Air Plan

Yesterday, the Keller ozone monitor recorded an 8-hour average of 90ppb. It became the monitor’s fourth-highest reading for the summer, and thus, its “design value” in TCEQ jargon – the reading that sticks and becomes the measuring stick for progress toward getting below the 1997 federal standard of 85 ppb. And we’re not doing so well right now.

Keller’s design value on Tuesday was in the high 70’s. On Wednesday it was 85ppb. On Thursday it was 90ppb. It’s been a good week for bad air in DFW.

As fate would have it, this new and bad design value, (the first in the 90’s range since 2009), occurred on “Clean Air Action Day,” the official local government and business-sponsored effort to encourage car pooling, biking and such during ozone season (raising hell with local governments and businesses to clean the air never seems to make their list). Despite “companies doing their share for cleaner air” DFW busted the 85ppb standard sooner than we have in years.

Seems like only yesterday officialdom was declaring that “July isn’t a traditional high ozone month.” Someone forgot to tell July.

A higher design value for 2011 makes it less likely that even a good showing in 2012 can save us from the three year average over 85ppb that will signal the failure of the TCEQ “do-over” SIP and the need for a third try.

2010’s design value was 85ppb. Even if 2012 saw a design value of 84ppb – something that has never happened – this year’s 90 ppb gives you a three-year average of 86.3. That’s just about back where we started when this air plan process began, and still in “non-attainment” with the Clean Air Act. We’re not “really close” to getting below 85ppb anymore, we getting further away.

The TCEQ isn’t predicting a high ozone day for Friday, despite a weather forecast containing many of the elements that would make it one. We could use a breather.

Update:
Oops. TCEQ is now predicting a high ozone day today. So take an oxygen tank with you when you go out and hope the design value doesn’t go up to 95ppb.

Is This the Day DFW Fails the 85 ppb Ozone Standard…Again? Yes it Was.

Thursday, July 07, 2011

Yesterday, Keller recorded a 90ppb ozone reading, a violation of the 1997 85 ppb federal standard. That makes the July 5th high of 85 ppb recorded at Keller the fourth highest number for that site this year, and thus, Keller becomes the first DFW ozone monitoring site to record the 2011 official failure to reach the old standard. And there you have it, a nicely-wrapped present for the business-sponsored Clean Air Action Day! that occurring even as we speak today.

According to TCEQ’s ozone forecast, DFW is going to be having another bad air day today. Light winds out of the south-southeast, high temperatures, and a state agency intent on not going out of its way to achieve better air quality might all conspire to bring another wave of monitor “exceedences.” If one of those exceedences occurs at the Denton Airport monitor, then DFW will have not met the 1997 obsolete 85 ppb ozone standard once again.

In preparation for next week’s public unveiling of its proposed DFW clean air plan, the Texas Commission on Environmental Quality has scheduled a last-minute, out-of-nowhere, meeting for this Thursday, July 7th, of something called the Dallas-Fort Worth (DFW) Photochemical Modeling Technical Committee.

This is a CYA development on TCEQ’s part to legitmize the switching of one transportation model for another in the DFW “plan.” After using the same EPA model/software for a number of years, including the first three-quarters of the time it was crafting the DFW effort, TCEQ decided it wanted to use a new EPA model/software. One it had been actively resisting using for over a year. Why? Because the new model gets them more estimated Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOC) pollution from vehicles. The more pollution assigned to a car, the more pollution you reduce when you take it off the road.

Since the entire TCEQ 2011 “plan” for DFW is predicated on a steady rate of trade-ins of older, more polluting cars for new, less-polluting cars over the next three years, this new model gives the Commission more reductions….in theory. You have to believe the TCEQ rate of return will stay constant, that the vehicles bought will indeed be significantly less polluting, and that other factors won’t cancel out any progress you make (no reining-in gas industry pollution).  And you have to believe the TCEQ could be right about the effectiveness of one of its DFW air plans for the first time in 20 years. It could happen.

Downwinders has noted that, based on TCEQ’s timeline for the switch, the complete analysis of the new model/software will not be available until after the public hearing next week in Arlington. That means the public will have no opportunity to make comment on the adequacy of the new modeling, and thus the real plan – versus the one that used the old model being discussed up until last April. This strikes us as not honoring in spirit or letter the EPA’s renewed commitment to public participation, and could strike EPA the same way. 

This Committee meeting this week may be an effort to dull that criticism, by saying that, “look, things are essentially wrapped up and ready to go and the hearing will actually be about the real plan and not that thing we discussed for most of the plan-building process.”

For those of you who want a preview of the gory details, or just want to see how creative the TCEQ can be in rationalizing this switch, the meeting is at the uncitizen-friendly time of 10 am this Thursday, July 7th in the Transportation room at the North Central Council of Government’s headquarters in Arlington at 616 Six Flags Drive. 

Maybe we missed this item the first time, because The Star-Telegram’s Mike Norman mentions it in passing as an old news item from last October in his most recent column, but apparently the firm performing the giant “Ft. Worth Study” of the city’s gas facilities “found leaks at 68 percent of the sites tested. They had expected 10 to 25 percent.”

The study is going “door-to-door,” examining 50% of all the gas sites in Ft. Worth. A conservative approach would be to extrapolate that 68% to all the Ft. Worth sites.

We’ve made note of the fact that the TCEQ estimated annual inventory of Volatile Organic Compounds from the Barnett Shale gas industry was increased monthly from July to this May, when it stood at a little over 114 tons PER DAY. We haven’t seen the numbers for June. Studies like this could result in the state having to significantly increase their estimates. Remember that fully 80 tons or more per day of that total was traced back by TCEQ to leaking valves and condensate tanks with estimated leakage rates far less than 68%.

Although Ft. Worth’s study was supposed to be released this last week, it looks like now it won’t come out until July 13th – the day before the TCEQ hearing on the proposed new DFW clean air plan. The largest flaw with the TCEQ plan? It doesn’t address the growing volume of gas industry VOCs in the DFW airshed.  

Although they never actually use our Campaign name (maybe because their news division has done its best to ignore it), the Friday editorial makes the same case we do and calls on the state to respond to the desires of local governments to do more to cut toxic and smog-forming VOCs from the gas industry.

It also issues an important call for area elected officials to come to the July 14th TCEQ hearing in Arlington and directly request those larger cuts:

“While state regulators have sometimes seemed impervious to public comments, this opportunity is North Texas’ best shot to improve yet another lackluster air-pollution plan. If local leaders stay silent, the TCEQ will stick with the laissez-faire approach that has left our area in a smog-filled haze.”

We would only argue with the “sometimes” language. For the last ten years or so, TCEQ has been remarkably consistent in always ignoring the public in North Texas when it comes to clean air plans. Still, the moment we give up challenging the Commission is the moment TCEQ will claim the public must like what it’s breathing.

Belated thanks to the editorial staff and yet another plea to get the paper’s Metro editors on the same page in covering local environmental stories. It’s getting really tiresome to find the only coverage of clean air efforts on the opinion pages.

DFW saw two more ozone violations occur on Wednesday, both at sites that had already tripped once in June. That means that the area has two monitoring sites that are already halfway to the four violations that would render 2011 another official clean air failure. All it takes are four separate eight-hour violations of the ozone standard at any one site for EPA to declare DFW in continuing non-attainment of the old 1997 85 ppb ozone/smog standard.

We especially like this reaction from industry: “I reject the notion of widespread or serious pollution,” says Kathryn Klaber, executive director of the producers’ trade group, Marcellus Shale Coalition.”
 

A belated congratulations and thank you to the Argyle Town Council and the Forth Worth City Council, which became the 8th and 9th North Texas cities to vote unanimously in favor of a Fair Share resolution calling for the Texas Commission on Environmental Quality to include significant cuts of Barnett Shale VOCs in the currently proposed DFW ozone plan. You know, the “do-over” plan to meet the obsolete 1997 ozone/smog standard that we haven’t been able to meet so far.

Another well-meaning, if empty-calorie, attempt to bring awareness to cleaner air by the regional Powers-That-Be. Unfortunately, our first four violations of the old 1997 ozone standard came on June 6th this year.  Wonder if anyone from COG will show up to testify at the July 14th public hearing on the DFW ozone plan to criticize the Rick Perry TCEQ that keeps us from achieving safe and legal air in DFW? That would be doing something substantive.

Amazing that it’s now up to “secondary”  outlets like the Denton Record-Chronicle to report air quality stories in the DFW area. In the past, both dailies would have had a story previewing the June 8th vote, and then a post-vote reaction piece. But that would require an environmental staff reporter, which neither the S-T nor the DMN possess right now. Fortunately for us, there are editors and reporters like Peggy Heinkel-Wolfe picking up the slack. No Comment: Commissioners Don’t Even Acknowledge Fair Share