Title V Speech Writing Tools

● Require continuous monitoring of all critical emissions

● Remove the 4-hour loophole and require daily visible emissions observations

● Require daily compliance checks instead of monthly (ref. Section II, Condition 2.1)

● Direct monitoring of PM and PM10 emissions; do not rely on emission factors (ref. Section II, Condition 2.2)

● Revise language to specify monitoring of all activities that may result in emissions, not just processing and manufacturing

● Reduce the emissions limits; current allowable emissions are double historical use

● Establish RACT-based VOC emissions limits

● Improve opacity limit enforcement with clear definitions of activities and sources, and require immediate Method 9 testing when emissions are observed (ref. Section II, Condition 2.4)

● Require more stringent limits based on model control technologies

● Require EPA recommendations for CKD emissions (ref. Condition 10.6.2.1) - specifically, on-site handling of CKD in closed, covered vehicles and conveyance devices, and keeping cement kiln dust in enclosed tanks, containers, and buildings when temporarily stored for disposal or sale

● Require real-time and transparent data reporting

● Require third party verification of compliance of required conditions to establish community trust

● Mandate the use of BACT for all emission sources

● Require regular environmental audits and mandate regular updates to emission control technologies to stay current

● Require explicit penalties, fines, and corrective actions for every violation; review of the control plan, the current ‘penalty’, has been proven ineffective for 30+ years

● Require 24/7 monitoring for fugitive dust events, as well as the control measures in place that are intended to prevent them

● Require specific protocols like recording and responding to incidents such as spills, high speeds, insufficient moisture, and malfunctioning sprinklers; these steps should be aimed at preventing CKD dust from escaping and complement existing obligations to monitor and address dust emissions post-occurrence (Ref. Condition 12.7.1)

● Require the paving of frequently used haul roads to control and reduce fugitive dust emissions and the ongoing issue of material spillage onto Highway 66; CEMEX increased its truck traffic by more than 100% (230 new trips per day) in October 2022 (Ref. Condition 13.4 and Subsections)

● Require installation of cameras across active plant areas for continuous monitoring, and immediate identification of dust emission origins; video footage shall be retained for verification purposes to identify the root cause of the regular discrepancies between plant records and community-reported fugitive dust events (ref. Condition 15.1)

● Require a comprehensive Air Quality Impact Assessment that evaluates the cumulative impact of all emission sources at the facility.

● Include additional emission factors related to the Dowe Flats mine and a detailed accounting of "process fugitives"

● Deny CEMEX's request to remove the Dowe Flats crusher and conveyor from their emissions limits until such equipment is fully deconstructed and verified as non-operational

● Require a third party assessment of the full environmental impact of CEMEX’s requested modification to remove the limestone throughput limits

● Include emissions from mobile sources directly related to CEMEX's business activities, including, but not limited to, trucking and other transportation means, in the facility's total emissions counts with appropriate monitoring, limits, and consequences for violations in place

● Require additional monitoring/reporting to determine raw material inventory and throughputs

● Require that any violation of the control plan must result in immediate corrective

measures, specifically capital improvements, not just fines

● Require and define clear, substantial penalties and fines for every violation; the penalties

must be severe enough to deter non-compliance as the status quo does not

● Require immediate penalty imposition; violations detected should result in immediate, proactive, and publicly transparent action, without waiting for annual inspection reports that are typically issued 12-18 months after inspection

● Specify explicit and timely penalties, fines, and corrective actions for every violation of the control plan

● Implement a "three-strikes" policy, where after three violations, the facility must cease operations until it can demonstrate compliance