President’s Message: Texas Chemical Industry Urges Support for Proposition 2

TCC President & CEO Hector L. Rivero

An adequate supply of clean, affordable water is absolutely essential to the success of the state’s chemical industry, manufacturing, oil and gas, and other major economic sectors, making water a crucial component of job creation and economic development. Texas has suffered through several severe droughts recently, which heightened awareness among state legislative leaders that something must be done to ensure an adequate water supply for future generations.

On November 8th, Texas voters will have the opportunity to vote FOR Proposition 2 – a constitutional amendment to help local communities grow and maintain their essential water supplies. The Texas Chemical Council (TCC) and Association of Chemical Industry of Texas (ACIT) strongly support this constitutional amendment, and I urge you to vote for Proposition 2.

Proposition 2 resulted from the near unanimous passage of Senate Joint Resolution 4 by the 82nd Texas Legislature.

The most important thing for voters to understand is that Prop. 2 will not cost state taxpayers any money, and the bonds used through this measure will save local taxpayers millions when building and financing water projects.

The bonding authority granted by Proposition 2 is designed to be self-supporting: the bonds issued are repaid by the debt service of the borrowers and don’t count against the state’s constitutional debt limit. The Texas Water Development Board’s (TWDB) current bonding authority will be exhausted in 2013, and without this reauthorization, water programs administered by the TWDB would be crippled.

The chemical industry and other industries use large volumes of water in their operations, although most chemical plants return well over 95% of the water they use to downstream sources (and that water is returned cleaner than when it was captured). Because many of these facilities are located along the Texas coast, they are often at the end of rivers and tributaries that provide them with water for their operations. As droughts dry up our state’s rivers, lakes, and reservoirs, this impacts the supply of water for cities, agriculture, and manufacturers all along a river basin and can often create dire shortages for industrial facilities located down river near the coast. Without adequate supplies of water, manufacturers would be unable to operate and this would result in significant loss of jobs and investments in many communities across the state.  

Our state’s population is growing faster than our ability to provide adequate supplies of water, causing increasing strain on our existing water supplies, and causing water bills to increase. Proposition 2 is needed to provide local communities the tools they need to plan for, and meet their future water needs at reasonable rates.

Proposition 2 would ensure that the TWDB could continue to administer their assistance programs, provide cost-effective financing for the Texas State Water Plan (SWP), and continue to help with local and regional efforts to address the state’s water and wastewater needs.

If Texas’ State Water Plan were not fully implemented, 83% of Texans would not have an adequate supply of water during times of drought.  Failure to meet the state’s water needs in drought conditions could cost Texas businesses and workers approximately $11.9 billion in lost income today, and up to $115.7 billion in 2060.

The use of bond money authorized by the passage of Proposition 2 is limited to financial assistance to political subdivisions for water, wastewater and flood control projects.  The additional bond authority cannot be used for TWDB administrative expenses or grants.

The Bond Review Board would continue to review any proposed bond debt issuance under the constitutional authority granted by passage of Proposition 2.  The TWDB has an excellent financial history, with zero defaults resulting from loans issued by the agency.

For most Texas businesses, even temporary interruptions of our state’s water supply could be devastating.

Remember, Proposition 2 will not cost state taxpayers any money, and the bonds used through this measure will save local taxpayers money when building and financing water projects. Failure to implement the state water plan by passing Proposition 2 could impact the bottom line of every business, and sooner than your think. Can any of our businesses afford that kind of trouble?

I urge you to SUPPORT Proposition 2 on Election Day: November 8th, 2011.

TCEQ considers Enforcement Policy Changes

Implementation of the New Statutory Penalty Cap
On August 25, the TCEQ Commissioners held another Work Session to discuss changes to the agency’s enforcement policy in response to the passage of the TCEQ Sunset Bill, HB 2694.  At issue was implementation of the new statutory cap of $25,000/day for most environmental violations.

Over the past several weeks, TCC has been working closely with the TCEQ to ensure that the sunset bill is implemented in a manner consistent with the legislative intent behind the bill.  Prior to the Work Session, TCC had received indications from TCEQ staff that they intended to implement the new statutory cap in a manner that would have doubled (at a minimum) TCC members’ penalties.  On the days leading up to the Work Session, TCC worked with the Executive Director and the Commissioners to come up with alternatives to implementing the new cap in a manner that is not overly punitive to industry.

At the Work Session, Commissioner Rubinstein began the discussions of this item with the recognition that the Legislature raised the statutory cap from $10,000/day to $25,000/day (which is effective Sept. 1, 2011) so that TCEQ would have the discretion to adequately punish those companies that egregiously violate the law.  His observation was that raising penalties across the board for the entire regulated community, simply because the agency has the ability to do so because of the new cap, did not appear to be the intent of the Legislature.  In the alternative, he proposed revisions to the Penalty Policy that will revise the percentages upon which major and minor source violations are assessed.  In most cases, this will result in a small increase in penalties, but nothing compared to what was originally proposed by TCEQ staff.

Both Chairman Shaw and Commissioner Garcia agreed that Commissioner Rubinstein’s proposal was the more sound approach.  All three Commissioners agreed that the public should have an opportunity to comment on the revised percentages.

Subsequently, on August 29, TCEQ issued notice that another revision of the Penalty Policy was available and the agency is accepting comment on the latest revision until September 9, 2011.  The changes to the Penalty Policy will be finalized at the September 28 Work Session. In the revised document, TCEQ is proposing to amend the base penalties (i.e., the percentage of the statutory max) in all categories except in those cases where a major facility caused major harm by an actual release.  To view a copy of the proposal, please click on the following link:
http://www.tceq.texas.gov/about/comments.html. 

TCC is working with the Air Conservation Committee, the Water & Waste Management Committee and the Legal Advisory Group to develop comments to the latest Penalty Policy revisions proposed by TCEQ.

Adoption of the Agency’s General Enforcement Policy Into Rule
On August 30, TCC submitted comments to TCEQ on the sunset bill directive to the agency to adopt its general enforcement policy into rule.

The comments addressed 10 questions presented to the TCEQ Commissioners at the July 5 Work Session.  To view a copy of TCC’s comments, please click here.

Austin City Council Takes First Step Toward Plastic Bag Ban

The Austin City Council took the first step on August 4th toward banning plastic bags at retail and grocery store checkouts.

The council voted unanimously to direct city staffers to begin writing a ban with the help of retailers, environmental groups and others. The ban and a plan to gradually phase it in will be presented to the council by November.

Council members also asked staffers to gather information about a possible ban on paper bags, as well as plastic ones, and about possibly charging fees for so-called single-use bags instead of banning them outright.

Details such as whether small stores should be exempt and the penalties for not complying with a ban will be worked out during the four-month process. If enacted, Austin would be the first large city in Texas to enact such a ban; Brownsville already has an ordinance in place.

Austinites use about 263 million plastic bags a year, and according to a city report, cost the city and taxpayers about $850,000 a year to clean up as litter and put in landfills.

A successful voluntary effort by large Austin retailers, including Wal-Mart, HEB, Randalls and Target, to cut plastic bag usage and encourage recycling was not “effective enough”, some city officials have said.

On the day of the vote, nonprofit Texas Campaign for the Environment called on the city to ban both plastic and paper bags, saying that would achieve the larger goal of helping consumers get in the habit of using reusable bags instead of single-use bags.

Mark Daniels, vice president of sustainability at Hilex, a large manufacturer and recycler of plastic bags with locations in the Dallas area and across the country, said that the bags pose no environmental threat because they are fully reusable and recyclable.

Daniels said a ban would put at risk the nearly 9,000 jobs in Texas that are involved in producing, recycling and transporting the bags. “There is also no evidence that plastic bags kill wildlife or are an exceptionally large source of litter,” he said.

A plastic bag ban would compel consumers to begin using more paper bags, which require more energy and fuel to produce and transport than plastic bags, Daniels said. The ban, he said, “would just not be good public policy.”

Daniels pointed to the recycling program, which is voluntary, funded by retailers, and offers a searchable database on the “A Bag’s Life” website (www.abagslife.com/) so consumers can find the nearest retail location for dropping off bags for recycling.

He said the infrastructure is already in place for recycling programs, the adoption of the previous ordinance was beneficial to everyone, and has kept jobs in this tough economy.

Jenn Studebaker, an Austin single mother with four children spoke against the proposed ordinance. She said the Council’s proposal criminalizes trash, and “we should have incentives instead of punishments, and Austin should not criminalize consumer choice.”

Studebaker recommended that the proposal be put to a public vote, to let the people decide.

Texas AG Abbott to Oppose EPA’s Cross-State Air Pollution Rule

Greg Abbott

A spokeswoman for Texas Attorney General Greg Abbott says the office pledges to oppose a new air rule by the federal Environmental Protection Agency (EPA).

Spokeswoman Lauren Bean said Abbott’s office “will pursue every available legal remedy” to prevent the EPA from implementing its recently adopted Cross-State Air Pollution Rule, or CSAPR, in the state.

The attorney general’s response comes just days after the Texas Railroad Commission wrote Abbott, asking him to challenge the new rule. The TCEQ Commissioners also had a thorough discussion at their work session last week and are weighing their legal options as well.

The EPA adopted the CSAPR on July 6th. The rule, effective Oct. 7th, requires 27 states, including Texas, to significantly reduce power plant emissions that cross state lines and contribute to ozone and fine particulate pollution in other states, beginning in January 2012.

“The Commission firmly believes that the rulemaking process employed by the EPA was legally flawed, and that the rule, particularly as it focuses on Texas, is unsupported by credible and accurate technical data and analysis and will have serious adverse economic consequences for Texas without demonstrable environmental and health benefits,” chairwoman Elizabeth Ames Jones and commissioners David Porter and Barry T. Smitherman wrote in their letter.

The commission questions the legal validity of the notice of proposed rulemaking issued by the EPA because the adopted version, it says, is much broader in scope than the rule as initially proposed.

In its letter to Abbott and Jon Niermann, assistant attorney general for the state’s Environmental Protection and Administrative Law Division, the commission says the EPA also did not properly analyze the cost of compliance nor adequately assess the impacts of the rule on the state.

“Texas relies on electricity generated by lignite coal… [which is mined in the state], the regulation of which resides at the [Texas Railroad] Commission,” it wrote.

Under the CSAPR, Texas is expected to reduce sulfur dioxide, or SO2, emissions in the state by 47 percent from last year’s levels – second only to Ohio. In addition, of the states included in the CSAPR SO2 reduction requirements, about 25 percent of all reductions are expected to come from Texas.

Texas’ total lignite power generation capacity is about 9,500 MW, according to the commission.

“If CSAPR requires any of those units to shut down or run half time, Texas will not have enough power to keep the lights on,” it wrote.

The commission says it is concerned about the timing and the expected emission reductions themselves.

“The timing of the new requirements – Jan. 1, 2012 – is unreasonable because it does not allow enough time to implement operational responses to ensure reliability,” it wrote. “Many coal-fired power plants may be forced to limit or shut down operations, possibly resulting in reductions in the safety margins of power operation of this state.

“The CSAPR will put at risk the economic future of power generation and those dependent on affordable electricity in Texas.”

The commission asked Abbott’s office to bring legal action and seek a stay of CSAPR’s effectiveness.

EPA: Arlington (TX) Public Hearing on Oil & Gas Well Emissions

The EPA has scheduled public hearings for late September in Texas, Colorado and Pennsylvania on its proposed regulations for air pollution at oil and gas wells.

The agency said that the daylong hearings would be Sept. 27 in Pittsburgh, Sept. 28 in Denver and Sept. 29 in Arlington, Texas. The public will be able to comment on the EPA’s proposals aimed at reducing emissions.

The proposal includes the first federal air standards for wells that are hydraulically fractured and also seeks to have operators capture and sell natural gas that currently escapes into the air.

Texas, Colorado and Pennsylvania all have seen a significant increase in gas drilling since the discovery of major natural gas shales in those states that are accessible using hydraulic fracturing technology.

Environmental Regulations, EPA Become GOP Candidates’ Target

The environment is looming large in the Republican presidential race, with candidates criticizing green regulations and most questioning man-made “global warming”.

The debate became more interesting recently, when former Utah Gov. John Huntsman criticized Texas Gov. Rick Perry for calling global warming an unproven scientific theory Perry cited the potential for “billions, if not trillions of dollars” to be spent trying to reduce greenhouse gases.

Huntsman’s response on ABC’s “This Week”: “When we take a position that basically runs counter to what 98 of 100 climate scientists have said, what the National Academy of Science has said about what is causing climate change and man’s contribution to it, I think we find ourselves on the wrong side of science, and, therefore, in a losing position.”

Governor Rick Perry

Gov. Perry said: “I think we’re seeing almost weekly or even daily scientists who are coming forward and questioning, the original idea that man-made global warming is what is causing the climate to change.” The climate is changing, he said, but has been doing so “ever since the Earth was formed.”

Minnesota U.S. Rep. Michele Bachmann said that if she’s elected president: “I guarantee you the Environmental Protection Agency will have doors locked and lights turned off and they will only be about conservation. It will be a new day and a new sheriff in Washington, D.C."

Former Massachusetts Gov. Mitt Romney said: “I don't speak for the scientific community, of course, but I believe the world’s getting warmer. I can’t prove that, but I believe based on what I read that the world is getting warmer. And number two, I believe that humans contribute to that.”

The Washington Post notes that the discussion has changed substantially since the last presidential campaign. In 2008, Republican nominee John McCain chose Portland to announce he favored aggressive cuts to greenhouse gases.

“Climate change has become a wedge issue,” according to Roger Pielke Jr., a University of Colorado professor. “It’s today’s flag-burning or today’s partial-birth-abortion issue.”

The EPA has come in for more across-the-board criticism among candidates. Bachmann and former Speaker Newt Gingrich want to shutter the agency. Perry of Texas wants to impose an immediate moratorium on environmental regulation, and Huntsman thinks most new environmental regulations should be shelved until the economy improves.

U.S. Rep. Ron Paul of Texas wants environmental disputes settled by the states or the courts. And Herman Cain, a businessman, wants to put many environmental regulations in the hands of an independent commission that includes oil and gas executives. Romney is less critical, but opposes regulation of greenhouse gases.

According to the New York Times, the “extraordinary intensity” of this year’s skepticism is driven by the “faltering economy, high fuel prices, the Tea Party passion for smaller government and an activist Republican base that insists on strict adherence to the party’s central agenda.”

Former Vice President Al Gore said he hoped that one day, climate change skeptics would be seen in the same negative light as racists.

In a recent interview, Gore explained that in order for climate change alarmists to succeed, they must “win the conversation” against those who deny there is a crisis:

Gore also took shots at Gov. Perry, who has lambasted climate change alarmists on the presidential campaign trail, and at other politicians who dare to question the veracity of global warming science.

“This is an organized effort to attack the reputation of the scientific community as a whole, to attack their integrity, and to slander them with the lie that they are making up the science in order to make money,” Gore said.

EPA’s Proposed Ozone Regulation Could Cost $1 Trillion

Thomas Pyle

By Thomas Pyle, president of the Institute for Energy Research, a not-for-profit organization that conducts intensive research and analysis on the functions, operations, and government regulation of global energy markets.

The EPA has proposed to tighten the screws on American businesses and households by reducing acceptable ozone levels. The proposal could render up to 96 percent of U.S. counties noncompliant, and by some estimates would impose economic damages exceeding $1 trillion.

There is no compelling health reason to foist such draconian regulatory changes on the fragile U.S. economy. The proposed regulations amount to serious costs with negligible benefits.

EPA regulates ground-level ozone levels under the Clean Air Act. The current primary regulatory standard for ozone is 0.075 parts per million (ppm), established in 2008. (Implementation of the 0.075 ppm standard was suspended in 2009 pending further study.)  EPA reviews its air quality regulations every five years, so normally EPA would review the ozone standards in 2013. Yet for some reason, the Obama administration has decided that it needs to raise energy and regulatory costs on U.S. businesses right now, two years ahead of schedule.

The official decision has not yet been made, but the EPA’s new ozone regulations will likely fall in the range of 0.060 to 0.070 ppm. That works out to a range of 60-70 parts per billion. To give an idea of just how miniscule these concentrations are, consider that this range is the equivalent of less than one cup of water poured into an Olympic-sized swimming pool.

To grasp the significance of the proposed change in the regulatory threshold, we can compare the compliance rates of U.S. counties under the current and proposed levels. According to an analysis conducted by the Business Round Table, 66 out of 736 counties nationwide do not meet the EPA’s current ozone standard of 0.075 ppm. However, if the EPA lowers the acceptable concentration down to 0.060 ppm, then the estimated number of non-attainment counties would skyrocket to 628 (out of 736) according to the Business Roundtable. That means fully 85 percent of the nation would be in non-attainment. The EPA’s own analysis is even more pessimistic, predicting that up to 96 percent of monitored counties would be non-attainment with the stringent 0.060 ppm threshold.

Regions in non-attainment would be subject to greater EPA regulation and would need to alter their activities in an attempt to reduce emissions. Businesses might have to install new technologies to reduce emissions, cars might undergo more frequent inspections, and electricity prices could be significantly higher as utilities switched to different fuels. Naturally, taxpayers from all over the country would foot the bill for the actual enforcement costs of the stringent regulation.

The estimated economic damages from such compliance vary, but they may be quite severe. For example, the Manufacturers Alliance/MAPI released a 2010 study by economist Donald Norman on the effects of the 0.060 ppm standard. Norman projected that during the years 2020 to 2030, the annual compliance costs would exceed $1 trillion (in 2010 dollars). That cost works out to 5.4 percent of GDP in 2020. Total job losses by 2020 could reach 7.3 million by 2020, which represents an estimated 4.3 percent of the total labor force that year.

Such are the possible downsides of the proposal, but what are the benefits? Many scientists and organizations, including the American Heart and Lung Association, have expressed support for the stricter standard. They claim that lower concentrations of ozone would benefit people suffering from conditions such as bronchitis and asthma.

Yet there are always tradeoffs. Policymakers need to decide if the benefits of the new rule outweigh the costs. Even the EPA’s own statements on the issue should give Americans pause: It has claimed the new regulations could save up to $100 billion per year on healthcare expenditures by 2020, yet the EPA also acknowledges that the compliance costs to business could be as high as $90 billion by 2020. This is a small margin for error, especially in light of the far more severe costs estimated in other studies.

It is difficult to have a rational discussion on this issue because proponents of the stricter standard are imagining kids with asthma choking in a smog-filled LA highway. This is very misleading. In reality, the proposed 60 parts per billion standard is so strict, that even areas of Yellowstone National Park may not be in compliance. To the extent that some areas will be affected by ozone emitted elsewhere (even outside the United States), it may prove literally impossible to comply with the draconian new regulations.

With unemployment hovering above 9 percent—and the actual figure remaining much higher—and regular households already struggling to keep up with energy bills and prices at the pump, now is hardly the time for the EPA to tighten the screws on the economy. The proposed standards for ozone would impose real economic hardship for dubious medical benefits.

EPA to Review Regulations to Eliminate ‘Unjustified Burdens’

The EPA finalized a plan recently to review dozens of regulations to ensure they are not overly burdensome, part of an administration-wide “lookback” mandated by President Barack Obama.

President Obama

The plan offers the Obama administration an opportunity to counter Republican claims that EPA is imposing new regulations without thinking about their effect on the ailing economy. But industry and business groups quickly dismissed the plan Tuesday, arguing it does not go far enough.

EPA will review 35 regulations under the final plan. Sixteen of those rules will be reviewed quickly, a process that could lead to “modifying, streamlining, expanding or repealing a regulation or related program during the 2011 calendar year,” EPA says. EPA will review the other 19 regulations over a longer time period.

Many of the regulations were identified in EPA’s proposed plan, which was released in May.

The agency says it will reduce reporting and recordkeeping for its gasoline and diesel rules, work with the Agriculture Department to establish “regulatory certainty for farmers” and better coordinate air pollution rules, among other things.

EPA says a “central goal” of its review is “reducing unjustified burdens and costs.”

In its final plan, EPA outlines four actions the agency has taken in recent months to streamline its regulations, including exempting industrial milk containers from oil-spill prevention rules and redesigning fuel economy labels. The four actions will save EPA as much as $360 million per year, the plan says.

In total, EPA’s regulatory reforms will save more than $1 billion in the coming years, EPA says.

“Taken as a whole, recent reforms, already finalized or formally proposed, are anticipated to save up to $1.5 billion over the next five years,” the plan says, noting that additional efforts outlined in the plan will save more money.

More broadly, EPA plans to use new technologies to make its regulations more efficient.

“High-speed information technologies allow real-time reporting of emissions and provide unprecedented opportunities for transparency and public involvement in matters affecting local environmental conditions,” the plan says. “These technological advances allow us to better track environmental progress, apply innovative approaches to compliance and reduce regulatory costs.”

EPA says it will continue to review its regulations every five years.

“On a predictable, transparent, five-year cycle, EPA intends to ask the public to nominate additional regulations for review and intends to commit to new reviews to supplement those described in this plan,” EPA says.

The final plan is in response to a January executive order by President Obama that instructed all federal agencies to review their regulations to determine whether they “should be modified, streamlined, expanded or repealed so as to make the agency’s regulatory program more effective or less burdensome in achieving the regulatory objectives.”

The administration is already getting pushback on its regulatory review plans. The U.S. Chamber of Commerce said Tuesday the plans do not go far enough.

“The administration’s findings and determinations, on their own, are a worthy effort at making technical changes to the regulatory process, but the results of this lookback will not have a material impact on the real regulatory burdens facing businesses today,” said Bill Kovacs, a senior vice president at the Chamber.

The American Petroleum Institute similarly gave the EPA effort a lukewarm review.

API’s Howard Feldman, on a call with reporters Tuesday, praised the agency’s decision to end requirements for certain vapor recovery systems at gasoline pumps due to onboard recovery systems in modern vehicles.

But like other business groups, API wants EPA to scuttle major planned ozone standards.

Feldman, API’s director of regulatory and scientific policy, reiterated allegations that the ozone standards will impose onerous emissions requirements on scores of businesses in areas that are out of attainment, leading to businesses contracting or moving overseas in some cases.

“With 25 million Americans unemployed or underemployed today, it is hard to understand why the administration is considering a standard so potentially harmful to the nation’s future prospects — and a standard that makes a mockery of the administration’s program to eliminate or modify rules that are unnecessarily costly or burdensome,” he said.

Dow’s Gary Hockstra Named Vice President of Manufacturing, Engineering and EH&S for Dow Advanced Materials Division

Gary Hockstra

Gary Hockstra, Vice President and Site Director of Dow Texas Operations in Freeport and TCC Board Member, has been named Vice President of Manufacturing, Engineering and EH&S for the Dow Advanced Materials Division.

“Gary’s extensive knowledge in leading large organizations focused on operational excellence and driving a culture based on EH&S will be a great value to our business portfolio,“ said Jerome Peribere, President and CEO of Dow Advanced Materials. “I am certain that with his experience and leadership he will help our division meet our aggressive goals and help transform Dow into a truly market-driven company.”

Hockstra was named Vice President and Site Director of Dow Texas Operations in December 2007.

“Leading Texas Operations has been one of the highlights of my Dow career,” said Hockstra, who will relocate to Philadelphia. “It was a privilege to work with such an outstanding group of employees, retirees and community stakeholders every day. I’m going to really miss working at this site, but I’m very excited to be a part of Dow Advanced Materials.”

Earl Shipp, the current Vice President and Site Director of Dow Michigan Operations, has been named the new Vice President and Site Director of Dow Texas Operations in Freeport. Shipp will relocate to Texas.
Hockstra joined Dow in 1980 after earning a degree in Chemical Engineering from Michigan State University. He began his Dow career in Midland, Michigan, working in Research & Development.   In 1985 he relocated to Italy and subsequently moved to Terneuzen, the Netherlands where he worked in Manufacturing & Engineering.

In 1996, Hockstra moved to Texas to serve as Light Hydrocarbons Technology Leader for Texas Operations.  In 2000, he assumed the additional responsibility of Light Hydrocarbons R&D director. In late 2002, he was named Manufacturing Director of Engineering Plastics and in 2004 he assumed the role of Manufacturing Director for Engineering Polymers.

Upcoming TCC & ACIT Events

October 5th – ACIT Mid Coast Breakfast at the Dow Chemical Company’s Freeport cafeteria. Click here for details.

October 6th – ACIT South Texas Reverse Trade Show in Corpus Christi. Click here for details.

October 13th – TCC/ACIT Annual Meeting Luncheon at the Hilton Houston Hobby Airport Hotel. The featured guest speaker will be Texas Agriculture Commissioner Todd Staples.

October 21st – ACIT Mid Coast Golf Tournament at the Wilderness Golf Course in Lake Jackson. Click here for details.

October 27th – ACIT Houston Ship Channel Fall Golf Tournament at Timber Creek Golf Club in Friendswood. Click here for details.

December 7th – ACIT South Texas Economic Outlook Breakfast. Details to follow.

Upcoming Member Events

For a listing of TCC & ACIT Member promotions and events, please click http://www.acit.org/categories/Events/Upcoming-Member-Events/.
(These events are not organized or endorsed by TCC or ACIT.)