Air Plan

Via the journal Nature comes news that air sampling in the natural gas fields north of Denver have shown gas operators losing approximately 4% of their product to the atmosphere — not including additional losses in the pipeline and distribution system.  That’s more than either industry claims or government emissions inventories report. “If we want natural gas to be the cleanest fossil fuel source, methane emissions have to be reduced,” says Gabrielle Pétron, an atmospheric scientist at the University of Colorado in Boulder who helped wrote a summary of the findings. Much of the released methane comes from batteries of storage tanks, but a significant percentage is just “raw gas” leaking from the infrastructure. This data from the field is giving new credence to Cornell Professor Robert Howarth’s report from last year that concluded natural gas actually released more Greenhouse Gas pollution than coal over the lifetime of each fuel’s use (R. W. Howarth et al. Clim. Change Lett. 106, 679–690; 2011). “I’m not looking for vindication here, but [the NOAA] numbers are coming in very close to ours, maybe a little higher,” he says. We’ve written before about the crossroads Dallas is facing in allowing gas drilling as the only North Texas city committed to a plan to reduce Greenhouse Gas pollution. This new study suggests that it will be impossible for Dallas to honor its commitments for those reductions if it allows drilling without compensating for the increase in Greenhouse Gas emissions somehow. 

Via the Westchester Gazette in Grand Prairie, this is a GIS map of the pads and gas wells covering intersection of Tarrant, Denton and Wise Counties. It could also be Dallas’ future. There are only two more meetings of the Dallas Gas Drilling Task Force before the group issues its recommendations to the City Council – Tuesday February 21, and Tuesday, February 28th, both meetings on the 6th floor of Dallas City Hall, and both starting at 2 pm. Based on media coverage, you might get the impression there are only a handful of lease sites in Southwest Dallas and Oak Cliff at stake. In fact, there are many, many more than that – hundreds more. You’re going to be reading more about these sites in the weeks to come in an attempt by Dallas citizens to keep these kinds of maps from coming true on the east side of the Metromess. 

This is not a story that will ever make national headlines. It hardly even got a respectably-sized article in the town where it’s taking place. But for beat-down citizen-soldiers of the air wars looking for proof that their own local battles can affect national policy, it’s a tale worth telling. Yesterday, the Department of Justice and EPA announced a settlement agreement with a multinational cement company called ESSROC. Among other things, the agreement calls for the pilot testing of advanced Selective Catalytic Reduction (SCR) pollution control technology at ESSROC’s two obsolete wet kilns in Logansport, Indiana. Wet kilns like the three at Ash Grove’s Midlothian plant. It will be the first demonstration of this remarkable technology on wet kilns anywhere in the world. Last year, DOJ reached a similar agreement with LaFarge Cement that’s requiring a pilot test of SCR on a dry kiln in Illinois. Those results are due by July, 2013. The results from the wet kilns in Indiana will be due by May, 2015. This will be about the time the DFW area is trying to assemble a new clean air plan to reach the just-announced ozone standard of 75 parts per billion. We’ll have pilot tests of SCR on both types of kilns in Midlothian, and Downwinders will be using those tests to advocate finally requiring SCR on all Midlothian cement kilns. In use in European cement kilns for a decade, SCR – basically a huge industrial size version of the catalytic converter every US car has – has been proven to reduce emissions of smog-forming Nitrogen Oxides by 90% or more, while also reducing Particulate Matter pollution, metals, and dioxins. It’s considered the gold standard of kiln control technology. When it does end up in Midlothian, SCR will be coming back to the kilns and people that are responsible for its import into the US. That’s because Downwinders was the first citizens group in the country to began advocating the use of SCR in cement kilns – way back in the year 2000, as part of a DFW anti-smog plan. Impossible the state and cement companies said. Too expensive. Not technically feasible. We didn’t win, but we kept up with information about the technology. A couple of years later, our modest assistance to a group of citizens fighting a proposed Holcim cement plant right on the banks of the Hudson in New York gave us access to their hired engineering expertise, which had done its own technical review of SCR in Europe. We took that information and made it a basis for a demand in our own settlement with EPA and TCEQ over the failed 2000 DFW air plan to do an independent review of SCR for application to the Midlothian kilns. That 2006 study is still the only study of its kind in the nation. Much to TCEQ’s lasting chagrin, that report confirmed that SCR was technically and economically feasible for application on the Midlothian cement plants. TCEQ has done its best to run away from that report every since, even having its staff perjure themsleves in state legislature testimony about its conclusions, but it got published and distributed nationwide. Other states and engineers read it, and are still using it. During this same time Downwinders, with the help of funding acquired through yet another settlement, hired its first ever technical expert, a young engineer from SMU named Al Armendariz. One of his jobs was to review the SCR report we’d generated and collect more data on the track record of the technology in Europe. By the end of his stint, he was somewhat of an expert on cement control technology, especially SCR. And then he went to go to work as the Regional Administrator of EPA. As it happens, EPA was in the middle of a national enforcement initiative involving the entire US cement industry. Many of the violations that were found revolved around illegal and excessive emissions of Nitrogen Oxides. Downwinders pressed for SCR pilot tests as part of these agreements. In January, 2010 EPA and DOJ announced the LaFarge settlement requiring a first-ever US pilot test of SCR. In discussions with EPA Midwestern staff afterwards, it was clear that the TCEQ report and Downwinders’s efforts were well-known and provided the technical evidence to help drive the settlement talks toward including an SCR provision. Yesterday’ announcement of a new round of SCR pilot-testing indicates that influence is still being felt…..Did we need luck? Absolutely. Did we make our own luck? Absolutely. We were opportunistic as hell. We advanced the cause at every turn. We fit square pegs into round holes. Unrelated developments got pulled into relationships that built on previous steps because we saw a path that nobody else did. We slowly built the technical and political scaffolding we needed. And these last two years have seen the fruits of that strategy. What began as a demand for a specific control measure for a local DFW clean air plan has now brought the entire US cement industry to the brink of using a control technology that could bring massive reductions in pollution nationwide. This is a story about the un-sexy, un-Erin Brockovich way of grinding out incremental social change with small groups of very persistent people. And it’s the way progress is made most of the time. Want to change the world? Start in your own backyard.

Unlike Texas, Wyoming’s Governor actually recommended that his shale-producing counties be included in smog “non-attainment areas” because of the pollution from gas industry sources. The EPA has agreed and now will draw boundaries for one of the most unique such areas in the entire country. That’s because unlike DFW and just about every metropolitan area in the country, ozone levels in Wyoming’s rural Green River Basin peak between January and March when Volatile Organic Compounds and Nitrogen Oxides from the gas industry combine with bright sunshine, snow on the ground, and temperature inversions to create the ideal conditions for ozone to form in large concentrations. 2011 was an especially smoggy year for Green River Basin residents, with levels exceeding the worst days in Los Angeles. Inclusion in an official ozone non-attainment area will now make gas industry sources the target of systematic pollution reductions via the same kind of controls that have been around for years, but which have yet to be adopted wholesale by industry or completely mandated by EPA. Despite the almost torturous incrementalism, this designation in Wyoming is proof that these local plans can force reductions from sources before national regulations catch-up to make them uniform. This is exactly the strategy Downwinders has been successfully using in the DFW air quality planning process since 1995, first to reduce emissions of the Midlothian cement plants, then including power plants, and a host of other sources. This past year we argued that the increase in emission from gas sources warranted new controls on all Barnett Shale operations in North Texas. We didn’t win that fight, but we didn’t win the cement plant fight the first time out in the 1990’s either. We won’t stop trying because in Texas, these federal plans are one of the few ways for citizens to affect their air quality future.

Despite DFW and Houston having very bad smog years, the Austin-San Marco Metropolitan Area managed to achieve compliance with the new 75 parts per billion ozone standard in 2011 – but just barely. The San Marcos Mercury runs down the particulars, including the origin of Central Texas air pollution where half of the amount of ozone is from on-road vehicles, 20-25 percent is from non-road sources like construction and agricultural equipment, and the remaining 25-30 percent is from industrial sources such as power plants, cement kilns, lime kilns, and oil/gas production equipment. Cement kilns? Why yes. In fact, the Lehigh cement plant in Buda, south and upwind of Austin, is the largest point source in the Austin MSA for nitrogen oxide (NOx) – a major smog-forming pollutant. Also upwind of Austin, TXI, Capitol and Alamo cement plants form the second largest cluster of kilns in Texas (second only to Midlothian) between New Braunfels and San Antonio. And don’t forget all the Eagle Shale pollution south of San Antonio that’ll also find its way to the Capitol City on some “ozone season” days.  There’s no question that should smog get worse in Austin (likely), or the ozone standard come down to 70 ppb in 2014-2015 when it’s next reviewed by EPA (likely if President Obama is still in office) Austin air quality planners will be looking to how Downwinders worked to reduce NOx pollution from the Midlothian cement kilns. Nor is Austin the only American city that will have to deal with cement plant pollution because of more protective ozone standards in the coming years. As “non-attainment areas” get bigger, more cement plants that were “out in the country” will all of a sudden be in the upwind backyard of metropolitan areas. In this respect, the template that Downwinders has helped establish in Midlothian/DFW – retrofitting pollution controls for 30 to 40% reduction, while pushing for newer systems from Europe that can get up to 90% reductions – will be serving as a national model for years to come. “Give us a place to stand, and we can move the world.”  Read More

Late Friday EPA announced that it was recommending two more North Texas counties – Wise and Hood – join the current nine-county DFW “non-attainment” area for smog, or ozone pollution for purposes of trying to reach the new 75 parts per billion federal standard. In doing so, the EPA disagreed with the latest State of Texas plan to leave the non-attainment area boundaries unchanged. But as the Star-Telegram points out today, that wasn’t the original position of the state. In 2008, the Texas Commission on Environmental Quality suggested both Wise and Hood be included in DFW’s smog zone. According to the documents submitted to EPA by TCEQ supporting this inclusion (accessible via a link in the S-T article), “Wise County produces significant stationary source emissions, ranking 2nd in the 13-county air quality planning area for NOx emissions in 2005. Hood County, the thirteenth county in the air quality planning area, has a design value of 84 parts per billion for 2005 through 2007, and a preliminary design value for 2006 through 2008 of 77 parts per billion.”  But, as the S-T story points out, TCEQ commissioners requested that Wise be removed from the recommendation to the governor’s office in December of 2008 and Hood was cut out of the recommendation less than two months ago. Supposedly, these counties were removed by the state because ozone averages up to and including 2010 were lower than the ones in previous years. But that’s only one criterion and since Wise doesn’t have  monitor at all – because TCEQ is afraid of what it might find – that’s not a legitimate argument for its absence on the TCEQ list to EPA. But wait there’s more. In the documents EPA sent the state to justify both Wise and Hood Counties being included, it cites a number of different factors, including new emissions from Barnett Shale gas production. EPA used a national 2008 comprehensive emissions inventory to account for how much smog-producing Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOCs) were coming from each North Texas county. According to this data, Hood County had 5500 tons a year of NOx emissions, and 9500 tons a year of VOCs FROM ALL SOURCES, while Wise had 12,000 tons a year of NOx and 23,700 tons a year of VOCs. Those are big enough numbers to get noticed. And yet EPA notes that a year later, TCEQ did its own Barnett Shale emissions inventory and found even higher totals for some counties. For Hood, Shale production accounted for 7000 tons a year of NOx – or more than 1500 tons more a year than the EPA’s inventory of all sources in Hood County combined. VOCs from gas pollution accounted for 2100 tons a year, or almost a quarter of the EPA inventory total. In Wise, TCEQ’s shale inventory found 2500 tons of NOX, and 6000 tons of VOCs a year being emitted from gas production. In addition, EPA traced back where dirty air came from on high ozone days at selected Tarrant County and Parker County smog monitors. It concluded that these “back trajectories” for the Eagle Mountain Lake and Parker County monitors “further support that air that is transported from Hood and Wise Counties ends up in the area when ozone exceedences are observed.” As we noted on Friday, this is the first time in the two decade battle over DFW air quality that gas industry air pollution has been a reason for including a county in the DFW non-attainment area. That’s what makes this latest announcement such a milestone, and worthy of more discussion in places like the Dallas and Denton gas drilling task forces that are charged with re-writing those cities gas mining ordinances.

Yesterday the EPA sent Governor Perry a letter saying that it had rejected the state’s recommendation to keep the DFW non-attainment area for smog, or ozone pollution, restricted to the same nine counties, and instead will expand it to include Wise and Hood Counties. This is overdue good news. Wise County is where the pollution from DFW often goes during”ozone season” when south by southeast winds blow everything north by northwest. TCEQ has been avoiding putting any ozone monitors in Wise County for fear of the high levels of ozone pollution they might find there which would make DFW air quality look even worse that it already is. Wise County is also the birthplace of horizontal fracking of gas hosts countless wells, compressors, pipelines and a huge processing facility in Bridgeport. These emissions, along with the commuter travel from Wise to the rest of DFW, and the fact that the county is already part of the regional transportation authority, are all reasons why it’s being included in this latest designation. Hood County’s Gas drilling and commuter travel is primarily responsible for its inclusion, although it hosts some power plants as well. According to the EPA, high ozone readings near Wise, “indicates that this county should be included in the nonattainment area. … The high growth in these emissions is due in large part to growth in emissions from Barnett Shale gas production development, but also due to growth in population.”  It’s the first time the EPA has added counties to the North Texas non-attainment area because of gas industry pollution. Both counties will now be automatically included in the air quality planning process that will determine what the next DFW clean air plan, aimed at the new 75 parts per billion federal ozone standard announced in September, will look like. No start date for that process yet, but the final plan for DFW to reach 75 ppb must be submitted by 2015 or so which means we may see the machinery gearing up after next year’s presidential election. Meanwhile, new restrictions will begin to be introduced, including “off-sets” (new large “stationary” source of pollution can’t relocate to Wise or Hood without committing to reducing more smog-forming pollution than they would emit) and vapor recovery units on gas station pumps.

Tuesday morning saw the last 2012 meeting of the North Texas Clean Air Steering Committee at the Council of Government’s HQ in Arlington. It was also the lowest point in DFW air quality planning in the last 20 years. On the agenda was a summary of the latest TCEQ clean air plan for DFW, the one that predicts we’ll have the cleanest air we’ve ever had next summer – just in time to avoid a third failure in reaching a 1997 85 parts per billion smog standard in the last five years. Downwiders Director and Committee member Jim Schermbeck grilled TCEQ engineer David Brymer about the probability of every DFW monitor hitting historic lows in 2012, as the TCEQ computer model driving this air plan predicts. “It’ll be very challenging,” was his response. No. Getting unemployment below 7% is challenging. Having the cleanest air on record a year after suffering the worst air in five years is downright impossible, and TCEQ knows this. EPA knows this. Everyone knows this. And yet the TCEQ Commissioners will be voting to submit this DOA plan to EPA next Tuesday, because “the modeling” shows we’ll be doing great! Sitting through this TCEQ storytelling time was a minority of Committee members. Only a handful bothered to show-up, and most of them left before the final discussions. Attendance at these meetings over the last two years by almost everyone but the three environmental representatives has been awful. But maybe the reason a lot of them didn’t show up on Tuesday was because their decision to trust TCEQ back in January and not vote to recommend any new pollution reduction strategies for this clan air plan seems even more foolish and irresponsible now  – after the worst smog since 2007 and a state plan that was written by Mother Goose. “The TCEQ knows best” mentality was ever-present this time around, fueled of course by people who’ve never dealt with TCEQ, and/or who are ideological soulmates of Governor Perry who don’t want any new pollution controls measures imposed by government. Missing from this cycle of air quality planning was the gravitas of past sessions, where there was actually some seriousness about cleaning the air. But no worry, we’ll all be back at it in a year or so when the regulatory machinery will be gearing-up for a new clean air plan for DFW to meet the new ozone standard of 75 ppb. Nothing in life is certain but death, taxes and DFW smog plans.