Air Plan

This is the article the Dallas Morning News printed today on 2011 ozone levels. You should read it.

Then, if you haven’t already, you should read the post directly below this one.

Now, decide if the DMN wrote their piece specifically to try to rebut our post, or is it independently that shallow in how it looks at the data from this year?

No mention of the one or two air plans that have been implemented between the first part of last decade and now. Or the big difference in pre-2007 numbers vs after-2007 numbers.

No mention of the flat line that has been our ozone levels in DFW since around 2007, or the roll back this year’s numbers represents. Or mention that air pollution from new gas sources over the last five years is actually making planned progress impossible.

No mention of the fact that this year’s Design Value is the highest since 2009, and we have more monitors out of compliance than at anytime since 2007.

No mention of what part, if any, the economic slowdown is responsible for the difference between the early oughts and now.

No mention of the phenomena of excessive heat actually leading to less ozone because of the lack of atmospheric mix, something discussed in our comments section.

No mention of the fact that the proposed TCEQ do-over air plan aimed at the old 85 ppb standard is already obsolete itself because of the severity of this summer’s ozone numbers.

This summer is not following the script the TCEQ had already written in their air plan, but you wouldn’t know it from reading the News

They’ve got their rose-colored glasses on.

As reported below, this last Wednesday was the single smoggiest day in DFW this summer.

In fact, it was the single worst day in at least two summers, and maybe longer.

One of the results of this first week of Smogust was that a fourth DFW monitor, way up in Pilot Point, Denton County, had an “exceedence” over 85 ppb for the fourth time this year and it officially joined Keller, Denton, and Frisco as locations that have violated the 1997 federal ozone standard in 2011.

DFW has not had four monitors in violation of that standard since 2007. Using that as a measuring stick, we’ve already had the smoggiest summer in five years.

DFW’s ozone “Design Value,” i.e. the highest reading among the pool of fourth-highest readings at each monitor (every monitor gets three mulligans before the “exceedences” officially count as a Clean Air Act violation) so far this summer is the 90 ppb reading from the Keller monitor in early July.  That’s the second highest in the last five years (Eagle Mtn Lake had a 91 in 2009), and 5 ppb worse than it was last year.

Air quality in DFW has stopped getter better. At best, it’s stagnating. At worse, we’re seeing a rollback. This is exactly the opposite of what’s supposed to be happening according to the Texas Commission on Environmental Quality. Because all of us are supposed to be going out and buying new, less polluting cars (thanks to that awful EPA) smog levels should be steadily decreasing. To the point where we’ll be below 85 ppb by the end of NEXT summer. It’s all right there in their computer model. If only the real word would get it together and act like the model.

And it’s only the beginning of August. We’ve had violations as late as September 21, and season-high readings as late as mid-August. With the continuing drought and heat, we could certainly have high numbers well into September this year. Grapevine is just one more “exceedence” over 85 ppb away from being another monitor officially in violation of the Clean Air Act –  that would bring the total to five. Dallas North and Rockwall are two and three bad air days away from adding to that number. We’re just two more bad days away at Denton and Frisco from seeing the Design Value climb to as high as 91 or 95 ppb.

DFW hasn’t seen dramatic decreases in pollution since the most important parts of the 2006-2007 air plan was implemented – the one that cut cement plant pollution from Midlothian and contained actual control measures instead of just being a spectator to new car purchases.

Since that point, progress has stopped and a retreat is now in progress. Rick Perry is not making DFW air cleaner. He and his TCEQ are making it harder to have safe and legal air in DFW by not requiring the same level of controls on the cement plants, coal plants, and the gas industry as EPA has required of cars and trucks. These are the sources of smog pollution the state is responsible for regulating, only Rick Perry’s environmental agency isn’t interested in, you know, improving the environment.  Meanwhile, breathers in North Texas are stuck with the worst air in the last five years with no end in sight.

Sunscreen? Check. Hydration? Check. Oxygen tank?
Check.

Monday it was the Frisco monitor with a violation of the 1997 eight-hour ozone standard we’re still trying to meet in 2011. Tuesday it was Denton. Today…..by 11 am Rockwall shot up to 99 ppb which isn’t a good sign at all. Look for one or more monitors to trip again by the time the sun sets. You can keep track of your own deteriorating air quality here.

Update:
And so Wednesday’s final tally produced the single worst bad air day in DFW this summer, as well as the worst ozone season in five years. Six monitors exceeded the 1997 8-hour, 85 ppb federal standard that the current TCEQ clean air plan is supposed to meet: Frisco, Denton, Dallas North, Rockwall, Grapevine, and Pilot Point. Five of those monitors recorded  their highest readings for this summer. Combined with Tuesday’s violation in Pilot Point (which we missed), today’s smog levels make that monitor the fourth one in DFW now totally out of compliance with the 85 standard.  And folks, we haven’t had four monitors out of compliance with the 1997 standard since 2007.

Yesterday was a bad air day in North Texas despite the official TCEQ ozone forecast of “no problem-o.”

Smog monitors in Keller and Denton had already recorded their fourth reading over 85 parts per billion (ppb), with Keller providing this year’s benchmark high of 90 ppb. On Monday, the wind blew NE and it was Frisco’s turn, resulting in a 1997 standard-busting eight-hour average of 86 ppb.

That makes three DFW monitors out of compliance with the federal ozone standard we’re supposed to be meeting by now. That’s the most since 2009, when we also had ozone readings in the 90 ppb range.

We have one more summer to reach a three year running average of under 85 ppb, or the current TCEQ strategy officially fails. We’d have to have a lot of rain or favorable circumstances next summer to be able to avoid that fate. Or, you know, a really good clean air plan. The outlook for either is dim. Feds Fair Share: EPA Issues Gas Pollution Regs

Friday, July 29, 2011

In reaction to a court-ordered deadline for action, the EPA on Thursday released new proposed rules for reducing air pollution from oil and gas production, particularly from “fracking.” They look a lot like our own Fair Share Campaign, that in turn looked a lot like the conclusions of everyone who’s examined the issue who doesn’t work for the gas industry. And echoing Dr. Sattler’s “Leaking Money” report published by Downwinders in May, EPA estimates the controls will save gas operators millions of dollars annually by reducing waste.

Turns out that TCEQ is color-blind as well.

Some of you may subscribe to the Commission’s  DFW ozone alert e-mail list.

You may think those “Orange Alerts” you’ve been getting every so often since Spring are an indication of what days represent breathing health threats. You would be wrong.

When you get an orange alert, it means one or more monitors in DFW is registering an ozone level of between 75 and 96 parts per billion (ppb). This level of smog pollution is officially classified by TCEQ as air “unhealthy for sensitive groups.” You actually have to have a smog problem above 95 ppb to just be plain “unhealthy” air at TCEQ.

But TCEQ’s entire alert system is based on an out-dated understanding of what levels of smog do damage to public health.

Three years ago, the Bush Administration EPA recommended a new federal ozone level of between 60 and 70 ppb concluding that the old 85 ppb standard was no longer protective of public health. So when TCEQ is telling you the air outside represents only a threat to “sensitive groups,” it’s really a danger to all of us. And that danger goes down to 70 or even 60 ppb.

NPR had a report on the new standard and the antiquity of similar “air quality alerts” across the country.

The difference in the number of days that there are “unhealthy” levels of smog in DFW is significant depending on where you’re starting point is.

Since April, there have been 12 “orange” days in DFW according to the TCEQ database on line here (75 to 95 ppb at one or more monitors). During that same time there were 32 “yellow days” (60 to 74 ppb at one or more monitors) including nine that saw levels at 70 to 74 ppb.

So instead of 12 days of air this summer that have been “unhealthy for sensitive groups,” there have actually been 44 days of air that would be considered potentially unhealthy for everyone by EPA scientists. The problem of bad air grows almost 400%.

When things are orange at TCEQ, they should really be red. At least, you know, according to the scientists who study this stuff for a living.

However out of whack this system is regarding public health and current science, it’s in perfect alignment with the TCEQ’s and Governor Perry’s ideological view that smog isn’t much of threat to human health. For years, the agency has argued that ozone is a “benign pollutant” and doesn’t deserve all the regulatory attention it’s gotten from EPA.

Let’s all watch and see how long it takes for TCEQ to adapt its color-coded ozone alert system to the reality of a new EPA ozone standard scheduled to be announced in early August now. Office pool starts now. Here are the odds as of today:

Change when EPA proposed new standard is announced –  1000 to 1 Against
Change when EPA adopts final rules – 100 to 1 Against
Change when EPA requires new DFW clean air plan for the new std. – 50 to 1 Against
Change when Rick Perry leaves office – 2 to 1 For  

Just the other day, we were wondering if the Obama Administration could withstand industry lobbying on its third try to announce a new federal ozone standard that will make all the usual suspects cry out that the sky is falling. We have another 20 days or so to see out that decision turns out.

But there’s no question the Obama EPA is standing behind its proposed interstate air pollution transport rule, a re-working of a George W. Bush scheme to reduce pollution crossing state lines, despite all the whining by Rick Perry, TCEQ, ERCOT, the Dallas Chamber of Commerce and whoever else Luminant could get to pile-on that the EPA was just picking on Texas again.

This last week saw the EPA pushing back with specific opinion pieces in the major dailies, and a timely swing through the state by EPA Administrator Lisa Jackson.

It’s behind the DMN paywall, but Gina McCarthy, Assistant Administrator of the Agency’s Office of Air and Radiation writes that,

“Despite claims to the contrary, this rule is based on sound scientific and economic analysis and will benefit the people and businesses of Texas.

This rule will also help Texas be a good neighbor by preventing pollution before it can become a problem for other states — and unfairly deprive their people of the health benefits associated with breathing clean air. As a matter of fact, fine-particle pollution from Texas power plants travels far and wide, significantly affecting air quality for millions of Americans in 11 states. In turn, pollution reductions taken in other states and Texas will benefit Texas families, preventing an estimated 670 to 1,700 premature deaths per year starting in 2014.

In other words, Texas is not being “singled out” by the EPA, as some have claimed. Texas and its sources of pollution are being held to the same standards as other states.”

(Funny story about Ms. McCarthy and Texas. During the 10-month wait in 2009 for a new Region 6 EPA Administrator to be appointed by the Obama Administration, long-time General Counsel Larry Starfield became Acting Regional Administrator, has he has been before when waiting for a new President to appoint a replacement. Nothing new there. Except that Texas and EPA were already at odds over the legality of the state’s “flex permits.” Instead of allowing Starfleld to act as the Agency’s negotiatoir, TCEQ Chairman Byran Shaw insisted that senior EPA officials from DC be at the table – no substitutions allowed -even though Starfield had the most experience with the program. Consequently, to satisfy Chairman Shaw’s pique, McCarthy traveled down to Texas over and over again during that first year, until Dr. Armendariz was eventually appointed as Regional Administrator and took over the reins. Ms. McCarthy knows the TCEQ very well. )

At the same time, Administrator Jackson was in Austin at a conference on green energy when she was asked about all the moaning and groaning by state officials on behalf of EFH and Luminant, the companies that have the dirtiest coal-fired power plants in Texas, and therefore the most cleaning-up to do. She had this to say:

“Well, three points. I’m happy to talk to ERCOT and we’re going to reach out to them to understand their concerns. But three things. Remember, the cross-state pollution rule is really the next generation of CAIR, which was proposed under Bush administration. Texas is a part of it. There is no surprise here for facilities. Don’t forget the extraordinary public health benefits. We’re talking about between 670 and [number unclear on tape] lives each year starting in 2014. That’s Texans. And that equates to billions, between $5 and $14 billion in health costs. Last but not least, this is not an onerous rule. Our modeling shows that over 50 percent of the pollution, the particle pollution, the soot that we’re worried about, comes from three plants. This is technology that’s out there that other plants have. Actually much of Texas’s generation is quite clean, and so our model shows this can be done cheaply and efficiently.”

Let’s take this opportunity to remind everyone that at the same time that Governor Perry and Bryan Shaw are criticizing EPA for it “heavy-handedness,” with this transport rule and other issues, the two are using the EPA’s own tougher emissions standards for cars as the basis for the proposed DFW smog plan. TCEQ’s strategy, and we’re not making this up, is to watch as everyone buys new cars with these higher emission standards and hope that smog levels go down.

When the new EPA transport rules take effect, there will be less ozone-forming pollution making its way from East and Central Texas coal-fired power plants into the DFW Metromess. This probably means there will be less ozone in general (although you never know with the rise of gas drilling in North Texas). And that probably means lower ozone levels sometime around 2014. If the levels do dip, we’re pretty sure that state officials will find a way to take credit for it, even as they accuse the EPA of destroying Texas’ economy.

At least that’s the forecast from TCEQ today.  We’re already at a 90 ppb “design value” after being at 85 ppb last year. This year’s current high number was set in early July. The odds are pretty good that DFW will have more violations at least through August-September. The only question is how high will this year’s number go? This is the kind of “progress” you get when the agency put in charge of cleaning up your air doesn’t really think dirty air is a problem.

Thanks to an entity named Jimzshow over at YouTube, you can see video highlights of last Thursday’s Rick Perry Bean Cook-Off and TCEQ Smog Hearing, including:

The Calvin and Tim Show before the hearing.

Downwinders’ own Jim Schermbeck making the case that the plan has already failed, even before it’s finalized.

Arlington Environmental Institution Julia Bergen doing the Talking Smog History Blues.

Arlington resident, gas activist and Ben Zine friend Kim Feil.

St. Jo Resident Joe Dial’s letter to Governor Perry and the TCEQ Commissioners.

Texas Campaign for the Environment’s Jeff Jacoby, complete with Rick Perry Mask prop.

..and more. Check it out.

But according to this website info, the NW Tarrant Tea Party Folks were asked to come over and counter the “misinformation” about gas drilling by the astroturf group CLEAN Resources (Citizens for Lasting Energy and Affordable Natural) Resources. This accounts for at least two or three of the 10 am hearing speakers and maybe one at the evening session. Pretty weak tea actually.

As Sharon says, however, this refers to Colorado and New Mexico, and not Ft. Worth, which missed its own deadline to release its massive study of gas air pollution Wednesday in favor of a roll-out Thursday Noon. When it does go up, it should be accessible by way of this website.

The Colo. and NM study contains sampling done by citizens groups at various sites which found:

“…a total of 22 toxic chemicals in the air samples, including four known carcinogens, as well as toxins known to damage the nervous system and respiratory irritants. The chemicals detected ranged from 3 to 3,000 times higher than what is considered safe by state and federal agencies. Sampling was conducted in the San Juan Basin area of Colorado and New Mexico, as well as Garfield

County in western Colorado.”

As you might have guessed by now, the toxins they found were Volatile Organic Compounds (VOCs) like the ones that the TCEQ decided not to reduce in the proposed smog plan up for a public hearing Thursday night. Yet another reason to come and tell the state it must do more to clean the air, including reducing gas industry VOCs, which are the largest single source of the pollution in the 9-county “non-attainment” area for smog pollution.