cement industry
Citizens To Form Posse, Demand State Enforce the Clean Air Act at Thursday Hearing on New DFW Air Plan
(Arlington) Critics of a new plan to clean the air in Dallas-Ft. Worth are using a public hearing on Thursday evening to accuse the state of Texas of breaking the law by not requiring the implementation of pollution control technologies already in widespread use to help lower smog levels in North Texas.
“We’re asking residents to come out and get sworn into a citizens posse to help us make the state follow the Clean Air Act,” said Jim Schermbeck, Director of the local clean air group Downwinders at risk, one of the leading opponents of he new plan. “Austin is going to ridiculous, Monty Python-like lengths to avoid new controls on the Midlothian cement plants, East Texas coal plants, and local gas facilities in this new plan – even though those controls are now commonplace in each industry.”
Thursday’s public hearing centers on a new plan to comply with the federal ozone standard of 75 parts per billion (ppb) by 2018. DFW has never achieved such a low level of smog, and only this last year dipped below the 1997 standard of 85 ppb for the first time with the help of cooler, wetter summer.
EPA says a state plan like the one the Texas Commission on Environmental Quality is proposing for DFW must include “all Reasonable Available Control Technologies,” and “all Reasonable Available Control Measures” to get lower smog levels as “expeditiously as possible.” EPA defines these as technologies as ones that are “technically and economically feasible.” But according to Schermbeck, the state of Texas is deliberately ruling out local use of pollution controls already adopted by industry that could speed cleaner air.
He cited three examples. Selective Catalytic Reduction, or SCR acts much like the catalyst on cars, only on a much larger scale for industrial plants. It’s already in use on at least half a dozen European cement plants where it’s reduced smog-forming pollution by up to 90%, and on many coal-fired power plants across the world and in the US, where it achieves the same results. Yet the TCEQ DFW air plan doesn’t require SCR on the largest single sources of smog pollution in the region, the Midlothian cement plants, or the East Texas coal plants that are known to impact DFW air quality, saying the technology isn’t “feasible.” TCEQ maintains this stance even though the Holcim cement plant in Midlothian has announced plans to include an SCR unit on one of its own kilns.
“Here’s a pollution control technology already in operation and achieving great results, with a cement plant in North Texas already adopting it, but the state’s position is that it isn’t ‘feasible’. It’d be comical if it wasn’t delaying cleaner air for over 6 million people that haven’t had it in decades.”
Besides ignoring SCR on cement and coal plants, Schermbeck said the TCEQ has also ruled-out electrification of large gas compressors as “infeasible” – despite the widespread use of electric compressors In the Barnett Shale already and the requirement of municipalities like Dallas and Southlake to allow nothing but electric compressors within their city limits. According to a 2012 study by the Houston Advance Research Consortium, compressors could increase downwind ozone levels as much as 3 to 10 parts per billion. There are at least 647 large compressors in the DFW “non-attainment area” covered by the TCEQ air plan.
“Requiring just these three technologies that are already on the market and being used in their respective industries could reduce air pollution by thousands of tons a year and help us achieve compliance with the new federal ozone standard much quicker,“ said Schermbeck. He said they all pass the test of being feasible according to EPA definitions. “By law, they should be required.”
Instead, the state is relying exclusively on a new federal gasoline mix being introduced in 2017 to achieve the required 75 ppb standard by 2018. Although it’s expected to help lower ozone levels across the country, it won’t get DFW down to the level of 75 ppb alone. To make the plan work on paper, the state has had to estimate oil and gas pollution downward in a way Schermbeck and others claim is unrealistic.
“Basically, the state’s approach is to do absolutely nothing for the next three years and hope the federal gasoline change brings it “close enough” to the lower standard. But hope is not a plan.”
Schermbeck said his group would be passing out badges to members of their clean air posse and recruiting residents to persuade the EPA to reject the state’s proposal. The federal agency has the final say. But there’s also always court – where many clean air rules for the state of Texas have been decided over the last 20 years. “If government won’t enforce the law, we may have to do it ourselves.”
TCEQ’s Terrible, Horrible, No Good, Very Bad Air Plan for DFW
TCEQ Public Hearing on the new DFW Anti-Smog Plan
Thursday, January 15th 6:30 pm
Arlington City Hall, 101 W. Abram
Over the last two decades, we've seen some pretty lame DFW clean air plans produced by the state, but the newest one, scheduled for a public hearing a week from now, may be the most pathetic of the bunch.
From a philosophical perspective, the Texas Commission on Environmental Quality stopped pretending to care about smog in DFW once Rick Perry decided to run for president around 2010 or so. Computer modeling was scaled back, staff was slashed, and the employees that were left had to be ideologically aligned with Perry's demand that no new controls on industry (i.e potential or existing campaign contributors) was preferable to six or seven million people continuing to breathe unsafe and illegal air.
TCEQ's 2011 anti-smog plan reflected that administrative nonchalance by concluding – in the the middle of the Great Recession – that consumers buying new cars would single-handedly deliver the lowest smog levels in decades. It did not. It went down in history as the first clean air plan for the area to ever result in higher ozone levels. The first, but maybe not the last.
This time around, it's not the cars themselves playing the role of atmospheric savior for TCEQ, but the fuel they'll run on. Beginning in 2017, the federal government is scheduled to introduce a new, low-sulfur gasoline that is predicted to bring down smog by quite a bit in most urban areas. Quite a bit, but not enough to reach the ozone standard of 75 ppb that's necessary to comply with the Clean Air Act by 2018. It's the gap between this official prediction and the standard where the state is doing a lot of hemming and hawing.
TCEQ staffers really did tell a summertime audience in Arlington that that estimated 2018 gap of between 1 and 2 ppb was "close enough" to count as a success. Now, you might give them the benefit of the doubt, but remember this is an agency that has never, ever been correct is its estimation of future ozone levels. After five attempts over the last two decades, TCEQ has never reached an ozone standard in DFW by the official deadline. Precedent says this plan won't even get "close enough."
Plus, we know getting "close" to 75 ppb isn't protecting public health in DFW. Even as this clean air plan is being proposed by Austin, the EPA is moving to lower the national ozone standard to somewhere between 60 and 70 ppb (There's a hearing on that at Arlington City Hall on January 29th). That new EPA ozone standard is due to be adopted by the end of this year. So this entire state plan is obsolete from a medical perspective. Instead of aiming for a level of ozone pollution closer to 70 ppb as soon as possible, it's not even getting down to a flat 75 ppb at all DFW monitors by 2018. It wil take an entirely new plan, and pulling TCEQ teeth, to do that much later. In other words, millions of people will have to wait as much as a five to seven years longer to get levels of air quality we know we need now in 2015.
What are the major flaws this time?
1. TCEQ is Using 2006 in 2014 to Predict 2018.
The EPA recommends that states use an "episode" of bad air days from the last three years – 2009-2013 – in trying to estimate what ozone levels will be three years from now. The more recent the data, the better the prediction.
TCEQ is ignoring that recommendation, relying on a computer model that's already nine years old. This has all kinds of ramifications on the final prediction of compliance. Instead of having more recent weather data, you have to "update" that variable. TCEQ doesn't have to compensate for the drought DFW is experiencing now or factor in a year like 2011 where the drought caused a worst case scenario for ozone formation.
TCEQ isn't using more recent data on how sensitive monitors are to Nitrogen Oxide (NOx) and Volatile Organic Compounds (VOCs) – the major kinds of pollution that cause smog . That's important because gas production in the Barnett Shale has put a lot more VOCs in the air. But instead of getting a more accurate post-drilling boom read on what's driving smog creation, the TCEQ is relying on a picture that starts out before the boom ever started.
The further you reach back in time for a model to predict future levels of smog, the fuzzier that future gets, and the less accurate the results. TCEQ is using a model that's twice to three times older than EPA guidance recommends. What are the odds that TCEQ estimates will be correct based on this kind of methodology?
2. TCEQ is Downplaying OIl and Gas Pollution
Citizens attending the air quality meetings in Arlington over the past year have seen the TCEQ try and hide the true volume and impact of oil and gas pollution at every turn. Instead of all the industry emissions being listed under the single banner of "Oil and Gas Pollution," the Commission has tried to disperse and cloak them under a variety of categories in every public presentation.
"Other Point Sources," a classification that had never been seen before, was the place where pollution from the 647 large compressor stations in DFW could be found – if you bothered to ask. "Area Sources" was where the emissions from the thousands of other, smaller compressors could be found – again, only if you asked. "Drilling" was separate from "Production." And despite other agencies being able to tease out what kind of pollution came from the truck traffic associated with fracking within their jurisdictions, the TCEQ never bothered to estimate how much of the emissions under "Mobile Sources" was generated by the Oil and Gas industry.
The reason the TCEQ has tried so hard to hide the true volumes of oil and gas pollution is because once you add up all of these disparate sources, the industry becomes the second largest single category of smog-forming pollution in DFW, second only to on-road cars and trucks (and remember many of those trucks are fracking-related). According to TCEQ's own estimates, oil and gas facilities in North Texas produce more smog-forming VOC pollution than all of the cars and trucks in the area combined, and more smog-forming NOx pollution than the Midlothian cement plants and all the area's power plants combined.
TCEQ is loathe to admit the true size of these emissions and place them side-by-side next to other, traditional sources, lest the public understand just how huge a impact the oil and gas industry has on air quality. Austin's party line is that this pollution isn't contributing to DFW smog – that it's had no impact on local air quality. But such a claim isn't plausible. If cars are a source of smog, and cement kilns and power plants are a source of smog, how can a category of VOC and NOx pollution dwarfing those sources not also be a source of smog? Think how much less air pollution we'd have if the Barnett Shale boom of the last eight years had not taken place?
In it's last public presentation in August, the TCEQ made the impact of oil and gas pollution clear despite itself. According to the staff, oil and gas emissions were going to be decreasing in the future more than they had previously estimated. As a result, a new chart showed that certain ozone monitors, including the one in Denton, would see their levels of smog come down significantly. It was exactly the proof of a causal link between gas and smog that TCEQ had been arguing wasn't there. Only it was.
In terms of forecasting future smog pollution, TCEQ is underplaying the growth of emissions in the gas patch. Everything it's basing its 2018 predictions on is years out-of-date, leftover from its last plan.
Drilling rig pollution is extrapolated from a 2011 report that counts feet drilled instead of the actual number of rigs. TCEQ predicts a decline in drilling and production in the Barnett Shale without actually estimating what that means in terms of the number of wells or their location. It also assumes a huge drop-off in gas pollution after 2009 that hasn't been documented by any updated information. It's only on paper.
While recent declines in the price of oil and gas have certainly put a damper on a lot of drilling activity, there's still a significant amount going on. Look no further than Mansfield, where Edge is now applying for permit to build a new compressor and dozens of new wells on an old pad.
In 2011, nobody was building Liquified Natural Gas terminals up and down the Gulf Coast for an export market the way they are now. Analysts say those overseas markets could produce a "second boom" in drilling activity between now and 2018, but the TCEQ forecasts don't take that into account.
Gas production pollution numbers – emissions from compressors, dehydrators, storage tanks – are even more tenuous. Every gas industry textbook explains that as gas plays get older, the number of lift compressors increases in order to squeeze out more product. Increase the number of compressors and you increase the amount of compressor pollution. But TCEQ numbers fly in the face of that textbook wisdom and predict a decline in compressor pollution because wells in the Barnett Shale are getting older!
The best analogy for how TCEQ is estimating oil and gas pollution is its poor understanding of where those thousands of smaller compressor are and how much pollution they're actually producing. No staff member at TCEQ can tell you how many of those compressors there are in the region – they literally have no idea and no idea of how to count them in the real world. There are just too many, their locations are unknown, and they were never individually permitted.
Instead, the TCEQ takes production figures from the Railroad Commission and guesses how many of those small compressors there are, as well as their location, based on where the RRC tells it production is going on in the Shale. Then staff guesses again about the emissions being emitted by those compressors, because there's no data telling them what those emissions actually are. In the end you have a series of lowballed guestimates, stacked one atop the other, presented as fact. It's smoke and mirrors.
3. TCEQ Isn't Requiring Any New Controls on Any Major Sources of Air Pollution
Like its previous 2011 DFW air plan, which resulted in an increase in North Texas ozone levels, TCEQ's new plan requires no new controls on any major sources of air pollution, despite evidence showing that such controls in smog-forming emissions from the Midlothian cement plants, East Texas coal plants, and Barnett Shale gas facilities could cut ozone levels significantly.
Selective Catalytic Reduction (SCR) is already used extensively in the cement plant industry in Europe to reduce smog pollution by up to 90%. Over a half dozen different plants have used the technology since 2000. The TCEQ's own 2006 report on SCR concluded it was "commercially available." Holcim Cement has already announced it will install SCR in its Midlothian cement plant. Yet the TCEQ makes no mention of this in its plan.
That's right, a cement plant in Midlothian has decided SCR is commercially viable, but the State is looking the other way and pretending this development in its own backyard isn't even happening. TCEQ is stating in its proposed plan that SCR just isn't feasible!
In 2013, a UTA Department of Engineering study looked at what happened if you reduced Midlothian cement plant pollution by 90% between 6 am and 12 Noon on weekdays. Ozone levels went down in Denton by 2 parts per billion. That may not seem like a lot, but in smog terms it's the difference between the Denton air monitor violating the 75 ppb standard under the TCEQ plan and complying with the Clean Air Act.
In 2012 a UTA College of Nursing study found higher rates of childhood asthma in Tarrant County "in a linear configuration" with the plumes of pollution coming from the Midlothian cement plants. SCR means less pollution of all kinds: smog, dioxins and the particulate matter the Nursing College thought was causing those increased rates of childhood asthma. By delaying the requirement that all the Midlothian cement plants install SCR by 2018, the state is turning its back on a problem that Cook Children's hospital described as "an epidemic."
The same is true of SCR in the East Texas coal plants. The technology is being used in other coal plants around the world and in the US to reduce smog pollution. There's no reason it shouldn’t be required for the dirtiest coal plants in Texas that impact DFW air quality. After decades of being out of compliance with the Clean Air Act, DFW is one of the places the technology is needed most.
Last year the Dallas County Medical Society, led by Dr. Robert Haley, petitioned the TCEQ to either close those coal plants or install SCR on them. The doctors' petition was rejected by TCEQ Commissioners and they were told their concerns would be addressed in the DFW air plan. They aren't. Those concerns, along with the proof they presented about the impact of the plants on local air quality, are being ignored.
Electrification of gas compressors is a commonly used technology that could cut smog pollution as well, and yet the TCEQ is not requiring new performance standards that would force operators of hundreds of diesel and gas-powered compressors in North Texas to switch to electricity.
A 2012 Houston Advanced Research Center study found that pollution from a single compressor could raise local ozone levels by as much as 3 to 10 ppb as far away as ten miles. There are at least 647 large compressor stations in the western part of the DFW area. Dallas and other North Texas cities have written ordinances requiring only electric-powered compressors within their city limits based on testimony from industry that electrification was a commonly used technology in the industry. And yet, TCEQ's official position is that electrification isn't feasible.
In ignoring these types of new controls the TCEQ is violating provisions of the Clean Air Act to implement "all reasonably available control technologies and measures" to insure a speedy decrease in ozone levels. Each of these technologies is on the market, being used in their respective industries, and readily available. Studies have shown that each of these technologies could cut ozone levels in DFW significantly, but the TCEQ is refusing to implement them. In doing so, many observers believe it's blatantly in violation of the law.
We don't expect TCEQ to change its position. That well has been poisoned for the foreseeable future. But we do expect a higher standard of enforcement from the Obama Administration EPA. That's why we're asking you to show-up at the public hearing and oppose this dreadful state air plan a week from now in Arlington. We need to demonstrate to the federal government that citizens are concerned about getting cleaner air now, not in the next plan or the one after that. Now. We need to put pressure on the EPA to reject this TCEQ plan, to either send it back to the drawing board or substitute one of its own. Without you showing up, that pressure isn't there.
Between now and Thursday – and all the way through January 30th, you can send prepared comments opposing the TCEQ plan to Austin and the EPA Regional Administrator with a simple click here – and add your own comments as well.
As a reward for coming over and venting your frustration, we'd like you to stay and party with us at the official "retirement party" of State Representative Lon Burnam, beginning at 7:30 pm just four blocks down the street. It's a roasting and toasting of the best friend environmentalists ever had in the Texas Legislature, as well as a fundraiser for Downwinders to continue our work to defend your air. JUST CLICK HERE FOR TICKETS.
Next Thursday you can support clean air two ways in one evening. Help us beat back a terrible, horrible, no good, very bad air plan, and then come celebrate the wonderful, righteous, very good work of a dedicated public servant. See you there.
2014 DFW Smog Report: Good News But Don’t Hang Up the Gas Mask Yet
For the first time since DFW began recording its smog levels, the region's three-year running average dipped below the 1997 eight-hour 85 parts per billion (ppb) standard. After years of leveling off at around 86-87, it's dropped to 81 ppb. That's good news.
DFW's decrease is attributed to 2011's terrible numbers rolling off the board and a wetter, cooler and windier summer than normal these last five months or so. As both drought-ridden 2011 and this year's results demonstrate, weather still plays an extremely critical role in how large or small our smog problem will be. Another summer or two like 2011 could easily put us back over the 1997 standard. More wet and cooler weather could see the decrease continue.
The news would be better except that we were supposed to have originally accomplished this milestone in 2009, then again last year after a second try, according to the Texas Commission on Environmental Quality (TCEQ).
As it is, we still haven't reached the current, more protective 2008 national standard that was revised downward to 75 ppb after a review of the scientific literature.
In January, TCEQ will host a public hearing on its proposed "plan" to EPA to meet that goal that predicts most, but not all DFW monitors will reach 75 ppb by the summer of 2018.
Despite overwhelming evidence that new controls on the Midlothian cement plants and the reduction of gas industry pollution could speed this achievement, TCEQ's new plan contains no new pollution control measures on any major sources of smog polluters – cement kilns, coal plants, gas sources – but instead relies on the federal adoption of a new lower-sulfur gasoline mix for on-road vehicles. Like past proposals by Rick Perry's TCEQ, this one depends solely on the feds to get them into compliance. TCEQ isn't lifting a regulatory finger to help.
And its new plan once again aims high, not low. At last count, there were at least three Tarrant and Denton County monitors that TCEQ admitted would still be above the 75 ppb standard at the end of 2018. "Close enough" is the reply from Austin.
From a public health perspective, it's even worse. Why does the ozone standard keep routinely going down? Because new and better evidence keeps accumulating to show widespread health problems at levels of exposure to smog that were once considered "safe." About every five years, the EPA's scientific advisory committee must assess the evidence and decide if a new standard needs to be enforced to protect public health.
For most of the last ten years, the position of this independent panel of scientists is that the standard should be somewhere between 60 and 70 ppb. They were ignored in 2008. They were ignored in 2011. They once again came to this conclusion last May. What was the evidence that persuaded them? That the current 75 ppb standard for smog causes almost 20% of children in "non-attainment areas" to have asthma attacks, and leads to hundreds of thousands of deaths every year. Cutting the standard to 60 ppb reduces those deaths by 95%. Since the Clean Air Act states the EPA is duty bound to set a smog standard protective of human health, 60 ppb seems to be the threshold level that the current scientific literature says is actually safe for the majority of the population most vulnerable to the impact of bad air. By contrast, a smog level of 70 ppb only reduces those deaths by 50%. (Policy Assessment for the Review of the Ozone National Ambient Air Quality Standard, U.S. Environmental Protection Agency, Office of Air and Radiation, Office of Air Quality Planning and Standards, Health and Environmental Impacts Division, Ambient Standards Group, August 2014)
By December 1st, EPA Administrator Gina McCarthy must decide whether to officially recommend a standard in that 60-70 ppb range. It looks as though this time, the EPA might just endorse what the scientists are recommending, although it's unclear whether it'll be the upper or lower part of that range.
So even while the TCEQ is saying it's "close enough" to achieving the 75 ppb standard left over from George W's administration by 2018, the evidence is that level is too high to prevent large public health harms and must be lowered. A lot.
This is why it's so infuriating that the TCEQ is satisfied with getting only "close enough" to a 2008 standard that's about to become obsolete. Austin knows it could demand better air pollution control measures on the market right now that would accelerate the decrease in smog. It knows the pubic health would benefit from requiring such measures. But it's willing to condemn DFW children and others at risk for many more years for the sake of keeping its "business-friendly" reputation.
And while this year's slip below the 85 ppb standard is a sign of some progress, it remains true that DFW still has the worst air in Texas – a title we took from Houston years ago. Take a look at the chart summarizing the 2014 ozone season across Texas. Despite the nicer weather, DFW still had almost twice as many readings above 75 ppb as Houston and four above the 85 ppb standard. Houston had no readings above 85. In fact, San Antonio was the only other city to record a level so high – once.
DFW still has a smog problem and all it takes is another hot and dry summer to see it escalate. We need the help more controls on major sources could give us. We need Selective Catalytic Reduction on ALL the Midlothian cement and East Texas coal plants. We need electrification of gas compressors in the Barnett Shale. This should be the message to both the TCEQ and EPA during the public hearing in January.
DFW smog in 2014: we've met the Clinton era standard for now, on the way to trying to get "close enough" to the W Standard, and still very far from a new Obama standard. Don't hang up the gas mask yet.
After a 14-year Campaign, State-of-the-Art Pollution Control Finally Coming to Midlothian
(Midlothian) After a 14-year effort by local citizens, Holcim US Inc. is applying for a permit to the Texas Commission on Environmental Quality to install a Selective Catalytic Reduction (SCR) unit in their Midlothian facility. It's the first application for commercial use of SCR technology in any U.S. cement kiln.
DFW-based clean air group Downwinders at Risk has been advocating the use of SCR in the three Midlothian cement plants located just south of I-20 since 2000, when a German cement kiln first operated the technology successfully.
Together, the TXI, Ash Grove, and Holcim plants represent the largest concentration of cement manufacturing in the country and are a major contributor to DFW's historic smog problem.
"We need this pollution control technology in North Texas, and we're pleased to see Holcim's application," said Downwinders Director Jim Schermbeck. "But we wish residents could enjoy its results sooner than Holcim intends."
The SCR unit is planned for Holcim's idle Kiln #2 while a more common Regenerative Thermal Oxidizer will be built for its operating Kiln #1. Both technologies are being installed to meet new EPA emission standards for hydrocarbon pollution from cement plants. Those standards themselves were championed by Downwinders and other citizen groups in 2009, with over 200 people showing up at an EPA hearing the the DFW Airport Hotel to support them.
The deadline for compliance with the new standards is September 2016. However, restarting of Kiln #2, and the introduction of SCR in Midlothian, is dependent on local demand for Holcim's cement, which is still recovering from weak demand during the recession. That lack of demand could delay the technology's inauguration until after 2016.
Nevertheless, according to Schermbeck, Holcim's application for a permit to install SCR makes it's more likely that all of the Midlothian cement plants, and others in EPA "non-attainment areas" for smog pollution around the country, will be adopting it sooner rather than later.
"Holcim's application sets a precedent that's hard to ignore by regulators in Austin and Washington. For the first time a US cement plant has expressed enough confidence in SCR to make it a technically and economically-viable choice for pollution control. There's no going back."
SCR is widely considered to be the most advanced form of pollution control for cement manufacturing, capable of reducing smog-forming pollution by 90% or more, along with significant reductions in Particulate Matter, metals, and Dioxins.
Although about half a dozen European cement kilns are successfully operating the technology, U.S. plants have refused to endorse it. Two EPA-sponsored pilot tests of SCR are being conducted at Indiana and Illinois cement kilns as part of court-ordered settlements. Holcim's application for its Midlothian kiln is the first time and American cement plant is voluntarily approving SCR use.
Although it's not coming in time to impact the current DFW clean air plan, due to go to public hearing in January of next year, Holcim's application will put SCR on the agenda for the next such plan.
Just two weeks ago, EPA staff recommended a new ozone, or smog, standard of between 60 and 70 parts per billion over an eight hour period versus the current limit of 75 ppb. Adoption of a stricter standard is expected to occur by late next year, meaning a plan to meet that standard will be gearing up sometime in the next three to five years. By that time, Holcim's SCR unit should have a track record that can be cited as a reason for all the Midlothian cement plants to use it.
Schermbeck noted that just last month representatives of the TCEQ told a regional air quality meeting in Arlington that SCR was neither an economical nor technically feasible pollution control option for the Midlothian cement plants. He said Holcim's application belies that claim.
A public meeting on the Holcim permit application is being scheduled for early November.
Arrival of SCR on the scene marks the latest and the most dramatic milestone in the transformation of the local cement industry since Downwinders at Risk was founded 20 years ago to stop the burning of hazardous wastes in the Midlothian kilns.
After a 14-year battle, TXI halted its hazardous waste-burning operations in 2008. Downwinders then pursued a six-year "green cement" campaign to replace all seven obsolete and dirtier wet kilns with newer "dry kiln" technology. That campaign ended in 2012 with the announcement that Ash Grove would shutter its three wet kilns and build a new dry kiln in their place. That plant is due to go on line this year.
Adoption of SCR remained a goal of the group through four different DFW clean air plans going all the way back to 2000. Schermbeck said his group made incremental progress each time, winning small and large battles that directly lead to today's news.
"Holcim's application for SCR is the latest testament to the persistence and focus of a small group of committed citizens who have pulled and pushed the U.S. cement industry into the 21st Century one step at a time."
TCEQ: Link Between Fracking and Air Quality, No Cement Controls Just “Because”: Highlights From Tuesday’s Air Meeting
Dallas Resident Liz Alexander showed up at the Council of Governments meeting room on Tuesday to lend her support to the effort to get more out of an anemic state ant-smog plan than the state wants to give. She was a warm body whose presence would be its own statement of concern. She was being a good trooper by just showing up.
At first she sat far from the action amidst the rows of seats for bystanders and, despite encouragement, was resigned to just listening, because as she explained, "she didn't know enough to ask questions."
Then someone urged her to move up to the rectangle of tables where the presenters stand and deliver, where there are microphones to raise the volume of concerns and questions that might be posed by mind-numbing reassurances that everything is going hunky-dory. As more of these air quality meetings have occurred, citizens have been less and less shy about taking up these front row seats that look more official than the rest; look like they should be reserved for guys in suits. Increasingly they're occupied by people in street clothes.
And then, after much information had been paraded in front of Liz, she did something she did not think she was qualified to do only about 90 minutes earlier. She asked a question. It was about what assumptions had been included in the information about unspent air pollution clean-up dollars that are piling up in Austin. She got an answer from a local COG staff person in real time that satisfied her. In the space of one meeting she moved from spectator to participant.
And she wasn't the only one. More than any other meeting so far, this one involved more citizens asking more questions about more subjects – and it revealed just how thin the state's rationale is for doing nothing.
As predicted, it was a day for the Texas Commission on Environmental Quality to explain why its new DFW anti-smog plan was really going to work this time – unlike the five previous failures – and why it wasn't going to be considering any new controls on the Midlothian cement plants or on gas compressors – a refutation of the case Downwinders at Risk had made in its June 16th presentation.
But here's what really happened: For the first time in these proceedings the state admitted that oil and gas emissions have a big influence on regional air quality. And when a former County Judge asked an TCEQ's Air Quality Manager specifically why anti-smog controls already being used on cement kilns in Europe were not being considered for the Midlothian kilns, the staffer couldn't say, offering up only the longest, most pregnant pause by any state staffer in the history of these meetings.
After being heavily criticized for months for leaving at least four monitors above the 75 ppb federal smog standard even after its plan had ended in 2018, the state came back to this meeting saying they only had three sites above 75 ppb now, and by margins that didn't exceed the standard by more than 1 part per billion. Between June and August, there had been a remarkable drop in future estimated smog levels at the area's monitoring sties in the state's computer modeling – particularly at the historically most stubborn monitoring sites in Denton and Northwest Tarrant County.
What had caused this drop? A relatively modest decrease in Nitrogen Oxide pollution of around seven tons a day and a decrease in Volatile Organic Compounds of about 15 tons per day. That's not a lot of pollution to produce such a large decrease in monitor readings in the computer model.
A more important question is: where did the decreases in air pollution come from that could produce such dramatic results in the modeling? The answer: primarily from oil and gas industry sources. Based on TCEQ's own formula relying on the declining number of new wells being drilled in the Barnett Shale.
For the moment forget the methodological qualms you might have about that declining well assumption. Instead, appreciate the fact that the same state agency that couldn't bring itself to ever say the Barnett Shale was producing air pollution holding DFW back from meeting Clean Air Act smog standards now says that it's decreases in that very kind of pollution that are having such a substantial effect on the monitors in the western part of the Metromess that have been the most resistant to other control strategies. TCEQ has just proven a causal link its been denying for over seven years now.
It can't be just a one-way street. If declining oil and gas air pollution equals better air quality in the TCEQ's computer model, so increases in oil and gas pollution must lead to worse air quality.
There are all kinds of reasons to doubt that the drop in total oil and gas air pollution will happen at all or drop as fast or as sharply as the TCEQ predicts. Afterall, they're 0 for 5 in such matters. They may be underestimating the amount of total air pollution from all gas and oil sources and so the drop will not be as sharp. They may be underestimating the impact of lots of new lift compressors that will be showing up to squeeze the last bits of gas from older wells even as new wells are not drilled as often. But as of Tuesday the link has been made by TCEQ itself that such a drop results in big decreases in smog levels in Denton and Northwest Tarrant County. That's something that citizens can use to argue as proof of the impact of oil and gas facilities on local air quality.
Of course, it only took the span of about 30 minutes for the TCEQ to internally contradict itself about those results.
According to TCEQ computer modelers, natural gas Compressor Stations large enough to be considered "point sources" just like cement kilns or power plants will be responsible for over 17 tons of Nitrogen Oxides, and 26 tons of VOCs a day in 2018 – well over the amount of oil and gas pollution decreases that resulted in those lower monitoring numbers in Denton and NW Tarrant County. But according to the TCEQ staff responsible for suggesting new controls in the new smog plan, those numbers are not large enough to have an impact on improving DFW air quality or warranting a policy of electrification for those compressors that could reduce their air pollution to a fraction of those volumes.
So while 7 tons of NOx reduction from Oil and Gas sources is large enough to bring some of the most stubborn monitors down a whole part per billion, reducing air pollution from Oil and Gas sources by another 17 tons of NOx reduction would have no effect on DFW air quality at all and it's just not worth it to make them electrify compressors. Honest, that was the logic in play on Monday, and it didn't hold up very well under questions from people like Liz Alexander.
And that was all before you got to why the Midlothian cement kilns could not, no way, no how, possibly, under any circumstance, be required to install Selective Catalytic Reduction controls, just like their European counterparts have done over the last 15 years.
Turns out, it's just because.
Oh, the TCEQ staffer cited four criteria for any new control measure to meet before it could be considered. Let's see, there was "technological feasibility." Since there are at least seven full-scale SCR units up and running in Europe, that couldn't be a problem. It's accepted technology by some of the same companies operating kilns in the US – including LaFarge-Holcim.
There was "economic feasibility." And since there are all those SCR examples already in the European market and no company has gone bankrupt running them, that's also off the table. Plus the fact that the TCEQ's own 2005 study of SCR concluded it was "available technology" then that would only cost $1000 to $3,000 per ton of NOx removed – versus the up to $15,000 per ton of NOx removed ratio allowed in the state's own official diesel engine replacement program. Coming in at one-fifth the cost of what the state already said was economically feasible, it certainly ruled out that one.
There was the third criterion – that controls couldn't cause ‘‘substantial widespread and long-term adverse impacts.’’ The state said that wasn't the reason they couldn't be considered either, although the TCEQ staffers seemed to hedge a bit here, seemingly wanting to say that, really, they didn't want to cause themselves adverse impact by admitting that they had been wrong for over a decade about this stuff.
The proposed control cannot be ‘‘absurd, unenforceable, or impracticable.’’ Clearly, if the Europeans are doing it on their kilns, it's none of those either. It's quantifiable, and up and running in power plants, cement kilns and incinerators.
And it has to speed the attainment deadline by a year. No problem. SCR could do that if it was installed in a timely fashion.
So at the end of the state's presentation, former Dallas County Judge Margaret Keliher asked the TCEQ staffer exactly why SCR wasn't considered a possible pollution control measure since none of these criteria that had been presented seem to rule it out. And the TCEQ's staffer's response was…………………………………………………………………………………………………………………………………………………………………….
No, really, that was the response. She couldn't say. It was that embarrassing. Because the rejection of SCR by TCEQ isn't based on any of those criteria. It's based on a political decision that's been made that no new pollution controls will be sought on the kilns or any other major industrial polluter as long as Rick Perry is running for President. Or "just because."
How ridiculous is this? At this point the TCEQ is taking an even more regressive view of SCR controls than the cement industry itself. In June, Holcim Cement's Midlothian plant requested a permit from the state that would allow it to build either a Thermal Oxidizer or an SCR until for the control of VOC pollution. Being the free market fanatics the Perry Administration claims to be, doesn't the fact that one of the Midlothian cement plants is asking for a permit that includes the possibility of installing SCR mean it's automatically technologically and economically feasible? The market is never wrong, right? Are the folks at Holcim so enamored of kinky, off-the-wall green technology that they'll just include it in a permit for laughs? These guys are Swiss engineers. They have no sense of humor.
Denial of SCR as a viable control measure that could reduce smog pollution is making the TCEQ contort into sillier and sillier positions. It's making them deny the conclusions of their own almost-decade old report that said it was available to put in a kiln in 2005. It's making them deny the fact that SCR is up and running at over half a dozen kilns in Europe. It's forcing them to once again use the "Midlothian limestone is magically special" defense that has been used to forestall any progress in pollution control there over the last 25 years. The arguments used against SCR are exactly the same as were used against the adoption of less effective SNCR technology before it was mandated. In case you hadn't noticed, they're still making cement in Midlothian despite the burden of having to nominally control their air pollution.
The state wants to power through this anti-smog plan just like they did the last one in 2011. They don't want to have to make industry do anything. But at this point the denial of SCR as a control measure to be included in the next DFW anti-smog plan is so absurd, as is the justification for electrification of gas compressors, that it might be fodder in the next citizens lawsuit over a DFW anti-smog plan, which usually follows these things like mushrooms after a rainstorm.
Want to get involved in this fight and make it more difficult for the state to get away with doing nothing at all about DFW smog – again? Please consider attending our next DFW Clean Air Network meeting – THIS SUNDAY, AUGUST 17th, from 3:30 pm to 5:30 pm at the offices of the Texas Campaign for the Environment across from Lee Park in Dallas, 3303 Lee Pkwy, Suite #402 (214) 599-7840. Citizens are the only force that can make this plan better. Be there, or breathe bad air.
Ask the State and Holcim To Finally Give DFW “the Holy Grail” of Cement Pollution Control Technology
Swiss-based Holcim Cement is requesting a permit amendment to add new piece of pollution control equipment to its Midlothian cement plant, one of three cement plants that make the city the "Cement Capitol of Texas" and the largest concentration of cement manufacturing in the U.S. Good news, right? The problem is that the company is asking the state for the permit before deciding what kind of pollution control equipment to install.
That's right. Holcim is asking the Texas Commission on Environmental Quality (TCEQ) to OK a permit that will result in a "major modification" of its Midlothian plant and could produce significant amounts of new pollution before it even decides what the major modification is going to be. Anywhere else in the country this might be a bit odd, but hey, it's Texas, where Rick Perry's TCEQ has a rubber stamp standing by for anything industry requests.
Holcim's permit request is being prompted by a problem complying with new federal regulations limiting a kind of pollution called Total Hydrocarbons, or THCs. These are also sometimes referred to as "Volatile Organic Compounds." Think Benzene, and other kinds of hazardous flammable gases. In its permit application Holcim says it needs to add new controls to reduce THC to levels and come under the new federal standard. Fair enough. The company then says that it's still trying to decide between two different types of controls and will make up its mind after getting the permit and seeing how well its choice works out on one of its two separate giant kilns. That's the bogus part.
But wait, there's more! The two technologies Holcim is considering installing in Midlothian are: 1) A Regenerative Thermal Oxidizer, or RTO, which is a fancy way of saying setting them on fire and flaring them off, and, 2) A Selective Catalytic Reduction unit, or SCR, which is a tower of treated metal honeycombs that pick up pollution as the plant exhaust passes through them. RTOs are already installed on American cement plants, including TXI's huge Midlothian kiln just a few miles down Highway 67 from Holcim. On the other hand, up to now full-scale commercial SCR units have only been installed on European cement plants and in fact, the Portland Cement Association has lobbied long and hard to keep them out of the US for fear of raising the pollution control bar too high for all of the country's cement plants.
That's because SCR is more expensive to build and maintain than most cement plant control devices. But for the money, you get the Holy Grail of cement plant pollution control technology.
Most of the European cement plants that have SCR units install them to remove another type of pollution from their stacks – Nitrogen Oxides (NOx). If that sounds familiar, it's because NOx is a major smog-forming pollutant, and DFW has so much of it that the region has never been in compliance with the Clean Air Act standard for smog. And you'll never guess which facilities are the single largest sources of NOx pollution in North Texas. Or maybe you will: the Midlothian cement plants. That's why Downwinders at Risk has made it a point to campaign to require all three Midlothian cement plants – Holcim, TXI and Ash Grove – to install SCR….since all the way back in 2001, when the first European units were deemed a success at a German cement plant. SCR can remove 80 to more than 90% of all NOx coming out of a cement kiln. The 6500 tons of NOx a year that the Midlothian cement plants are permitted to release could be reduced to 650 tons with the application of SCR.
Now, as it turns out, SCR units are great not only at capturing large amounts of NOx pollution, but all kinds of other industrial pollution coming out of cement plants as well. Like THCs – up to 70% or so, but also Particulate Matter, Metals, Greenhouse Gases, Carbon Monoxide, and Dioxins. It's what's called a multi-pollutant control device because it does such a good job of eliminating a wide variety of nasty stuff from smoke stacks. This is what makes it the state-of-the-art technology for communities hosting kilns. In contrast, RTOs are single-purpose pollution devices aimed just at hydrocarbon removal and aren't designed to remove other kinds of emissions.
So even though Holcim is considering operating SCR because of its hydrocarbon problem, it would have a massive impact on the plant's air pollution across the board. And if Holcim were to set the precedent, the clock would begin ticking on bringing SCR to the other two Midlothian cement plants as well. It would only be a matter of time.
The public comment period for telling the state whether to accept or reject Holcim's permit application ends this Friday, July 11th at 5 pm. (If you're interested in jumping through the hoops to fill out the online form for official comments, you can go here and use Permit Number 8996)
Downwinders is submitting detailed comments praising Holcim for considering SCR, but urging the TCEQ to reject this permit because it's too vague and doesn't commit the company to any partciular technology, including SCR. We've also been collecting letters form local officials and stare legislators that urge Holcim to definitively choose SCR.
Now we're asking you to help us bombard both the Texas Commission on Environmental Quality and Holcim's US headquarters in Dundee Michigan in the next 48 hours with the same message to show public support for the company to do the right thing while rejecting a placeholder permit that doesn't commit it to do that right thing.
We want a permit request from the company that says Holcim will definitely install SCR, becoming the first commercial application of this state-of-the-art technology in America.
Using our "Featured Citizen Action" link, you can send such a message to Austin and Michigan in a matter of seconds right now. All you have to do is click here and then send the e-mails. We guarantee there's no more important or easier thing you can do for clean air in North Texas this week than sending these e-mails to the TCEQ Commisisoners and Holcim Corporate leadership. Please help us get the cement plant pollution control technology DFW deserves. It will only take a matter of seconds for you to help us achieve a goal we've been working toward for 14 years. We can do this. But we need your help. Now. Thanks.
Rick Perry, with a Smoking Gun, in the COG Headquarters: Monday at 10 am
The latest chapter in a decades old mystery game of "Get a Clue" happens tomorrow morning, Monday, June 16th when representatives of the Sierra Club and Downwinders at Risk present their case against the current state anti-smog plan during the regional air planning meeting at the headquarters of the North Texas Council of Governments, 616 Six Flags Road in Arlington. Come find out who and/or what keeps the DFW area from ever meeting federal clean air standards year after year and what can be done about it. The meeting starts at 10 am. Citizen groups are expected to do their presentations in the 11 to 12 hour. Then we'll all have a debriefing lunch at the Subway's down the street hosted by State Representative Lon Burnam. Y'all come.
Thank You. Citizens Might Have Just Saved The Local Air Planning Process…From Itself
A year from now, last Thursday' meeting in Arlington may be seen as a turning point.
Local residents refused to let the air quality planning process die, showing up in numbers that forced officials to switch to a larger room, and making sure their opposition to another state "do-nothing" air plan was heard loud and clear.
Their participation had already changed the day's agenda. Included was a breakthrough UNT study that directly challenges the Texas Commission on Environmental Quality's claim that natural gas emissions don't increase DFW smog.
UNT's Dr. Kuruvilla John's presentation of the new study received quite a bit of media coverage, before, during, and after Thursday's meeting. You can find some of the best coverage by clicking on the links below.
UT-Austin Study Reveals "Underestimates"
Dr. John's presentation influenced another researcher's slide show as well. Scheduled to speak about older, more generic ambient air measurements for ozone, Dr. David Allen of UT Austin instead presented more recent research into gas pollution as well.
Overlooked in the debut of the UNT study, Allen's constant monitoring of one drill site in Fort Worth revealed that the TCEQ was underestimating emissions from the pneumatic valves at the site by 159%.
That was news to both citizens and TCEQ, who said they hadn't looked at Allen's research and hadn't corrected their inventories to account for such underestimates. Valves like these are powered by natural gas, are quite numerous on gas equipment, and account for a large percentage of VOCs released from a fracking site.
A Better Picture of Oil and Gas Pollution
Citizen cross-examination of TCEQ staff members present at the meeting also revealed a different look at the volume of Oil and Gas industry pollution in the 10-county DFW "non-attainment area"
Up to Thursday, TCEQ was dispersing Oil and Gas pollution across several categories, making it impossible to show the true total impacts.
Here's an example of the way TCEQ likes to present the info:
SOURCES OF SMOG-FORMING NITROGEN OXIDE POLLUTION (NOx)
IN DFW's NON-ATTAINMENT AREA
1. "On Road" vehicles 113.21 tons per day
2. "Non-Road" vehicles" 39.87 tpd
3. "Area" 30.76 tpd
4. "Other Point Sources" 24.95 tpd
5. "Locomotives" 18.90 tpd
6. "Cement Kilns" 17.60 tpd
7. "Electric Utilities" 15.02 tpd
8. Oil and Gas Production 12.21 tpd
9."Airports" 11.77 tpd
10. Oil and Gas Drill Rigs 5.83 tpd
TOTAL 290.12 tpd
This makes it look like Oil and Gas pollution is not that big a deal.
But it turns out TCEQ is hiding 28.44 tpd of NOx gas compressor pollution in the "Area" and "Other Point Source" categories.
This was brought out in questioning on Thursday. Once you add these figures to the other Oil and Gas emission numbers spread out over different categories, this is what you get:
SOURCES OF SMOG-FORMING NITROGEN OXIDE POLLUTION (NOx)
IN DFW's NON-ATTAINMENT AREA
1. "On Road" vehicles 113.21 tpd
2. Oil and Gas Industry 46.48 tpd
3. "Non-Road" vehicles 39.87 tpd
4. "Locomotives" 18.90 tpd
5. "Cement Kilns" 17.60 tpd
6. "Area" 15.93 tpd
7. "Electric Utilities" 15.02 tpd
8. "Other Point Sources" 11.34 tpd
9. "Airports" 11.77 tpd
TOTAL 290.12
(Earlier today we put out an e-mail alert that left 10 tons off the "Area" category in this second chart, greatly affecting its ranking. That mistake is corrected in this version of the chart and we apologize for any confusion that might have caused)
When you quit playing the state's shell game with Shale pollution, the Oil and Gas industry becomes the region's second largest source of NOx pollution – the kind of pollution TCEQ says is the main driver of smog in DFW (not even counting all the pollution from O&G fracking trucks still hiding in the "On Road" category).
There have been control measures for cars to reduce NOx. There have been controls on heavy duty equipment and trucks to reduce NOx. There have been new controls on locomotives to reduce NOx pollution. There have been controls on airport ground equipment to reduce NOx pollution. There's even been middling controls to reduce the NOx from the Midlothian cement kilns. But where's the controls to reduce NOx from the Oil and Gas industry – the one source in this list that hasn't had the same kind of regulatory attention? Good question – save it for next time.
Citizen Participation is Crucial
This is the kind of close examination the TCEQ hopes to avoid by limiting debate on this new clean air plan, scheduled to be submitted to EPA by July next year. And it's exactly why citizens need to keep showing up.
Because of the momentum and interest coming out of Thursday's meeting, citizens also got the next scheduled pow-wow of the local air planning process moved up to late May or early June instead of waiting until July.
We're already taking suggestions for what you want to see on that agenda, so don't be shy. And thank you again for restoring some tiny amounts of integrity into a process that's been swamped by Rick Perry's indifference.
You're making a difference, and that's all anybody can do. This last Thursday it was a big difference. Let's try to do the same in May.
Some Coverage of Thursday's Air Planning Mtg.
Channel 8: "UNT researchers say fracking a contributor to North Texas smog problem"
Texas Observer: "Studies: Links Between Fracking and Smog Pollution Stronger Than State Claims"
Star-Telegram: "Natural Gas Production Contributing to Higher Ozone Levels, study Finds"
Denton Record Chronicle: "Officials: No New Plans to Clean Up Air"
HOW YOU CAN SAY "THANK YOU" BACK
Here's what Downwinders at Risk did this past week to make sure Thursday's air quality meeting wasa success:
1) Pressed for and got the UNT study linking fracking to smog on the meeting agenda after being told it would not be included.
2) Sent out releases to the media advertising the UNT presentation.
3) Sent out alerts to you and others to let you know about the new UNT study and the meeting itself.
4) Sent out a "Citizens' Guide to the Meeting" so you could be prepared for Thursday.
5) Showed-up at Thursday's meeting with handouts showing the lack of air quality progress in DFW and the lack of a complete plan by TCEQ
6) Used our questions to reveal how TCEQ was hiding Oil and Gas industry pollution totals in their data
7) Pressed for and got an earlier "next meeting" of the local air quality planning group
8) Sent out this follow-up so that everyone knows what went on and what the news is from the meeting
A local forum for clean air issues was about to disappear.
Only the last month's mobilization of citizens prevented that from happening on Thursday.
Who began that mobilization?
We did.
We really need your financial help to keep doing this. We don't get state or national funding – just local money from people like yourself.
Thanks. We very much appreciate it.
Another Chapter of “Why Don’t We See This in Midlothian?”
Cement plants are among the world's largest sources of CO2. In order to reduce their carbon footprints, either voluntarily or to comply with new environmental regulations, as well as make a buck, owners are trying out different strategies to turn their Greenhouse Gases into just plain green cash.
As far as we can tell, the "SkyMine" pilot-project announced for San Antonio's Capital Aggregates Cement Plant is still on schedule for operation later this year. Employing 50 people, the first-of-its-kind facility will convert the cement plant's carbon dioxide into baking soda and hydrochloric acid that's aimed at oil and gas field use.
Now comes word that a LaFarge Cement Plant in Canada is hooking up with a fuel cell company to make a slightly more progressive product from its GHGs:
"Mantra Energy Alternatives has struck a deal with Lafarge Canada to deploy an electrochemical reduction technology at Lafarge’s No. 9 Road cement plant.
“This will be the first pilot plant of its kind in the world,” said Mantra’s vice-president Patrick Dodd in a press release.
On paper, the technology would convert carbon dioxide, considered the most prolific greenhouse gas, into useful chemicals like formic acid and formate salts. The pilot plant would convert 100 kilograms per day of carbon dioxide emitted from the local cement plant into concentrated formate salts, which sell for about $1,500 per tonne.
Mantra is eying the formic acid for use in its patented fuel cells, which it bills as a significantly less expensive fuel cell with greater power density."
Granted, the manufacturing of oil and gas chemicals sounds more likely for one of the three huge Midlothian cement plants to attempt than diving into the alternative energy business, but at least it's something. The end products can change and adapt but these projects begin to put the infrastructure of a supply and demand system in place while seeing potentially large decreases in CO2 output. In 2014 America, the fastest way to get reductions in GHGs is to make it profitable to do so. These experiments pave the way for that to happen.
There's no question that the TX/ Martin-Marietta, Holcim and Ash Grove cement plants are the largest stationary sources of CO2 in North Texas, or that together, they form a huge GHG hotspot. All the old coal-fired power plants that would have challenged them have been shuddered or converted to gas.
While (forced) modernization at all three plants like the conversion from wet to dry kiln technology has brought all emission totals down, particularly CO2, the fact remains that the huge scale of operations in Midlothian means there's no other facilities that churn it out as much. And yet not one creative idea for how to reduce those huge local emissions has been announced from any of those companies. You can't just use the Texas excuse because the San Antonio experiment is happening despite no immediate government mandate, especially on existing facilities. And you might think that the first company to do so would receive some needed good PR. But nope.
This has been another chapter of "Why Don't We See This in Midlothian?"
Between Now and Friday: Tell Them What They Can Do With Their Smog
Frustrated that Rick Perry's Texas Commission on Environmental Quality isn't doing enough to end DFW's chronic smog problem, the local "Council Of Governments" has issued a "Request for Information" asking for the public's help in suggesting ways to reduce ozone pollution in North Texas.
Please use our Click N' Send E-mail form to make sure they get the message that the public wants:
1) State-of-the-Art pollution controls on huge "point sources" of pollution like the Midlothian cement kilns and East Texas power plants.
2) New pollution control equipment and strategies to reduce the air pollution from the thousands of natural gas facilities mining the Barnett Shale.
3) Inclusion of all trucks and off-road vehicles in the state's vehicle maintenance and inspection program.
You can also add strategies or ideas of your own as well. Just click here, fill out the e-mail and send it in to be counted.
It takes as little as 30 seconds.
BUT YOU ONLY HAVE UNTIL 5 pm FRIDAY, VALENTINE'S DAY.
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Rick Perry's TCEQ is so discredited on the matter of DFW smog, local officials usually working in concert with the state agency are now looking elsewhere for help.
Ever since DFW was required to write and submit new clean air plans, The North Central Texas Council of Governments has been the local vehicle used by the state to funnel information, concern, and ideas back and forth.
It was never easy to get Austin's attention or convince the Powers That Be of the need to take bigger clean air measures. It took a decade for Downwinders to get the State to admit that the Midlothian cement plants had a huge impact on local air quality before they were the targets of new controls.
But ever since Rick Perry began running for President in 2010, it's been impossible for Austin toget serious about any DFW clean air plan. For the past four years, TCEQ has claimed that it can reduce air pollution enough by doing nothing.
That strategy has been a dismal failure. New car buying in the middle of the worst economic downturn since the 1930's was the TCEQ clean air plan in 2011. Austin promised that if we just sat back, we'd have the lowest smog levels ever recorded. Instead we had worse air pollution levels than we did five years ago.
This time round, TCEQ is saying a new EPA-mandated low-sulfur gasoline mix in 2017 will be the region's savior for the new clean air plan that's supposed to be successful in reaching the new federal ozone standard of 75 parts per billion in 2018. We're at 87 ppm now – still in violation of the old 1997 standard.
Just watch this new fuel being added to cars and see the ozone numbers drop, TCEQ is saying. No need to put controls on gas facilities, or cement kilns, or power plants. Nothing that would give Rick Perry's opponents on the Right any opportunity to claim he was "anti-bidness."
Even the Council of Governments isn't buying it.
That's why, in their own bureaucratic fashion, this Request for Information that the COG has issued is it's own middle-of-the-road middle finger to TCEQ.
Usually, it would be the state facilitating a discussion of new air pollution control strategies, but since it's obviously not interested, the COG has decided to go its own way. That's how bad things have gotten in Austin – even their most reliable allies in DFW can no longer take them seriously.
It's not clear what will happen to the list of control measures that the Council of Governments is assembling. Some might receive some more official attention, but locals have no authority to write or override Austin's decisions. TCEQ is the only entity that's authorized to submit a new clean air plan to EPA by the June 2015 deadline.
But there are ways to use the useless clean air plans that Austin is submitting. Downwinders' own green cement campaign is a great example.
In 2007, we successfully inserted a voluntary air pollution control strategy into the TCEQ plan revolving around the purchasing of cement from newer cleaner "dry" kilns by local North Texas governments. We then took that "green cement" procurement option and went to Dallas to pass the nation's first green cement ordinance. Then Fort Worth passed it. Then Plano. Then Arlington. Then Denton. Then Dallas County. Then Tarrant County.
Within two years, we had established a de facto moratorium on dirtier "wet kiln" cement within at least a dozen municipal and counties. Combined with federal rule changes, we were able to get all Midlothian wet kilns closed. The last one is being be converted to a dry kiln this year. All while Rick Perry was governor.
The same thing could happen with a good "off-sets" policy for gas facilities if a local city of county could pass a template ordinance showing the way. Currently, most of the gas industry is exempt from being required to "off-set" their air pollution in smoggy "non-attainment" areas like other large industries in DFW. Take away this exemption and you'll see a swift decrease in gas industry air pollution.
It's these kinds of strategies that don't depend on action from Austin that offer the greatest potential for progress this time around.
TCEQ has never written a successful clean air plan for North Texas, and it's not going to start now. But citizens themselves can take their lungs' fate into their own hands and begin to build a system of local measures that can make breathing easier.
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CALENDAR AND STATUS REPORT OF DFW'S NEWEST CLEAN AIR PLAN
Reach a 3-year rolling average of no more than 75 ppm of ozone at all 18 DFW area air monitors.