Schulz
1 “Toll from Coal.” Tollfromcoal.org, 2025, www.tollfromcoal.org/#/map/(title:3470//detail:3470//map:3470/TX).
2 “TRI Toxics Tracker.” Edap.epa.gov, 2022, edap.epa.gov/public/extensions/TRIToxicsTracker/TRIToxicsTracker.html#continue.
3 2022 Community Health Assessment. 19 Apr. 2023. https://www.fortbendcountytx.gov/sites/default/files/document-central/documentcentral/health-human-services-documents/FBCHHS-2022-Annual-Report_Final.pdf.
4 “Overview of Federal Operating Permits.” Texas Commission on Environmental Quality, 2025, www.tceq.texas.gov/permitting/air/titlev/overview.html.
5 “TCEQ CR Query.” Texas.gov, Texas Commission on Environmental Quality, 2024, www15.tceq.texas.gov/crpub/index.cfm?fuseaction=iwr.novdetail&addn_id=420524552001296&r e_id=452478102001341.
6 Rogalski, Jeremy. “NRG: Texas’ Largest Power Plant Ready for Arctic Blast.” Khou.com, 22 Dec. 2022, www.khou.com/article/weather/texas-power-grid-winter-freeze-preparations/285-1f96fb0a0a94-4bf0-9dc0-7a2f3d2c62dd.
7 “Preliminary Monthly Electric Generator Inventory (Based on Form EIA-860M as a Supplement to Form EIA-860).” Eia.gov, 24 Jan. 2025, www.eia.gov/electricity/data/eia860m/.