Downwinders At Risk: FAIR SHARE

A Rational, Regional Plan to Reduce Barnett Shale Air Pollution

Did you know that more smog-producing "VOC" pollution is being released into North Texas skies from gas drilling and development than all the cars and trucks in the region combined?

It's true. For the longest time officials could blame vehicles for most of DFW's chronic smog problem.
No more.

Volatile Organic Compounds, or VOC pollution from vehicles is declining while the same kind of smog-forming pollution from gas industry sources is steadily growing. And the turnaround has come in just the last five years.

Gas drilling pollution has never been included in past DFW clean air plans in the way paint shops, power plants or even bakeries have been. That's got to change if we want to see the continued progress in air quality that we need.

Fortunately, we have an opportunity right in front of our noses to dramatically decrease this kind of pollution in 2011.

TCEQ SCHEDULED TO VOTE ON
A NEW DFW AIR PLAN THIS JUNE

Because DFW flunked the old 1997 smog standard in 2009 and 2010, the state must submit a new clean air plan for the region to EPA at the end of this year - 2011. That plan is scheduled to be approved by the Texas Commission on Environmental Quality by June and then open for public comment for a number of months before finally being forwarded to EPA in December. EPA can approve it as is, or send it back for revisions.

For the plan to be legal, it must include cuts in two kinds of major smog-forming pollutants: Nitrogen Oxides (NOx), primarily from combustion sources like engines and furnaces, and Volatile Organic Compounds (VOCs), emitted by combustion as well, but also as fumes from tanks, pipelines, and other non-combustion sources.

Both NOx and VOCs are released by the gas industry in DFW. In 2009, the state passed new rules governing engine efficiency in North Texas that are predicted to significantly reduce NOx pollution from the gas industry. However, VOC emissions from the gas industry remain essentially unregulated and are being allowed by TCEQ to grow, even as DFW faces a new, tougher ozone standard expected to be announced by EPA this summer.

THE HUGE "VOC GAP" IN THE NEW DFW AIR PLAN

TCEQ believes it has all the cuts it needs for NOx pollution in its current DFW air plan, but admits it still needs to cut approximately 140 tons of VOCs PER DAY. At the same time, the agency estimates that there are well over 100 tons a day of uncontrolled VOC emissions coming from the gas industry in the 9-County DFW "non-attainment area" for ozone, or smog.

You'd think TCEQ would have set about months ago to fill this large VOC gap in the new DFW air plan with the equally large amount of new Barnett Shale VOCs that have never been subjected to an air plan before. In fact, it tried first to downplay the estimate of how much of a cut was needed, and then tried to jiggle the numbers by using a different starting point. Neither strategy worked, and as of right now the state still needs to cut 140 tons a day of VOC pollution by June.

Those tons should come from the one industry that's contributed the most to the problem and been affected the least by 20 years of previous air quality planning.

Based on computer modeling done by TCEQ itself, a very good case can be made that is was gas industry emissions that caused the last DFW clean air plan to fail in 2009 and 2010. That is, the large volume and location of gas industry pollution could have made the critical difference in not being able to meet the 1997 federal ozone standard.

Despite this evidence, and even though it now overwhelms even car and truck exhaust in DFW, gas industry VOC pollution is not being targeted for reductions in the current 2011 DFW clean plan proposed by TCEQ.

THE FAIR SHARE FOR CLEAN AIR CAMPAIGN

Based on our successful Campaign for Green Cement, Downwinders is using the region's air quality future to prompt local governments, institutions, and individuals in North Texas to act in self-defense and demand TCEQ fill the VOC gap in the DFW clean air plan with cuts in uncontrolled gas industry emissions. We're calling this effort the Fair Share for Clean Air Campaign.

It's called "Fair Share for Clean Air" because it's time the gas industry did its part to clean up DFW air. Over the last 20 years, every other industry and business that releases smog-forming pollution has had to add controls, find new ingredients, or change production methods to reduce their emissions. Now, as its share of total air pollution continues to grow and creates an obstacle to air quality progress, gas emissions must be cut as well.

TOXIC EXPOSURES REDUCED

By requiring these cuts in gas VOC pollution through the new DFW air plan, we'd be dramatically decreasing a large source of the controversy surrounding gas drilling itself. Gas field VOCs includes carcinogens like benzene and formaldehyde, as well as potent greenhouse gases like methane.

In 2010, a study by the Houston Advanced Research Center revealed that levels of cancer-causing formaldehyde in North Texas air are more than double that of the Houston Ship Channel and that TCEQ monitoring of it was " too sporadic and inaccurate" to do much good. TCEQ's own tests in the Barnett Shale have shown "some of the highest benzene concentrations we have monitored in the state."

VOC poisons are believed to be behind many of the reported acute health problems associated with gas industry downwinders, including respiratory illness, nosebleeds, headaches, rashes, nausea and neurological problems.

Using off the shelf technology available right now, these emissions could be reduced by 90% or more by 2013. That's almost nine million pounds of toxic air pollution annually that could be eliminated in the next two years. No other strategy offers a quicker, more substantial cut in gas industry emissions.

POLLUTION CONTROLS ARE MONEY-MAKERS

Moreover, reducing this kind of pollution actually makes the gas industry money because most of the pollution controls that would be used capture profitable product that's now literally evaporating into thin air. Think about the vapor recovery system at your local gas station and you get a good idea of how these controls work. It's been estimated that gas companies could earn millions by simply re-directing these emissions back into their facilities.

A LEVEL-PLAYING FIELD FOR ALL OPERATORS

It also means all gas drilling abides by the same cleaner air standards throughout the nine-county area. There would finally be a level playing field instead of different standards for different cities and counties. An operator in Denton would have to have the same controls on the same equipment as the one in Johnson County and in central Ft. Worth.

A CALL TO ACTION

This approach makes sense to everyone who hears it...except the TCEQ. Commission representatives have basically told DFW elected officials not to interfere.

North Texans must either persuade TCEQ to add new controls for gas facilities in the DFW air plan scheduled for its approval in June, or persuade EPA to enforce the law and require TCEQ to include those controls before approving the plan in December. Fortunately, some of the same tools work toward both goals.

From now until the June TCEQ vote on the DFW air plan, and then until the end of the year if we must go to EPA, Downwinders will be assembling local alliances to get "Fair Share" resolutions passed by municipal and county governments in DFW's "non-attainment area." We'll also be trying to win the support of state and federal legislators, churches, civic groups, and other social and political institutions to the cause.

We want to show the state and EPA that there's a large regional consensus for using the 2011 clean air plan to reduce the very kind of pollution that most needs to be reduced.

Fair Share resolutions call on TCEQ to cut smog-forming Volatile Organic Compounds, or VOCs, as part of the 2011 DFW clean air plan by using vapor recovery controls on condensate tanks, replacing gas-powered valves, requiring electric compressors, and using "green completions" instead of open flaring.

Help us build a clean air plan that actually cleans the air. Contact us about bringing the Fair Share campaign to your city or county and use these resources to get started:

"Leaking Money" report on lost revenues (1819 KB)