To: Jack Broadbent, Executive Pollution Control Officer, Mary D. Nichols, California Air Resources Board - Board Chair, Richard Corey, California Air Resources Board, Executive Officer, and John Gioia, BAAQMD Stationary Source Committee, Chair

Stop "The Other" Keystone XL Pipeline !

Bay Area oil refineries, already the areas largest industrial emitters of climate-changing greenhouse gases (GHGs) and deadly particulate matter (PM), are getting ready for a deluge of tar sands and other heavy and dirty crudes.

Tell the local Bay Area Air Quality Management District (BAAQMD), the regulatory agency whose job it is to protect our public health, air quality and the global climate, that Bay Area refineries need immediate enforceable numeric caps or limits on refinery greenhouse gases. These caps will not only protect the climate, but prevent further increases in deadly particulate matter in surrounding communities.

Why is this important?

The Keystone XL Pipeline struggle has not ended! Unknown to most environmentalists, the San Francisco Bay Area, once a major World War II industrial hub, is soon to be on the receiving end of "the other" Keystone XL pipeline, by rail or by ship, if several of the five area refineries get their way.

We petition BAAQMD (the "Air District"): Suspend refinery permits until greenhouse gas emission cap regulations are in place!

Air pollution kills hundreds, if not thousands of people in the Bay Area each year and threatens to destroy our global climate and way of life. Refining the worlds dirtiest crude oils, such as tar sands, is a very carbon-intensive industrial process, producing vast amounts of climate-changing greenhouse gasses. Refining the dirtiest crudes also creates more deadly particulate matter, while emitting toxic heavy metals and cancer-causing airborne benzene.

Stronger refinery emissions rules from the Air District are our best chance for controlling refinery pollution, which is set to increase if recently permitted dirty oil refinery infrastructure is built.

The recently released, but grossly incomplete, refinery emissions rules (“Rules 12-15 and 12-16”) are too-little-too-late. These rules would fail to create a healthy breathing environment and would perpetuate the environmental injustice of exposing frontline communities to yet more refinery pollution.

The draft rules raise many questions: Why were greenhouse gases exempted from regulation? Why is there no proposal for enforceable, facility-wide numeric emissions caps or limits? How can you promise our air is not going to get worse without numeric caps, should these already approved dirty oil projects proceed? Why is the Air District ignoring Ultramar v. South Coast AQMD, which says an air district has the authority to require preemptive action on pollution:

• even if it requires phasing out the use of a chemical entirely
• even if it is done to prevent future episodes of air pollution
• even if emissions are not one of the EPA’s six 'criteria' pollutants, like greenhouse gases (See historic greenhouse gas petition on Wikipedia page: Criteria_air_contaminants).

I am writing to ask that you prevent refinery-emission increases by suspending all permitting for refinery projects and establishing a numeric cap on refinery pollution—including for greenhouse gases—at today's levels.