“Imaginary SIPs’ For $200 Alex.” “What the TCEQ DFW Clean Air Plan Looks Like After the Last Four Days”

Since Thursday, this is what’s happened to the DFW air shed:

There have been 32 violations of the old 85 ppb federal ozone standard at 14 of the 20 DFW air monitors.

There have been 31 new season-highs ozone readings set at 19 of those 20 monitors.

There have been three 8-hour episodes averaging 100+ ppb of ozone.

2 more monitors officially violated the Clean Air Act standard by adding 4th highest readings of 85 ppb or more. Now there’s a total of 6, the most since 2006.

The region’s official “Design Value” rose three times in four days – from 90 to to 92 to 95 ppp. That’s the highest it’s been since 2006.  Last year it was 86 ppb.

And that means that next year the ozone Design Value for DFW would have to be 71 ppb or lower for the Texas Commission on Environmental Quality’s currently proposed clean air “plan” for DFW to not fail. Basically, we’d all have to evacuate for the summer.

This is the math: 86 (2010’s DV) + 95 (2011’s DV – w/ one month to go) + 71 (what DFW needs in 2012) = 252 divided by 3 = 84 ppb.

Nothing over 84 as a three-year running average will do. That’s the formula in the Clean Air Act. 

There is no example of the DFW ozone pollution Design Value falling by 24 ppb in one year, or even over the 15 years the government’s been keeping track. And there’s nothing the TCEQ is doing in the next 12 months to change that. No new regulations, no new controls proposed for polluters. Just hoping that people buy new cars with those dreadful, oppressive EPA catalytic convertors in them.  They say that hope isn’t a plan, but the state is really trying hard to prove otherwise.

The TCEQ isn’t even going to turn in its “plan” until December or January. It’s still a proposed “plan,” even though it’s hopelessly, ridiculously obsolete after this weekend’s attack of the Smog Monster. It’s not just silly to continue to waste resources and tax dollars on something that has no chance of succeeding, it’s insulting.  The sensible thing to do would be to take the hit of being classified as a “severe” non-attainment area for ozone and begin anew the task of writing a clean air plan that’s actually, you know, a plan, with new ideas, implementing new technologies, and a chance at actually delivering something closer to safe and legal air for 6 million people.

But that strategy does have the disadvantage of requiring sensible people heading up the TCEQ. And since it’s TCEQ’s inanity and planned incompetence that brought us to the point of looking helplessly on as whatever air quality progress that was made in DFW over the last five or six years is wiped out, we wouldn’t count on TCEQ applying logic to the situation any time soon.