Pulse Point Newsletter for February 29, 2000
Published by Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
By Enrique Medina, MS, CIH

The US-Mexico border maquiladora industry is targeted for reductions of 85% from current emissions levels of volatile organic compounds (VOC) in order to meet air quality goals issued by Mexico’s Secretariat of Environment, Natural Resources and Fisheries (SEMARNAP).

SEMARNAP head Julia Carabias unveiled a $376 million "Air Quality Improvement Program for Mexicali 2000 – 2005” before Mexican President Ernesto Zedillo, at a presentation last week in the Baja California capital. High-level EPA officials were also in attendance. This program and two other plans for El Paso-Ciudad Juarez 1998-2002 (Paso del Norte) and San Diego-Tijuana, have been developed as part of the Border XXI Program jointly coordinated by US EPA and SEMARNAP.

The plans encompass a wide array of initiatives to improve air quality and reduce pollution from mobile, stationary and area sources. Of note are a number of cooperative actions between Mexican federal, state and local regulatory agencies in coordination with their US counterparts. Less clear is where the money will come from to pay for these measures.

The plans call for specific reduction goals in a number of emission categories, including those with non-attainment status in the US and Mexico, such as particulates (PM-10) in Mexicali-Imperial Valley, and carbon monoxide (CO), ozone and PM-10 in the Paso del Norte Region. Other numerical targets address sulfur dioxide (SO2), nitrogen oxides (NOx) and hydrocarbons (HC), which include Volatile Organic Compounds (VOCs).

Action items in both plans rely on promoting voluntary measures in the maquiladoras (foreign-owned plants that manufacture products for export under special tariffs) to cut emissions of VOCs by 85% to approximately 1,500 tons per year in Juarez, and 1,200 tons/yr. in Mexicali through a combination of existing and proposed programs.

One of these measures, the Voluntary Audit Program started in 1992 by the Attorney General for Environmental Protection (PROFEPA- the enforcement arm of SEMARNAP), is well known to the regulated community. Although nationwide most major industries have been audited, the border maquiladora sector has not been well represented in the program.

In a new development, the Paso del Norte Plan states that as part of SEMARNAP’s commitment to make information available to the public, the agency will release the previously undisclosed summary findings and action plans of PROFEPA facility audits.

The budget for this ambitious program, amounting to almost $90 million in Juarez and $376 million in Mexicali is divided between public and private funding sources. In Juarez, of the $41 million to be provided by the private sector, 59% is apportioned to mobile sources, and nearly $12 million to be invested by industrial sources to meet the plan’s goals. Almost all of the $47 million in public funds are earmarked for street paving to cut down on dust.

In Mexicali, an estimated $84 million investment is split among similar lines, including $4.7 million by the maquiladora sector to lower VOC emissions. However, proposed upgrading of the cargo and public transportation rolling stock adds another $292 million to the total, representing the bulk of total public investment (86%). It is unclear why this item is shown as public expenditures, since the trucking and urban bus fleets are in the private sector.

It is also not clear what are the sources of funds for the plans. Other than proposed tax credits for installing pollution control technologies (estimated at $4,000 per ton of VOC reductions), there is no mention of where any of the money will come from.

The plan’s implementation measures are equally as vague. Although the VOC reduction goals are considered voluntary- since Mexico has not issued rules on VOC emission limits other than for new vehicle coatings- the plan does not address specific questions such as:

The border air quality plans are the most comprehensive attempts to date addressing the growing air pollution problems faced by US and Mexican border cities. However, the quality of the emissions inventory data is doubtful, as it stems mainly from limited, industry-supplied data and generic emission factors. Also, the financial projections are incomplete, which can significantly underestimate the required investment.

Nonetheless, these reports are recommended reading for those responsible for strategic and operational decisions at existing or planned facilities along the border region. As of this date, only the Paso del Norte Plan is available on INE’s web page at www.ine.gob/plan.

In our next issue we will take a closer look at the emissions inventory data used to estimate source contributions from the industrial and energy sectors, and discuss the programs that will be implemented to encourage industry’s participation in the plans.

If you have questions about how specific elements of the air quality plans may impact your current or future operations, please contact us at (619) 297-1469 or send us an email at emedina@pulse-point.com.

Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
3361 28th St.
San Diego, California 92104
(fax (619)297-1023

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