TCEQ
DFW Smog Gets Worse for First Time Since 2015. Government: ¯\_(ツ)_/¯
2019’s “ozone season” came in like a lamb but is headed out as big, wheezy lion.
A three-day stretch from Thursday September 5th to Saturday the 7th that combined triple digit temperatures with lots of air pollution was enough to push Dallas-Fort Worth smog numbers for the year over 2018’s annual average. It was the first year-to-year increase in ozone levels since 2015, and more than enough to insure DFW will be in violation of the Clean Air Act for the 28th year in a row.
Because the formula for arriving at these averages is so convoluted, discounts the highest three numbers, and is stretched out over 8-hour periods, it takes a lot ozone to make them go up even incrementally. Raising the annual average by even one part per billion (ppb), from 76 to 77, as occurred by Saturday evening, hides a lot of Really Bad Air. Smog levels were in the 90’s and even close to 100 parts per billion at monitoring sites in the northern part of the Metromess. EPA’s national standard for 8-hour exposure to ozone is a 70 ppb average.
Three sites saw their 2019 highs set during this 72 hour period. Frisco had an eight hour average of 88ppb on Saturday, Keller 84 ppb and North Dallas 83ppb. There were four hours on the afternoon of the 6th when smog was over 90 ppb in Frisco.
That’s reminiscent of the bad ‘ol days from the Turn of the Century when levels in the upper 90’s and even topping 100 ppb were routine. Since 2000, there’s been a more or less steady fall in smog in DFW thanks to better controls on combustion-powered vehicles, and the citizen-induced decreases in pollution from Midlothian cement plants and the retiring of East Texas coal-fired power plants. In 2000 DFW’s annual ozone average was 102 ppb. It’s taken 20 years to lower that number to the high-to-mid 70’s. For the last three years we’ve seen decreases of 3, 1 and 3 ppb. 2019 halts that downward trend.
Beside the human health toll these numbers represent – an increase in asthma attacks, ER visits, strokes and heart attacks. – they also represent a challenge to government. This increase comes as the usual planning process to reduce dirty air in DFW sits in tatters. In fact, there really is no process anymore.
In the past, the North Central Texas Council of Governments (NTCOG) would bring the Chambers of Commerce, elected officials and some environmentalists together to cobble out a list of proposed strategies to reduce smog, then submit it to the Texas Commission on Environmental Quality in Austin where it would get watered down by corporate lobbying. Nevertheless, those past plans did have an influence on tightening emissions for ancient cement kilns and other industrial sources and they can take some credit for the two-decade decrease in smog.
But that process hasn’t taken place since even before the current administration took office. The last plan submitted by the region to the state was in 2013. Because Austin kept ignoring most of the region’s recommendations, NTCOG just gave up trying after that. It’s Clean Air Steering Committee was disbanded and hasn’t met for six years now. Despite approaching our fourth decade of illegally bad air there’s no official body in DFW working on a regional clean air plan. Everything is being run by Greg Abbott’s state agency – one that doesn’t believe there’s a climate crisis, wants to increase permissible exposure for dangerous pollutants, and whose former Toxicologist in now leading the Trump administration’s efforts to roll back federal pollution standards.
It’s doubtful a single part per billion rise in the regional average will prompt reconsideration of this laissez-faire approach. But it should.
Before the 2016 election, Downwinders was trying to pave a path for the federal government to take away the power of Austin to determine DFW’s clean air progress. We had hoped to have EPA delegated as the “final cut” author of a new clean air plan. Trump’s election made that impossible. But should this administration be gone by 2021, that strategy is still one local residents would be wise to pursue. As long as the State’s environmental agency is in the hands of anti-science flunkies and fanatics, there will be no concern about DFW smog in Austin.
Texas Misusing 17-Year Old Rural Air Pollution Model to Permit Inner-City Joppa Asphalt Plant
One of these is not like the other
What if you found out an industrial polluter was operating in your densely-populated neighborhood and the state told you not to worry because an obsolete computer model of the polluter’s releases 17 years ago and 500 miles away, in a desert, performed by the polluter themselves, said everything was OK?
That’s exactly the situation Joppa residents find themselves in as the Texas Commission on Environmental Quality (TCEQ) goes through the motions of renewing one of the permits of the many industrial polluters located in the community.
Austin Industries’ asphalt batch plant sits next to the Marietta Martin (TXI) concrete batch plant in Joppa, and both are in the Union Pacific switch yard and all of those are adjacent to the giant Tamko asphalt roofing factory.
Austin has applied to the TCEQ for a renewal of its 10-year old air permit for its Joppa plant and gave notice last December. Legal Aid of NorthWest Texas requested a contested case hearing on behalf of the Joppa Freedman’s Town Association and Downwinders at Risk requested one on behalf of resident Jabrille McDuffie.
To absolutely no one’s surprise, TCEQ’s Executive Director recommended against such a hearing at the beginning of August in comments mailed out to all parities. He argued that contrary to the opponent’s claims there was sufficient evidence that Austin Industries permit in Joppa was following the law and was “protective of human health.” Previous “air quality analysis,” the Executive Director says, have concluded such already.
The entire basis of that “air quality analysis” is the computer air modeling performed by Austin Industries’ hired contractors and supposedly double-checked by the state…in 2002.
Just like any other computer model, it all depends on the variables: volume of air pollution, local meteorology, stack height, local “receptors” aka people or animals who live by or near the facility, and even local terrain. Winds do one thing to air pollution on the open plains and another in the middle of a city block.
Because of these variables, an Exxon refinery that wants to build a facility in Houston with the exact same design as is has in Arkansas still has to submit a separate computer model to account for the distinct surroundings in the new location. The one from Arkansas just won’t do for Houston.
Or at least that’s the way things are supposed to work. But like so much else in Southern Dallas these days, things aren’t working the way they’re supposed to.
According to the TCEQ the Austin Asphalt facility is a portable asphalt batch plant operation. That means it wasn’t built specifically for its current Joppa site. It was moved there and it can be moved somewhere else.
In 2002 it first operated in Hockley County, a rural part of Northwest Texas near Lubbock some 400 miles west of Joppa. It moved to its current location in Joppa in 2008.
In 2002 the TCEQ let Austin Industries use what’s called a “SCREEN3” air model to determine if the air pollution from its asphalt batch plant’s was a threat to anyone in Hockley County. Again unsurprisingly, the firm hired by Austin Industries to do the computer modeling found it was “protective of human health.”
TCEQ says the Austin Industries’ asphalt plant has never been subject to any additional “impacts evaluation.” besides this 2002 review.
That means the only air modeling ever done for this Austin asphalt plant was while it was operating in rural Hockley County in 2002. There has been no air modeling of the plant since it came to Joppa in 2008.
In 2002 the Austin plant was in West Texas and used a rural air model. In 2019 they’re still using for it for operation in Joppa.
Besides the most obvious and important difference in population density between unincorporated Hockley County near Lubbock and inner city Dallas, all of the variables in the 2002 modeling apply only to the Hockley County location. Meteorology, stack height, and surrounding terrain among them. In fact, the entire model was defaulted to a “rural” versus “urban” option in 2002. This renders the modeling scientifically useless in its current location in Joppa.
But that uselessness isn’t keeping the Executive Director of the Texas Commission on Environmental Quality from citing it to justify renewal of Austin’s air permit.
There’s also the matter of the age and limitations of the SCREEN3 model. In 2011 EPA replaced it with something called the “AERSCREEN” model. In doing so the agency called the old model “outdated“ and said “there are no valid reasons” to keep using SCREEN3.
And it’s not just the EPA. State environmental agencies, like the Arizona Department of Environmental Quality, have quit accepting SCREEN3 modeling.
Alex De Visscher, Associate Professor and Canada Research Chair in Air Quality and Pollution Control Engineering at the University of Calgary, writing in an 2013 text book entitled “Air Dispersion Modeling: Foundations and Applications,” said SCEEN3 is a “product of a previous generation of air dispersion modeling” and “is no longer a recommended model… it does not allow for multiple sources, and it does not include atmospheric chemistry or deposition.”
These exclusions are important. There are multiple sources of Particulate Matter 2.5 air pollution at Austin Industries’ plant in its Joppa location, including piles of raw material, and industrial combustion at the site. SCREEN 3 modeling didn’t and wouldn’t reflect these multiple sources of pollution. And of course when you’re talking about PM 2.5 pollution, as you are with an asphalt batch plant, the atmospheric chemistry and deposition, or fallout, is critical.
TCEQ’s own air modeling guidelines say so:
“Air dispersion models utilize dispersion coefficients to determine the rate of dispersion for a plume. Dispersion coefficients are influenced by factors such as land-use / land-cover (LULC), terrain, averaging period, and meteorological conditions. Evaluating the LULC within the modeling domain is an integral component to air dispersion modeling. The data obtained from a LULC analysis can be used to determine representative dispersion coefficients. The selection of representative dispersion coefficients may be as simple as selecting between rural or urban land-use types. For the ISC, ISC-PRIME, and SCREEN3 models, the dispersion coefficients are based on whether the area is predominately rural or urban. The classification of the land use in the vicinity of sources of air pollution is needed because dispersion rates differ between rural and urban areas.”
The TCEQ itself says it makes a fundamental difference whether the air model for a polluter is run for urban or rural terrain. Yet for over a decade TCEQ and Austin Asphalt have misused the results of a “rural” computer model to misleadingly assure inner-city Joppa residents that the company’s asphalt plant posed no harm.
What’s more, the modeling performed in 2002 only examined “asphalt vapors,” a made-up, vague pollutant category that can’t be monitored or measured. It didn’t examine Particulate Matter 2.5 pollution or specific Volatile Organic Compounds that make up those “vapors” and was therefore incomplete in the extreme.
So despite all the verbage the TCEQ’s Executive Director uses to tell Joppa residents th
at past “air analysis” has shown Austin Industries’ plant to be protective of human health, in truth the only “analysis” ever done was performed 17 years ago in a sparsely-populated rural location 400 miles away from its current location, with what TCEQ admits are totally inaccurate modeling inputs by company consultants. It didn’t include all priority pollutants or even all sources of air pollution from the facility and the model used is now considered obsolete by EPA, modeling experts, and other state environmental agencies.
Joppa residents deserve better.
In its response to the Executive Director, Downwinders at Risk specifically requested TCEQ delay further regulatory action on this permit renewal until it can conduct a modern comprehensive air modeling impact analysis for Austin Asphalt’s current operation in Joppa that requires an evaluation of all on-site sources of pollution, including fugitive and mobile sources, on the Austin Asphalt site, off-site near-by sources of pollution within a three kilometer (1.86 mile) radius of Austin Asphalt’s facility, and representative monitored background concentrations obtained from local Joppa neighborhood monitoring as well as modeling of permitted maximums emission rates form all sources.
On September 11th the Texas Commission on Environmental Quality will take up the Austin Industries permit renewal at its headquarters in Austin. Both Legal Aid and Downwinders at Risk representatives will be present to answer any questions from the Commissioners but will not be allowed to make any statements. We’ll let you know the outcome.
One
might reasonably ask why the City of Dallas itself isn’t fighting this permit renewal? After all in 2007, the city took on a string of proposed coal-fired power plants that it said would increase air pollution for Dallas. But to date that same city has never bothered to try and stop an industrial polluter from opening shop or renewing its permit in one of its most abused neighborhoods.
This dishonest use of a irrelevant model by the state’s discredited environmental agency shows why it’s imperative the City of Dallas – and all municipalities in Texas – change the way they do business and be proactive in addressing their environmental justice and environmental health issues in their own city limits.
Too often city representatives default to state or federal officials on the environment when they should be the first line of defense, not the last. City officials’ reliance on a failed state agency to perform its job as environmental protector is what caused Shingle Mountain. It’s what caused this situation in Joppa. To change that means changing both policies coming out of City Hall and current City Hall culture. Environmental Protection is a Do-It-Yourself proposition these days.
Sorry Ms. Jackson: The City is Failing Southern Dallas
Marsha Jackson thought she’d found relief when Dallas Morning News columnist Robert Wilonsky wrote about the grotesque environmental disaster being caused by the Blue Star asphalt operation in mid-December..the first time.
After complaining almost a year to the City of Dallas, the State of Texas, and the EPA without any action taken, Ms Jackson saw Wilsonky’s column set-off a flurry of official concern about this inept and dangerous operation destroying acres of tree-covered Southern Dallas and Ms. Jackson’s home of 25 years.
That’ll happen when the city’s most read reporter informs you for the first time in passing about a situation it’s your job to already know about.
But that initial knee-jerk response left Blue Star still open for business, and without a clean-up. So Wilonsky wrote another column. Some more official action ensued. The City got a Temporary Restraining Order….that expired after a week. The authorities made Blue Star push their 4-5 story high mountains of used shingles back away from a small creek running through it’s property so the waterway would be better protected. Ms. Jackson? Not so much.
In fact, Blue Star has not been cited with even one nuisance, air pollution, or public health violation by the City of Dallas since it began building its special version of Hell a little more than a year ago. Officially, the city has shown zero concern for the human toll being taken by Blue Star’s pollution.
Last month Wilsosky wrote his third column stating what many of us feel when we see the operation in person: “This is insane.” He got Dallas City Manager T.C. Broadnax on the record saying Ms. Jackson’s plight was the result of bad zoning, the kind that allows polluters to only set-up shop south of Dallas’ historic dividing line Trinity River. But no action was taken to change that zoning and Blue Star keeps right on accepting truckloads of old shingles and keeps grinding them up in the open-air using the industrial equivalent of giant wood chippers, spewing fiberglass, plastic and maybe asbestos into Ms. Jackson’s property and neighborhood.
Blue Star keeps operating even though the City of Dallas says the business didn’t have a Certificate of Occupancy when they opened, despite evidence current city zoning doesn’t allow what they’re doing on the property they’re doing it on, and despite evidence they don’t have all the environmental paperwork they need for the despoiling taking place.
Despite his best efforts to do the job the City and State are supposed to be doing, Wilonsky’s words just haven’t been enough to stop the obscene environmental and public health problems being caused daily by Blue Star.
So maybe it’s time to do this ourselves.
Maybe it’s time to file some lawsuits of our own, as citizens. There’s now plenty of documentation to prove the case of destruction, property rights takings, and personal and public health problems. Are there lawyers working in the public interest who could pursue these on behalf of Ms. Jackson and her neighbors? Yes there are. There are ones who can sue for regulatory relief and others who sue for “personal damages” caused by this kind of reckless disregard. These “toxic tort” attorneys would do well to target the deep pockets of the City of Dallas and the State of Texas as well as the modest holdings of Blue Star. Often the way to permanently put a stop to this kind of thing is to make the responsible parities pay such a high price that they’re never even tempted to try it again.
Maybe it’s time for us to begin amortization proceedings against Blue Star. This is the process that closed the RSR lead smelter in West Dallas in the 1980’s. A city can change the zoning for a piece of property to something that clearly does not allow the current activity to take place on that property. In order to be fair, the law allows the current users to operate until they get their investment in the property back and then they have to close-shop and move. Once you see the Blue Star property, you’ll understand that it’ll take about a day and a half for the company to get back its “investment.” In fact, because of all the violations of law and probable lawsuits, Blue Star is probably already close to being in the red.
Amortization proceedings can be initiated by the City Council OR citizens themselves. Here’s a description from the Dallas City Code using the City’s 15-member, council-appointed Board of Adjustments:
§ 51A-4.704. Nonconforming Uses And Structures.
The city council may request that the board of adjustment consider establishing a compliance date for a nonconforming use. In addition, any person who resides or owns real property in the city may request that the board consider establishing a compliance date for a nonconforming use. Upon receiving such a request, the board shall hold a public hearing to determine whether continued operation of the nonconforming use will have an adverse effect on nearby properties. If, based on the evidence presented at the public hearing, the board determines that continued operation of the use will have an adverse effect on nearby properties, it shall proceed to establish a compliance date for the nonconforming use; otherwise, it shall not.
Ms. Jackson owns her house. So maybe it’s time we help her petition the Board of Adjustments to begin kicking Blue Star out of Southern Dallas ourselves. If the Council wants to do its job and join in, that w
ould be great. But we don’t need them to start the ball rolling.
Maybe it’s time we protested. Not just on behalf of Ms. Jackson, but the ancient, racist underlying cause of this awful situation and so many more south of the Trinity River. Everyone who lives in the “Southern Sector” is a current or potential Marsha Jackson. We’ve got to begin to change the entire zoning map of the city to get rid of the kind of outrages even the City Manager acknowledges are a problem. We need to demonstrate not just against Blue Star, but for improvement across the board, for real progress on the City’s own Master Plan for South Central that aims to “de-industrialize” the area – not make it into a wasteland. We need a platform for progress that address the Southern Sector as a whole instead of continuing to play whack-a-polluter every few months at a different location.
Since August, T
he Let Joppa Breathe Alliance has been meeting to try and draft such a platform as part of its mission. It’s been recruiting allies south and north of the river. It’s very near to making an announcement about that platform and the means it will begin to pursue it. This platform will be the first attempt to articulate specific City of Dallas environmental justice policy changes in the City’s history. It represents a tectonic shift in responding to age-old discrimination that’s still leaving a huge dusty coal-like legacy in Southern Dallas. We’re tired of playing defense. Its time we set the agenda.
Dallas City Hall has failed Ms. Jackson and her neighbors. It’s failed Joppa. It’s failed Cadillac Heights, and Highland Hills and Fruitdale, and West Dallas. Over and over again. To win progress, something more must be done. When the call comes for that something more, how will you respond?
End of Year Report: DFW Smog Goes Up While Going Down; PM is Worst Since ’03
Only in the nonsensical world of EPA air quality regulation could the official regional average for DFW smog actually decrease despite the worst levels of DFW Ozone pollution in five years.
In 2018 a quarter of all North Texas official monitor sites recorded smog levels in the 90-95 ppb range for more than an hour. 2018 was the first time in two years that any DFW monitors have had 8-hour averages of 80 ppb or above, and the first time since 2013 since there been at least six. In fact, this year’s total number of 80-or-above monitors is almost equal to the total number from the last five years combined.
Nevertheless, the regional average for smog pollution that determines government action actually went down from 81 to 76 parts per billion.
How does that happen? Not without a lot of numerical manipulation. EPA’s formula for smog pollution classification is a two part affair. First EPA only counts the highest 4th highest annual reading from each monitor in DFW. That means every monitor gets three “Mulligans” or “do-overs” before the results are eligible for regulatory use. Then EPA combines the last three year’s worth of those highest 4th highest readings to produce a rolling average. So that 2018 average is actually the results of the highest 4th highest reading from 2016, 2017, and 2018.
High readings from the summer of 2015 are rolling out of that three-year rolling average, while lower readings in ’16 and ’17 remain. While this year’s smog levels were higher, but not so extraordinarily high as to be able to counter the lower numbers making up the rest of the average.
But our smog was bad enough last year and this to once again make sure DFW is in “non-attainment” of the clean Air Act for the pollutant. For the umpteenth time in a row, we missed a deadline for meeting a Clean Air Act smog standard – this time it’s the 2008 75 ppb standard. If EPA follows its own protocol, that means DFW will be go from being “moderately” out of compliance to being in “Serious” non-compliance.
And please remember all of these numbers are based on only 20 smog monitors, half of which are located well-outside the DFW urban core, and none of which are located in Wise County, where Downwinders is doing the job of monitoring ozone pollution that the State and EPA refuse to do.
What are the consequences of this continuing violation of the Clean Air Act that imperils public health? Nada probably. At least while the Trump Administration holds office. In the past such classifications would have triggered a process leading up to some kind of official plan of action that, at least rhetorically, is aimed at correcting the 30-year old problem. But no one expects the State of Texas, or now the EPA, to take that responsibility seriously.
What you can expect is some official TCEQ spin about how it’s been successful in bringing down smog pollution levels. In fact, it was the wettest September on record that brought an abrupt end to what was shaping up to be an even worse smog year than it already was at the end of August. Historically, September is when DFW sees some of its worst bad air days. But not this year.
Accompanying the rise in smog pollution in 2018 was also a dramatic rise in the regional numbers for Particulate Matter (PM) pollution – the highest North Texas has seen since 2003.
After a long spell of annual peaks of between 24 and 28 migrograms per cubic meter of air, the 2018 average for highest daily readings among all sites has risen dramatically as of this month – to almost 40 µg/m3
Before this year, they’d only been four daily peaks above 40 µg/m3 over the last 15 years. In 2018 four out of 6 PM monitoring sties had registered daily readings averaging between 41 an 43 ppb as of October.
The EPA annual standard for PM pollution is 12 µg/m3. The 24 hour standard is 35 µg/m3.
As with smog, these readings are coming from a very small pool of monitors – in this case just six PM monitors scattered over an area only slightly smaller than Rhode Island.
Some of this might be blamed on the drought we we experiencing during the summer and increased dust circulation, but comparing it to 2011 when similar if not worse conditions were in play shows no similar bump then. Fewer coal plants blowing their plumes into DFW this year might lead you to think we were even due for a drop. Instead it’s as if someone turned the key on a couple more. There’s no obvious reason why PM levels would have jumped so much in a single year.
What’s clear is that local governments are the last refuge for effective and new air pollution control measures. Until political leadership changes in Austin and/or Washington, there’s no expectation of any relief. In fact, every day sees new proposals from the State or EPA that will actually increase smog and PM pollution in DFW. This is why local city and county elections are just as important as state and national ones.
We’ll have to wait until the end of 2019 to see if this rise in pollution averages is a trend or blip, but there’s no question that smog and PM are taking their toll on public health in DFW. Study after study shows harms at levels of exposure well below these annual and daily averages that determine EPA regulations. In the real world, your lungs, heart, brain and immune system don’t seem to be able to distinguish between “safe” and “unsafe” levels of poison as defined by the government.
Fresh from the Vault: Open Records Act Results from the Dallas Office of Environmental Quality
Last month we requested the City of Dallas’ Office of Environmental Quality files concerning air quality monitoring going back a few years. We wanted to know more about how City staff chose the Texas Nature Conservancy’s “Breathe Easy” study as its first air monitoring project through a process of…well, there wasn’t exactly a process was there?
Here’s some highlights from the materials we reviewed so far:
Despite criticism, OEQ Staff is recommending using the same air monitors for its own study that Downwinders used in Joppa.
OEQ staffers have criticized Downwinders’ portable monitoring in Joppa…despite the lack of any city monitoring up to that point in the neighborhood. Something about the lack of reliable data. But lo and behold, OEQ staffers seems to have recommended not only the same company (New Zealand-based Aeroqual) to the Nature Conservancy for its stationary monitors, but also exactly the same portable air monitors. We told you they were good.
Any local university scientist who’s worked with Downwinders is blackballed.
Dr. Kuruvilla John, Professor and Chair Department of Mechanical and Energy Engineering at the University of North Texas was “…biased because funded by Downwinders” according to one meeting summary and blackballed by OEQ staff as a City technical advisor for the Breathe Easy project. Dr. John’s sole sin was to get paid as a contractor in 2015 by Downwinders to perform a single study using the state’s own computer model for DFW smog. Before ruling him out, no one on OEQ staff mentioned that Dr. John’s modeling and study was endorsed by a unanimous Dallas city council vote recommending the EPA take more proactive measures to reduce smog pollution.
One wonders if his collaboration with Downwinders and other citizens groups in the DFW Air Research Consortium have made UTD’s Dr. David Lary similarly verboten to OEQ staff.
Dallas City staff in-kind contributions to the Texas Nature Conservancy “Breath Easy” project are very, very large.
To date, the partnership between the City and the Texas Nature Conservancy has raised almost $300,000 in grant money for a study involving nine schools. But that total pales in comparison to the in-kind contributions the city is making to the effort over both its developmental period and it two-year run. For example…
Combine all the staff time over 3-4 years with data services costs and you could well have a multi-million dollar donation from the City of Dallas to the Texas Nature Conservancy, courtesy of your tax dollars.
OEQ staff likes the idea of a new air monitoring network…in other cities.
As one OEQ staffer put it: “We’re looking at air monitoring programs in states and cities. In Minneapolis/St. Paul the state agency is installing low cost (and low resolution) monitors in every zip code. In L.A. they are installing 100 monitors citywide. Baltimore, Chicago and Lafayette all have enhanced monitoring programs. Here the TCEQ has zero interest in any of these projects. The EPA staff are very interested, but cannot offer any financial support.”
A OEQ staffer sought a job with the Conservancy even as the Breathe Easy project was taking shape.
“We are teaming up with the Nature Conservancy and their new Urban Conservation Director ( a position I interviewed for in early 2017….)”
As you piece together the email chains and date memos, it’s clear that if it weren’t for the considerable support from the City of Dallas, the Nature Conservancy’s Breathe Easy air monitoring project would…need a lot more grant money.
Why has OEQ staff committed so much time and money to a two-year study of nine schools while dismissing the lesser expense and effort of joining a regional network of air monitors many times that size? A real time air quality network modeled on the very kind OEQ staff seem to admire from afar in other cities? That’s an answer that we haven’t found in the files yet.
But it’s something to keep in mind for the re-scheduled September 24th Quality of Life Committee meeting where presentations about both the TNC/City’s private study and the DFW Air Research Consortium public network will be featured.
Two of these “Soot Trackers” Are On Their Way to Downwinders…and You
Thanks to a grant from the Simmons Sisters Foundation, Downwinders is proud to announce we’ve purchased our first two portable Particulate Matter sensors for our No Safe Level Campaign against PM pollution.
They’ll be the only PM monitors of their kind in the region, and their arrival will inaugurate a new era in DFW citizen-empowered science.
The sensors are made by AEROQUAL, a New Zealand company, and you can’t find them on Amazon. They measure both PM 10 and PM 2.5 (microns) at the same time. Their sensor heads use laser and optical sensors to measure light scattered from particles passing through the laser beam. A built-in fan ensures a stable and precise flow of sample air to the sensor. They also compensate for humidity by way of an on-board humidity sensor.
Each comes with a long-life Lithium battery which allows for 24 hours of remote operation between charges. Recharging takes just 3 hours. The monitor can be plugged-in and left to run indefinitely. Besides displaying levels in real time, measurements can be stored on the device and downloaded later to a computer via the USB cable and bundled software.
They come factory-calibrated to European Union standards and are capable of being re-calibrated for side-by-side use with an EPA monitors, or any other local baseline. 
These monitors have two parts – a base and a a detachable sensor head – making them even more useful. In the future Downwinders can buy other kinds of sensors from AEROQUAL to plug into the base and test for gaseous pollutants like Ozone, or Sulfur Dioxide. In all, 28 other sensors are available.
Before now you either had to buy $16,000 PM sensors that were fully calibrated or settle for much less reliable equipment. But the technology is moving so quickly and demand is scaling up so fast that a middle-income niche market for scientifically-rigorous instruments is beginning to provide opportunities to non-profit groups like Downwinders, and the public in general.
Along with these portable sensors, we’re also ordering stationary PM monitors as part of the regional network being established by UTD and others.
As a result of this influx of technology, Downwinders is creating a PM Project Science Director position to maintain the integrity of our research. The Science Director will be in charge of these monitors, training citizens on how to operate them, and overseeing their use in the field.
Our plans are to begin using the sensors in neighborhoods and suspected hot spots as soon as possible to help us fill out our PM Map of DFW. We want to be able to loan them out to those citizens who’ve gone through the training and have a problem they want to investigate. They’ll also be available for use during accidents, explosions, and fires.
We’re not letting state and EPA rollbacks stop us. We’re creating our own regional air monitoring network. Are you interested in joining? Stand by. We’re just getting started.
How Do You Make Progress in the Trump Era? Two Words: Particulate Matter
Public Health
Economic Development
Transportation
Housing
Childhood Development and Education
Environmental Justice
Crime
In the same way lead exposure was linked to lower IQ in children and anti-social behavior like crime, PM Pollution is now being linked to learning disabilities and juvenile delinquency.
And in the same way public health mandated the removal of lead from gasoline and paint, many public policy measures are needed to help eliminate PM pollution exposure.
Many if not most of these are local in nature. They don’t need EPA or TCEQ approval.
__________
In California, buffer zones between new homes and freeways are under consideration because so many 
studies have shown children living next to freeways suffer significantly higher rates of Autism and learning disabilities.
Some local governments, school districts, and public transit agencies, including DART are beginning to electrify their bus fleets to reduce exposure to PM pollution and save money. “No idling zones” around schools and are being enlarged.
In DFW, Downwinders is sponsoring a broad public health initiative aimed at identifying and reducing PM Pollution from all sources, called “No Safe Level.”
Just as PM pollution poses all kinds of adverse health effects it also provides lots of opportunities at the local level to make things better for your neighbors:
Safer homes and schools.
More sustainable public transit.
More equitable zoning.
Pollution controls.
Public Health protections in the neighborhoods that need them most.
We can make progress. But we need your help.
“NO SAFE LEVEL”
Particulate Matter
CAMPAIGN MEETING
SATURDAY, JANUARY 27th
2 – 4 PM
Hill Country Room
Meadows Conference Center
2900 Live Oak in Old East Dallas
Get the Basics on PM
Help Pick Campaign Targets and Create Strategies for Change
Your Hosts, Our No Safe Level Committee members:
Cresanda Allen
Shannon Gribble
Amanda Poland
Evelyn Mayo
Misti O’Quinn
FOLLOW-UP:
West Dallas residents won their fight to close the RamCrete batch plant at the January 10th Dallas City Council meeting. The vote was 14-1 with Council Member Rickey Callahan the lone outlier. However, The City’s Office of Environmental Quality didn’t distinguish itself when a spokesperson reassured Callahan that any facility meeting TCEQ standard exemption permit levels of pollution “could not be causing a problem.”
Incompetence or Negligence? It Doesn’t Matter: Local Air Pollution Catastrophes on Oct 19th & Dec 11th Show Why DFW Must Have Its Own 21st Century Independent Air Quality Monitoring Network
Q: What caused PM and Ozone pollution to spike so high and fast on Oct 19th that health alerts had to be issued from Dallas to Denton?
A: The Texas Commission on Environmental Quality couldn’t care less.
That’s the take-away from Peggy Heinkel-Wolfe’s story that appeared over the weekend in the Denton Record Chronicle.
You may remember we reported on the mystery shortly after it happened and tracked down all the local and non-local suspects cited by officials in the media that day. None of them turned out to be the cause of an air pollution incident that was so potent it raised the entire regional ozone average a whole part per billion and forced PM levels into the triple digits.
Heinkel-Wolfe goes one step further and makes inquires from the TCEQ itself. And the run around she gets is Catch-22 material.
TCEQ says they can’t investigate an air pollution problem unless there’s a known cause. But if there’s a known cause, what you’ve got there really isn’t an investigation any more, it’s an enforcement action, isn’t it?
This article may be the single most compelling case for why DFW needs its own locally-controlled air quality monitoring network. Find it here.
Q: Where are the results of the air samples the Dallas Fire Department supposedly took when a West Dallas Recycling was sending large plumes of black smoke over the surrounding and downwind neighborhoods on December 11th?
A: Nobody seems to know.
A huge pile of metal scrap burned and smoldered for over 24 hours at Sunshine Recycling on Ruder Street in West Dallas on December 11th. Thick plumes of smoke streaked the sky for half a day and into the night.
According to WFAA-TV, a Fire Department Hazardous Materials response team was on site because there were hazardous materials on site – although exactly what those were, or are, remain nameless.
That evening the Dallas City Councilman who represents West Dallas, Omar Narvaez, posted on his FaceBook page that “The Fire Dept has conducted testing and there is no hazardous materials burning.”
Really? Because when a scrap yard like that catches fire, you can bet there’s “hazardous materials” burning whether it’s officially noted or not. Plastic tubing and hoses become Dioxin-generating embers. Used oil has all kinds of metals in it that attach themselves to the smoke particles. Vinyl can generate very toxic fumes. Just the PM pollution from the smoke alone was enough to trigger all kinds of harmful health impacts. Very likely the entire pile of metal waste that was burning that night was indeed “hazardous.”
But OK, you say you took tests and they showed nothing out of the ordinary? Let’s see them. In December Downwinders submitted a Texas Open Records Act request to the City of Dallas for the results of those tests. We’re still waiting. As of today, and despite three phone calls to the Open Records Division of the City Secretary’s office, we still don’t have what it’s supposed to take no more than 10 business days to get. It’s been a month and counting. We’re trying to get some legal help to extract the information. Stay tuned.
For $500 a piece, we can install a dense grid of PM monitors across the region, tie them all together and present the information to the public in a transparent accessible way. It can be locally-controlled, directed by scientists, and independent of political influence.
It would automatically track plumes in real time, not an hour ago. It would give you reliable and specific levels of pollution rather than vague reassurances. It would transfer the power from officialdom to citizenry.
That’s the new Network we’re building. Stay tuned.
Mysterious Catastrophic Air Pollution Episode is Why DFW Needs its Own Air Sensor Network
Not quite two weeks ago, on Thursday October 19th, something happened to throw local air quality conditions into the red zone for most of the day.
There was a inexplicable smokey haze extending along the limestone escarpment from Midlothian to Dallas and then north to Denton, sending Particulate Matter pollution soaring to Beijing levels and ozone readings so high the whole regional average went up a part per billion. Countless downwind residents complained to officials, FaceBooked, and Tweeted about “the smell of burning plastic” enveloping their neighborhoods with the smoke, which was so thick many thought the problem was just down the street.
The 24-hour standard for Particulate Matter Pollution is 150 ug/m3. The annual standard is 12.
70 ppb is the new ozone standard.
The events took the Texas Commission on Environmental Quality completely by surprise. Commission computer forecasting had not predicted an Ozone Alert Day or warned of heavy PM pollution. Officials were playing catch-up for the rest of the day.
Now almost two weeks later nobody official knows what caused this Really Bad Air Day. Not the EPA. Not the Texas Commission on Environmental Quality. Not the DFW area citizens who breathed in the dirtiest air their lungs have seen all year.
Despite the sophisticated technology available to us in 2017, a single unexpected incident upwind of DFW can throw the entire North Texas air shed into the danger zone with no warning and no clue as to what initiated it.
Readings from state monitors were of no help until damage had already been done. As usual they were two hours or more behind in reporting. The numbers they were displaying at 12 noon were actually taken at 10 am. You had no idea what was going on in real time so that you might better protect yourself or family.
There are only three or four Particulate Matter pollution monitors in all of DFW. Even if you’d wanted to use the state’s current monitoring system to track this mystery plume, you couldn’t have done so. It doesn’t have that capability.
As inquiring reporters called, the TCEQ staff found a variety of things to blame. TCEQ suggested the smoke was from a Bastrop forest fire near Austin. But readings from monitors between Bastrop/Austin and Dallas show there was no problem south of Midlothian that day, while there was a huge problem north of there at the same time. Eyewitnesses who saw the plume on Thursday reported a thick narrow ribbon of a plume you’d see coming off a near-by source, not the sort of diffused cloud you’d expect to witness after traveling more than a hundred miles downwind. And then there’s that “burned-plastic smell.”
Then it was maybe one or more “controlled burns” in the Midlothian-Mansfield area. As it turns out, neither fire department found evidence of any permitted controlled burns in their own jurisdictions that could have cause so much pollution. Midlothian’s single permitted fire for the day was “the size of a coffee table” according to a department employee.
According to the Mansfield Fire Department “a fire” was reported to be located at Kimball Road and Hwy 287 just north of the Midlothian city limits. This is what’s at that intersection:
Please note the caution against open flames. Could a fracking site have produced the kind of particulate matter pollution and haze we saw on October 19th without methane or other kinds of pollution being released en masse as well? It doesn’t seem like it could. But what if the fracking site had been turned into a temporary waste incineration site for the day?
That’s not all. A satellite pic of the intersection and what’s around it reveals Kimball and Hwy 287 to be a kind of rogue’s gallery of potential suspects:
Besides the fracking sites you can be see in mid-drilling on this Google street level tour, the road leads to a Trinity River Authority Wastewater Treatment plant and the back door of the giant Ash Grove cement plant.
TRA is a shadowy, 60-year old regional bureaucracy that owns millions of acres of land, reservoirs, landfills, and wastewater-treatment facilities. It’s been in environmental hot water before. Wastewater treatment accumulates a lot of solids, and the TRA handles a lot of trash. It’s not inconceivable that it had something to do with the October 19th incident by thinking it could get away with an open burn on its own property.
Ditto for Ash Grove. Like the other two cement plants in Midlothian, Ash Grove’s kiln is allowed to burn industrial waste, including used oil, tires and plastics – remember the oft-cited “smell of burning plastic” citizens reported on the 19th? Waste-burning cement plants have had their wastes combust and cause huge fires before and each plant has its own emergency response crew which might be able to put out a fire without calling Midlothian.
There’s no proof Ash Grove, TRA or the fracking sites were the cause of the October 19th public health disaster. But there’s also no proof yet they didn’t cause the problem.
The truth is: there’s no official explanation for what made the air so dangerous to breathe on October 19th .
More truth: As of Friday, October 27th the TECQ had not even opened an official investigation into this matter – which again, sent Particulate Matter pollution to levels not seen outside SE Asia and single-handedly raised the regional ozone level.
This is why Downwinders at Risk filed the first of what we’re sure will be a series of Texas Open Record Act requests last Friday seeking:
“Any and all printed or electronic documents and electronic media containing information concerning or related to ozone, particulate matter and/or haze air pollution readings and levels in the Dallas-Forth Worth non-attainment area on Thursday, October 19th 2017, including official ozone action warnings issued, complaints filed about air quality in the Dallas-Fort Worth area that day, photographs, satellite images, computer modeling, as well as all material related to any questions, inquiries, or investigations about air quality in DFW on October 19th anyone in the TCEQ, or contracted by TCEQ has been tasked to perform since October 19th or is still performing currently, and e-mails, letters, reports, telephone logs and notes, memos and all other material about October 19th air quality from 6 am Tuesday October 19th to Wednesday October 25th, 2017.”
TCEQ has until November 10th to respond. We’ll keep you posted.
In the meantime, this episode becomes Exhibit A in why DFW needs to catch-up with other metro areas and build its own network of high tech air quality sensors.
If such a grid had been in place, there would have been a real time warning of the PM and ozone pollution being generated shortly after the it started. There would have been a way to locate the source of the pollution right away and do something about it before it got worse, and there would have been a way to predict the plume’s course and warn those in its path before it got there – not two hours after it arrived.
In this sense a modern sensor grid is actually a pollution prevention device, an investigative tool, and an early warning system all rolled into one.
In a metropolitan area that’s been out of compliance with the Clean air Act for 27 years and counting over 14 million lungs are being held hostage by a state air quality monitoring system left over from the 1990’s. It’s being maintained by a state agency that’s run by polluters, officially thinks smog isn’t bad for you, and is cutting its air monitoring budget.
There’s no desire in Austin to update this obsolete system and no money to do so. If DFW officials want to utilize 21st Century technology to help them clean their air, they’re going to have to build their own network of air monitors – exactly the proposal the DFW Air Research Consortium was trying to get funded with a National Science Foundation grant. Close, but no cigar.
Without the NSF grant, local officials are going to need to get creative. Are there private businesses who might want to sponsor an app that could tell give you useful air quality info in exchange for naming rights: “Brought to you by the Nissan Leaf DFW Clean Air Network.” Are there local foundations that would contribute? What about local high-tech billionaire Mark Cuban? For less than a million bucks, DFW could have 500 Particulate Matter sensors that would be capable of of pinpointing a problem down to the street address.
Baltimore, Chicago, Chattanooga, Louisville, L.A. , Oakland, and Lafayette, Louisiana are all way ahead of DFW in building out their own local dense grid of air sensors. They’ve done it with a combination of private, government and academic know-how and financing.
We have as much, or more technical expertise and money than any of those locales and we should have more incentive given our chronic air pollution problem. There’s no reason we can’t build our own modern, more protective, more useful way of monitoring air pollution – even if the state isn’t interested. Not only can we do it, but in light of the events of October 19th, it should be considered a necessary act of public health self-defense.
Is that a Disco Ball, or is Your Photoluminescence Experiment Just Glad to See Me?
Downwinders’s “Evenings of Science and Socializing”
Concludes with SRO Crowd in Denton
We’re pretty sure it was the first time Cambridge-trained UTD Physicist Dr. David Lary had presented in a bar.
The occasion was opening night of Downwinders’ “Evenings of Science and Socializing” at Bryan Street Tavern, in a dark back room that came complete with fog machine, disco ball, and a too-close juke box.
But Dr. Lary is nothing if not persistent. He’s applied for one grant after another in trying to fund his dream of a regional grid of hundreds or thousands of air monitoring sensors. He was told not to even bother applying for a prestigious National Science Foundation grant. That would be the same grant he and his consortium of colleges, cities, and citizens groups are now in the running for. That kind of persistence is why he’s an honorary Downwinder.
And so, like the trooper he is, Dr. Lary pushed through all the distractions and pitched his plan to an audience of about a dozen and half, including wayward bar patrons who stumbled onto the exhibit and stuffed $5 dollar bills into the donation jar.
Four nights later it was Dr. David Sterling of the UNT Health Science Center explaining how his school’s partnering with the Fort Worth League of Neighborhoods gave birth to the design of the portal used by the public to access the monitoring information. His talk drew about two dozen citizens to the Ginger Man pub, including many that had been directly involved in the focus groups he had sponsored over the past five years.
And two nights after that, Dr. Lary and UNTHSC Environmental Health doctoral candidate Leslie Allsop showed up at the Greenhouse in Denton with a Standing Room Only crowd of at least 40-50 folks, plus a few latecomers who were turned away.
Some of the audience questions were the same at every meeting. How much do the sensors cost? How do we get one or more of them? Some were particular to the location or audience being addressed, like why is Denton always the “worst-performing monitor” in North Texas? Answer: location, location, location.
All of these meetings were the first time the general public had been invited to look at the technology and plans of the DFW Air Research Consortium, (DFW ARC) the less-than-year old group that’s gaining momentum in its quest to use high tech solutions to decades-old problems. Downwinders has been instrumental in establishing and administering the group. It includes the cities of Dallas, Fort Worth, Plano, the School Districts of those cities plus Richardson and the Dallas County Community College system, TCU, UTA, UNT and UTD, plus Livable Arlington and Mansfield Gas Well Awareness.
News of the National Science Foundation grant the Consortium applied for should be coming any day now. Considering the competition, it would be quite incredible if the Consortium won. It would generate much needed publicity and increase our chances for getting other grants. But regardless, the work that went into the NSF grant has produced a template for the Consortium to apply to other foundations and individuals to grow the same regional grid of sensors. The work won’t stop if the NSF money doesn’t come through.
Proof of that are two on-going projects of the Consortium and its members that are already up and running.
The “10-Schools” project at UTD is one where a select number of schools across the Metromess will be paired with Particulate Matter and Ozone monitors in the first attempt to sketch out the frame of a regional grid system. Selection of the schools is being weighed right now. At every meeting there was a suggestion from citizens for this or that school that should be included based on its proximity to a large pollution source, or high absentee rates. It will be tough to narrow all those suggestions down to ten.
In the Fall, the project will be distributing the monitors, being assembled now at Dr. Lary’s lab at UTD. They’ll come with a video camera, a micro meteorology unit, and the pollution sensors themselves. Students will be able to use the monitors as a tool in classes. Neighborhoods will be able to use the information to better protect themselves. It will be the beginning of building a regional grid that identifies and tracks air pollution much better than the state or EPA does now.
Then there’s Downwinder’s own “Wise County Ozone Project,” that will use the two brand new portable ozone monitors we just bought to begin recording smog levels in the one and only county in the “DFW Non-Attainment Area” that doesn’t have any. We have at least one location secured for a stationary monitor, but we need some additional assistance. To pull this off, we need:
– Carpenters that can help us assemble a couple of 12-13 foot wooden platforms that will house the monitors.
– Solar expertise and panels to help power the monitors.
– Electrical Engineers that can help us hard wire the monitors to those panels and back-up batteries.
– IT experts who can help us with connectivity issues.
If you or someone you know could be of help in any of these categories, please write us at Info@downwindersatrisk@gmail.com or call us at 469-608-1972.
What these two projects prove is the technology featured in all three of our recent events is here now and being used. We don’t have to wait. We just have to organize ourselves to make effective use of it. Help us do that. With your expertise if you have it. With your time if you can spare any. With a contribution if you can.
There are many things you may feel powerless to change right now but this is a “bricks and mortar” change on the ground that can take place over the next few years and promises to deliver a challenge to both Austin and DC. Become a part of it.
Thanks to Dr. Lary, Dr. Sterling and Ms. Allsop for donating their time and taking on the challenge of bringing science to the public..and pubs. Thanks to our co-sponsors: The Dallas Innovation Alliance, the Fort Worth League of Neighborhoods, and the Denton Drilling Awareness Group. And thanks to everyone who showed up and made these events more useful to citizens. Onward thru the Smog.