The Chinese Silent Spring Moment?

by jim on March 2, 2015

Children wear masks as a thick haze of air pollution envelopes Tiananmen Square in January.?Every once in a while, even now, in the midst of our electronic surroundsound calliope, popular culture can freeze on a moment of some social significance that strikes a collective nerve.  For the US this summer it was Ferguson, Missouri. For China, it might just be this last weekend's debut of a documentary about the horrible air pollution that envelopes life in much of that country.

"Under the Dome" is the video manifesto of a Chai Jing, a former Chinese television reporter who didn't give much thought to the brown haze she was breathing, until she was breathing for two.

"Back then, she says, she paid little attention to the smog engulfing much of China and affecting 600 million people, even as her work took her to places where the air was acrid with fumes and dust.

“But,” Ms. Chai says with a pause, “when I returned to Beijing, I learned that I was pregnant."

“I’d never felt afraid of pollution before, and never wore a mask no matter where,” Ms. Chai, 39, says in the video. “But when you carry a life in you, what she breathes, eats and drinks are all your responsibility, and then you feel the fear.”

Her film was posted online Saturday and within just a news cycle or two caused such an uproar and reaction that China's minister of environmental protection compared it to Rachel Carson's “Silent Spring,” the landmark exposé of chemical pollution published in the early 1960's that led to the banning of DDT in the United States. By Sunday afternoon, over 25,000 comments from Chinese citizens had been left at her website, including ones like this that any frustrated downwinder can relate to: “In this messed-up country that’s devoid of law, cold-hearted, numb and arrogant, (her film) is  like an eye-grabbing sign that shocks the soul.”

Jing's approach to the material is partly responsible. This isn't a detached observational third-person narrative of the problem. It's her own memoir that uses science and investigative reporting as tools to explore the links between her daughter's benign tumor and the dirty air she believes might have caused it, and so many other health problems. It;s a personal story she probably ould not have told as a member of the official Chinese television news network where she was employed for many years.

We've noted for some time that the most radical environmentalists on the planet aren't Earth Firsters in Colorado, or Greenpeace activists in Europe, but angry Chinese parents, who, over the last decade, have kidnapped the managers of polluting facilities and destroyed whole chemical plants suspected of causing widespread health problems in villages. Undistracted by a mind-numbing, soul-killing regulatory regime like the Texas Commission on Environmental Quality that offers a veneer of control, there's no bureaucratic weapons available to most Chinese citizens when they're being shat on by industry. You either accept it or you don't. Increasingly, when it comes to the harm being imposed on their children, many don't. Especially the mothers.

Take a look at the membership of any front line environmental group. It's populated and administered mostly by women. It was women like Rachel Carson who took on the patriarchy of "modern science" to begin the discussion on environmental health. It was Los Angeles moms in the 1950's who organized the first anti-smog groups and began the modern fight for cleaner air. It was Lois Gibbs, the mother, at Love Canal who committed her own act of kidnapping when she found out her house was built on top of a toxic waste dump. It's women who lead the anti-fracking groups around the country today and here in the Barnett Shale. It's women who founded and make up 90% of Downwinders' board.

Environmental activism may be one of the purest forms of modern feminism there is, both in content and organization. And it's a woman, a mother, who may have once again held up a mirror to a culture, one that hosts a full 6th of the world's population, and asked what the hell are we doing to our species by exposing ourselves to so many obvious poisons. 

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leaking-damFor almost a year, Mansfield residents have been trying to rewrite their city's drilling ordinance to better reflect the science surrounding the public health consequences of heavy industry taking place so close to people. During this entire time, and countless appearances before their city council, there has not been one Mansfield citizen who came forward and defended the current approach.

But now that the Mansfield council is ready to act on a new ordinance, the gas industry is doing exactly what it's always accusing their opponents of doing, sending outsiders in to invade the town and spread misleading information. And they're doing it in a big, desperate way. Let's just review what's happened in the last couple of weeks:

Industry hired a sleazy push polling firm to conduct a Mansfield campaign by phone that purposely misleads about the impact of the revisions to the ordinance being sought and makes personal attacks on the residents pursuing those revisions.

Sent in trade association speakers from Austin and Fort Worth to Mansfield to further mislead the business community about the revisions being sought.

Set up an e-mail site where industry employees, no matter where they live, send their comments to the Mansfield City Council, in opposition to any revisions.

And last night, (Sunday) the industry released a "study" purporting to show how safe the existing 600 foot setback was in Mansfield.

And these are just the things we know about right now. Having seen the huge multi-well Edge Resources permit get temporarily, but unexpectedly, tabled in January, the industry wasn't about to take any chances on seeing that happening again in their own back yard. So they've thrown everything and the kitchen sink into the Mansfield fight.

Of course, this reaction is a tremendous complement to the efforts of the intrepid Mansfield Gas Well Awareness group, that has, oh who knows, maybe a millionth of the budget the industry has already spent on these efforts. That the gas industry should be so frightened by calls for "responsible drilling" and more protective measures that have numerous precedents in the region tells you all you need to know about their insecurity post-Denton. It's almost comical.

Let's just take the latest effort that the Energy in Depth guys are generously calling a "study." Forget that if an environmental group were offering up such a thing, they'd be the first to point out its obvious bias. But of course, that objection disappears entirely when they fund the results. All of a sudden its a paragon of virtuous objective science. And mind you, these results were funded by the very gas operator who's well emissions are being sampled. No conflict of interest there.

Forget also that they're so proud of this work that they released it on a Sunday, after hours, the day before the Mansfield City Council takes up consideration of a new gas drilling ordinance. It's almost like they wanted to minimize the scrutiny of the thing.

Also put aside that this thing is not peer-reviewed or journal published – because the "science" is so poorly done that it could never pass review and get published in anything but an Energy In Depth blog post.

Also discount the love industry has for for testing levels of contaminants in the air versus its utter contempt for testing people and health. If you're going to claim as your working hypothesis that certain levels of contamination are completely harmless, and that anything that falls below certain levels is benign, then why not put that hypothesis to the test by performing an epidemiological study? But no, you see no such studies coming from industry, because they don't want to test that hypothesis. 

One type of study is top, down. It looks at the levels of poisons in the air, and assumes that if they don't exceed the levels deemed dangerous by the regulatory arm of the industry , the Texas Commission on Environmental Quality, then everything must be hunky dory.

The other is bottom-up. It looks at the health of people who live adjacent to the facility releasing the poisons and determines whether their health is worse than those who don't live in close proximity to polluters, whether they are receiving officially sanctioned levels of poisons are not.

The reason the second type of study is a truer snapshot of reality is because we keep finding out that levels of poisons we thought were safe turn out not to be safe at all. Go back even 20 years to the Exide lead smelter in Frisco, or 30 years to the RSR lead smelter in Dallas. Regulators and industry were routinely saying that levels of lead being released by these facilities were "safe." As it turns out, they were not. In fact, science now says there's no level of exposure to lead that cannot do harm to a person, particularly a child.

This learning curve can be applied to many, many types of chemical exposures over the last few decades, including Benzene, and other poisons routinely released by the gas industry. And it's why industry never wants to test its hypothesis about "safe" levels of things in the air with studies of what the actual health of people who live near their facilities is really like.

In reality, the best epidemiological studies to date, those that ARE done by third parties and ARE peer-reviewed an journal published, all conclude that living near gas mining operations increases the likelihood that you'll get sick. That's the state of the science. It's the same kind of science that proved cigarette smoking causes cancer. And that's why industry wants to stick to telling you about how safe the levels of poisons are in the air.

But forget all of that. Let's just take this "study" thing at face value. There was a 100 minutes of sampling of the air in 2012 at a gas pad site before drilling started, and in 2014, there were three 30 minute samplings of air around 600 feet away from the pad site after drilling had begun, and one sampling site well away from the pad to function as a background reading. That's it. That's the entirety of the study: the comparison of this "before" and "after" short term sampling.

Now if you were a high school chemistry nerd looking for a shot in the local science fair, you might insist that the procedures and testing protocol be the same for the before and after sampling. And you'd be right. But this study didn't bother.

In 2012, the sampling looked at Volatile Organic Compounds (VOCs), Sulfur Compounds and Formaldehyde "and other Carbonyl Compounds." In 2014, the sampling only looked at VOCs. so, only one-third of the original 2012 testing was duplicated. You'd think they were trying to intentionally ignore some poisons or something.

But it gets better. There were 15 separate VOCs sampled for in 2012, but only six, (less than half and only barely more than a third), of those were sampled for in 2014. In other words, the 2014 sampling not only left out two-thirds of the 2012 contaminant categories, it left out most of the chemicals in the one category it did sample.

In 2012, you had a total of 100 minutes of sampling of air in the middle of the pad site. In 2014, you had three 30-minute samplings of air 600 feet away from the pad site. They couldn't even replicate the sampling time.

As Texas Sharon has already pointed out, you might want to do your sampling with the same general kinds of weather – circumstances that might promise a representative sample.  But no, not for this "study." There was only a trace of rain recorded at the site in 2012, but between half an inch of rain and two and a half inches of rain in the 2014 sampling. Of course, rain being in the air and all, that could affect your air sampling results.

The average wind speed was 6 to 11 mph in 2012, while in 2014, it was, well, the second report really doesn't say what the average wind speed was. It just says that the wind speed varied from 0 to 21 along with wind direction. But who needs details for real science right?

In 2014, none of the background samples were the highest levels of exposure found, that is, the highest readings of all chemicals found were downwind of the pad site.

Of the six VOCs sampled for in both 2012, and 2014, three were significantly higher in 2014.

Benzene was almost 4 times higher in 2014: .13  vs .49.

Toluene was almost three times higher in 2014: .35 vs .91.

Methyl Ethyl Ketones increased by a third: from .53 to .72.

And mind you this was in the rain with gusts up to 21 mph. Only m,p Xylene and Carbon Disulfide were lower in 2014.

In all, these chemicals were detected despite the crappy methodology used:

  • Benzene
  • Benzene, 1,2,4‐trimethyl‐
  • Benzene, 1,3,5‐trimethyl‐
  • Benzene, 1,3‐dichloro‐
  • Benzene, 1,4‐dichloro‐
  • Carbon disulfide
  • Carbon Tetrachloride
  • Cyclohexane
  • Ethane, 1,1,2,2‐tetrachloro‐
  • Ethane, 1,1,2‐trichloro‐1,2,2‐trifluoro‐ (Freon 113)
  • Ethylbenzene
  • Furan, tetrahydro‐
  • Heptane
  • Methyl Butyl Ketone (MBK)
  • Methyl Ethyl Ketone (MEK)
  • Methyl Isobutyl Ketone (MIBK)
  • Methyl Methacrylate
  • Methylene Chloride
  • Naphthalene
  • o‐Xylene
  • m,p‐Xylene
  • Styrene
  • Tetrachloroethylene
  • Toluene
  • Trichloroethylene
  • Trichloromonofluoromethane (Freon 11)

That's reassuring right? That's what the industry folks are saying, because guess what, they're all at levels below what TCEQ says are OK for you to breathe – for a total of 30 minutes per sample. Unfortunately, most of us have a hard time breaking our habit of breathing all the time. Everyday. For years on end.

Look, you don't need to be a scientist to know how full of holes this slap dash attempt at CYA actually is. Industry is just throwing one thing after another up on the wall and hoping it sticks for the time it takes for the Mansfield City Council to justify its rejection of the citizens' revisions. Especially the 1500 setback originally requested.

Industry keeps saying that this distance amounts to a "defacto" ban of drilling, but that's clearly not the case in Mansfield. It's own literature touts the fact that a rig can be more than a mile away from the gas deposit its mining. You can put a rig in an industrial zoning tract and still reach a pocket of gas underneath a neighborhood without the surface components being anywhere near each other.

So what's the real reason industry oppose these setbacks for heavy industry that would be more than appropriate for any other kind of heavy industry? It's because the gas industry doesn't want to be grouped with lead smelters, and cement plants, and refineries and other kinds of heavy industry. It operates under an industrial exceptionalism that's unique in the modern era. It wants to be viewed as the kindly, well-landscaped heavy industrial polluter. Because when you start seeing it differently, all the carefully-constructed mythology surrounding its operations becomes transparent – just like it did with lead smelters, cement plants and refineries.

Because of its massive infusions of cash and resources overwhelming Mansfield in the last couple of weeks, the industry may indeed forestall the inevitable a little longer in what it considers a jurisdiction that's bought and paid for several times over. But science marches on – the real sort – and it's not going to be very kind to this industry in the longer run. Even the Marlboro Man had to hang up his spurs. It's just a matter of time before this industry is viewed as just another nasty polluting cause of illness, even by those who've benefited from it the most.

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Pinochhio(Mansfield) — Residents in this Fort Worth suburb seeking a more modern approach to gas industry regulation seemed to have hit a raw Barnett Shale nerve.

A decision last month by the city council to postpone permitting of a giant new multi-well and compressor facility in Mansfield, pending development of a new gas ordinance, has spurred the largest and most expensive industry PR offensive since the fight over the Denton fracking ban vote last November, including a city wide “push polling” campaign that contain ad hominem attacks on local advocates.

“I guess we should be flattered that our efforts have attracted so much attention from the national gas organizations,” said Tamera Bounds, one of the targets of the industry’s efforts. “But the fact is, this is a matter for Mansfield residents, and over the course of the last nine months as we’ve been working with the city council on drafting a new drilling ordinance, to our knowledge not one Mansfield resident has addressed the council in favor of the old ordinance. Now, at the last minute, these national trade groups show up and pretend their speaking on behalf of our local interests. They aren’t.”

Although Bounds group began meeting in June 2014, and a city wide forum on a new gas ordinance was held in December, it’s the unanimous January 26th tabling of Edge Resources’ huge, 34 well, compressor, dehydrator, and storage tank complex by the Mansfield city council on its third and final reading that apparently has the industry worried they’re losing their influence in a town so deep in the Barnett Shale.

On the eve of the first reading of the newly drafted ordinance this coming Monday, Mansfield residents are getting calls from a number registered to The Woodlands-based Promark firm asking them to take part in its “survey” on Mansfield drilling issues. Promark is a notoriously partisan company with a pockmarked reputation. In 2004, Promark’s polling tactics were investigated by the American Association of Public Opinion Research for unethical polling practices. According to the AAPOR, push polls are “an insidious form of negative campaigning, disguised as a political poll. 'Push polls' are not surveys at all, but rather unethical political telemarketing — telephone calls disguised as research that aim to persuade large numbers of voters and affect election outcomes, rather than measure opinions.”

That certainly describes the line of attacks that were posed as questions asked during the company’s Mansfield calls, including If the ordinances are passed, did you know that the City taxes could be raised? Knowing this, would you support a new ordinance?” and “If ordinances are passed, did you know that schools would loose a lot of funding? Did you know that property taxes will go up?”

Despite these scare tactics disguised as a “survey,” no part of the ordinance would affect current facilities. It’s aimed only at new permits. Residents have requested better monitoring and enforcement as well as a more protective 1500-foot setback from homes, schools and other “protected uses” to replace the 600-foot setback requirement established in 2008.

Perhaps most disturbing are the personal nature of some of the push polling questions. For example it asks whether respondents “agree that the clean air activists are a nuisance to the city?” and then whether Mansfield Gas Well Awareness Group leader Bounds is “credible, somewhat credible, or not credible”

Besides Promark’s push polling, which no trade group has yet claimed responsibility for, industry representatives are also suddenly showing up in Mansfield trying to drum up supporters among the local business community.

This Friday, Austin-based Luke Legate of the “Joint Association of Oil and Gas Education Initiative” is speaking to the Mansfield Business Association. The Initiative is a state wide industry trade group alliance that includes the Texas Oil & Gas Association, Texas Royalty Council, Texas Independent Producers and Royalty Owners Association, Panhandle Producers and Royalty Owners Association, Texas Alliance of Energy Producers, Foundation for Energy Education, Texas Pipeline Association, Permian Basin Petroleum Association, and the South Texas Energy & Economic Roundtable. He’s never appeared before the Mansfield City Council.

Next Thursday, it’s Ed Ireland, Director of the Barnett Shale Energy Education Council speaking to the entire Mansfield Chamber of Commerce at the Walnut Creek Country Club. The BSEEC describes itself as “founded by consortium of leading Barnett Shale production companies.”  He was invited to the December forum that kicked-off the review of the new ordinance, but has not appeared at any of the regularly scheduled council meetings where gas was a topic since then.

“What’s ironic is that these are the very groups that rush to claim that “outsiders” are somehow responsible for stirring up local residents concerns, when it’s actually the industry’s own poor track record on the ground that’s promoting our activism,” said Erik Orsak, another Mansfield citizen leader of Mansfield Gas Well Awareness. “After months of good-faith negotiations between the city and concerned residents, we see this last-minute massive top-down wave of attacks by national trade groups invading Mansfield without any previous local support in an a attempt to try and undermine that process. It’s these industry groups that are the outsiders.”

Monday’s city council meeting will feature the “first reading” of a proposed ordinance and include a public hearing on its contents. While Mansfield Gas Well Awareness members say they’ve been pleased with the progress on some issues of concern to them, two of the most important, reducing harmful emissions and longer setbacks, have not been resolved to their satisfaction. Last month, they reminded the city council that Mansfield officials originally called for 1000 foot setbacks in 2008, but those got reduced after intense industry lobbying.

In fact it was the owners of Edge Resources, the same company some residents think is behind this wave of new industry lobbying after their permit was temporarily tabled in January, that wrote in an April 2008 letter to the Mansfield Planning and Zoning Commission and suggested that schools should have shorter setbacks “because children are very mobile.”

“It would be a shame if Mansfield were to make the same mistake twice based on industry bullying” said Lance Irwin, a Mansfield Gas Well Awareness member and a frequent critic of the industry’s operation in town. “Mansfield’s future is its children, its schools and its neighborhoods. We need to protect them as best we can.”

Monday’s city council meeting begins at 6:30 pm at Mansfield City Hall, 1200 East Broad Street  

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Stacks of evidence Wednesday of last week saw the deadline for filing official comments on the dreadful "plan" the Texas Commission on Environmental Quality has proposed to lower smog levels in DFW by 2018. In effect, the plan is to wait for federal gasoline changes in 2017 and hope for the best.

Shortly before closing time Wednesday, Downwinders at Risk and the Lone Star Chapter of the Sierra Club submitted 62 pages of criticisms concerning the plan. Not because either organization believes the TCEQ Commissioners will change heir minds, but because we're trying to establish a record that might eventually lead to a court challenge of the plan.

Although lengthy, the basic approach of the groups is two fold – call into question the state's computer modeling that's predicting success and challenge the state's exclusion of new pollution control measures on the Midlothian cement plants, East Texas Coal plants and Barnett Shale gas compressors.

Some of the highlights:

 – The computer modeling the TCEQ is using for its new plan is the same it used for plans in 2006 and 2011, neither one of them successful at meeting its goal of cleaner air by the assigned deadline. In fact, the last clean air plan using this same model underestimated smog levels by almost 10 parts ber billion and actually saw a slight rise in smog at its conclusion – the first time a DFW plan ever resulted in higher ozone levels.

 – In defiance of EPA guidance, the computer model TCEQ is using is more than five years old. EPA specifically recommends using an "ozone season" from 2009 to 2013. TCEQ's model is leftover from 2006, or three years older than the oldest year EPA says is appropriate. 

 – Also contrary to EPA rules, the TCEQ 2006 computer model ignores including the most relevant “meteorological conditions conducive to elevated air quality.” 2011 was the worst year for ozone levels in DFW since the beginning of this decade, in large part because it reflected the worst drought conditions. The three-year rolling average for the worst monitor, called the "design value" rose back up to 90 parts per billion after years of floating in the mid to upper 80's. But instead of using that year as a worst case baseline, the state defaulted to its 2006 model that doesn't incorporate the current drought.

 – TCEQ's prediction of success is built on a series of unrealistic assumptions about the quantity of oil and gas pollution. For example, it underestimates the number and impact of air pollution from hundreds of large compressor stations and thousands of smaller "lift" compressors as the Barnett Shale ages. Fully 60 to 70% of all air pollution from the gas industry comes from these kinds fo facilities, so a mistake in estimating their impact could have a large chain reaction at downwind air quality monitoring sites in Tarrant, Denton, Parker and Johnson counties. 

TCEQ also assumes that production levels in the Barnett will fall steeply. If they do not, there could be hundreds of tons more air pollution from the industry annually than what TCEQ assumes in its model.

That's important because the model predicts that the region will only barely squeak-by the 75 ppb standard required by 2018, with levels coming in at 75.87 at the Denton monitor site, 75.15 at Eagle Mountain Lake, and 75.04 in Grapevine.  A jump in oil and gas pollution – or any other surge in pollution from any other source – could make those numbers obsolete and ruin our chances fo complying with the Clean Air Act on time…again.

- TCEQ's "Contingency Measures" are illegal. Every smog plan must have a series of quantifiable back-up contingency pans in case the options the plan relies on fail to achieve success. In this case, the state is only relying on unquantified and voluntary actions, such as "incentive" programs, the effectiveness of which cannot be measured. Since you can't measure them, you can't count them.

- TCEQ failed to consider all "reasonably available control technologies" and "measures." Nearly 40 pages is devoted to the wrong-headed, irrational, and illegal way TCEQ rejects off-the-shelf air pollution controls for the Midlothian cement plants, East Texas coal plants, and large gas compressors.

Under the Clean Air Act, a state's plan shall provide for the implementation of all reasonably available control measures as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonably available control technology) and shall provide for attainment of the national primary ambient air quality standards.” In order for the EPA to determine whether an area has provided for implementation as "expeditiously as practicable,” the State "must explain why the selected implementation schedule is the earliest schedule based on the specific circumstances of that area. Such claims cannot be general claims that more time is needed but rather should be specifically grounded in evidence of economic or technologic infeasibility.”

Step-by-step, Downwinders and the Sierra Club explains why Selective Catalytic Reduction (SCR) is a reasonable control technology for the Midlothian cement plants and East Texas coal plants. Even as the owners of one of the Midlothian cement plants applies for a permit to install the technology, TCEQ is claiming its still not ready for prime time. The groups demonstrate how requiring SCR on these major polluters would have a large impact on DFW ozone levels.

The same level of absurdity if reveled in TCEQ's rejection of electrification of gas compressors. Despite being able to significantly lower smog-pollution in the very areas where its needed most, and despite electrification even being required by many Barnett shale municipalities, the state maintains that this option is unrealistic and unachievable.

There's probably no better compendium of the various sins committed by the TCEQ plan than these comments. If you're looking for the most solid case for compressor electrification, or SCR adaptation, or just TCEQ malfeasance, this is your one-stop shop.

You may think this is a technical document, or one full of legal mumbo-jumbo. It's not, at least not for the most part. Instead it's the kind of logical, evidenced case you'd assemble for a debate with the TCEQ. It's a blow-by-blow comprehensive look at why the state isn't any more likely to meet this clean air deadline than it has any other. A case we hope is capable of persuading EPA to reject the TCEQ plan. 

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Citizens Clean Air Posse Swearing-In. Check

Doctors speaking out. Check

Cute kids. Check

Concerned Mothers. Check

Info on how you can still make comments to EPA in support of a lower ozone standard. Check

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spew-stillThere was at least one truth uttered by Steve Everley, the professional PR spokesperson for Energy in Depth, itself the PR arm of the Gas Industry, during his testimony at last Thursday's EPA ozone standard hearing in Arlington:

"…natural gas producers will be significantly impacted by EPA’s proposal to reduce the National Ambient Air Quality Standard for ozone from 75 parts per billion to between 65 and 70 ppb."

Indeed. At the rate things are going in Austin and DC, it might be the only thing to impact the industry's large emissions of pollution for many years to come. Left unsaid by Everley was why the industry would be impacted by such a lower ozone standard – because in many parts of the country now, including the DFW area, smog-forming pollution from the gas industry is contributing significantly to higher ozone levels.

Even the governmental affairs branch of the gas industry, otherwise known as the Texas Commission on Environmental Quality, admits that facilities like compressors, storage tanks, pipelines, and de-hydrators found by the thousands in the western part of the Metromess contribute more smog-forming Volatile Organic Compounds (VOCs) than all the "on-road" vehicles in North Texas combined. This is true not only at the present time, but will be true at least three years into the future, according to TCEQ's own estimates.

Gas facilities also account for the third largest source of smog-forming Nitrogen Oxide pollution in DFW, according to TCEQ numbers included in their recent air plan submitted to EPA – only a ton per day less than all "non-road" vehicles in North Texas like construction equipment, and well ahead of "point sources" like the Midlothian cement kilns and local power plants.

In all, TCEQ predicts that 35,335 tons per year of smog-forming pollution will still be coming from the region's gas industry in 2018. That's a lot. It's so much that, as the TCEQ also demonstrates with its computer modeling, even a tweak here and there in gas pollution estimates can make big differences in the levels of ozone at monitors in places like Denton and Keller and Eagle Mountain Lake – traditionally the worst-performing air quality monitors in North Texas.

And that's why a lower ozone standard is a threat to the industry. The very air quality monitors the industry affects most with its pollution are the ones driving the region's high smog levels. Lowering the ozone standard means it would have to spend money to reduce those emissions significantly. It means it would have to spend money to prevent the kind of huge "accidental" releases of smog-forming pollution released by the Mansfield compressor on Thursday even while Steve Everley was testifying to EPA.

After giving her own testimony to EPA on Thursday morning, Earthworks' Sharon Wilson and Mansfield Gas Well Awareness board member Lance Irwin headed out to the Summit Midstream Partners Compressor Station behind Mansfield's Performing Arts Center, with an infrared, or FLIR "thermal imaging" camera. Such a device is capable of recording the kinds of VOC emissions that are often smelled and inhaled by surrounding residents, but can't be seen with the naked eye.

The Summit compressor and the two nearby Eagleridge gas wells have been the scene of many different complaints from the surrounding Mansfield neighborhood – everything from airborne foam landing in backyards to oily deposits landing on car finishes. On Thursday, Wilson and Irwin were responding to a new series of complaints about awful smells. When they showed up, what the two recorded was a massive "emergency blowdown" (versus the "planned" kind). While filming the event, Wilson suffered health effects familiar to gas facility neighbors and was overwhelmed by the obvious hydrocarbon fumes. Once you see her video, you understand why:

Such a blowdown was exactly what Lance Irwin had warned the Mansfield City Council about only three days before, during comments directed at slowing down or denying the permit for a new compressor, 34 wells, 12 tanks and a assortment of other facilities at an Edge pad site near Debbie Lane in town. He pointed out that industry and government estimates about emissions never take these kind of catastrophic events into account – form a short-term toxic exposure perspective, or as it turns out, from an air quality, smog-creating perspective. And he's right.

In this regard, these kinds of accidents are no different than the infamous industrial "burps" from refineries and chemical plants along the Houston Ship Channel that lead to smog spikes downwind. There are 650 large compressor stations in the DFW "non-attainment" area. How many are experiencing blowdowns on any given day? How many are affecting ozone levels in the spring and summer? The TCEQ estimates included in its DFW air plan don't even try to quanify them.

Because gas facilities like compressors are subject only to "standard permits," are located diffusely around a region, and don't officially emit a de minimus amount of air pollution, they're not subject to the federal rule of off-setting. That's when a new polluting facility locates in an already smoggy area like DFW and has to pay to cut smog pollution elsewhere if it wants to emit the stuff itself. If a new cement plant or power plant were to locate in DFW, it would have to pay to reduce a ton and a half of smog-forming pollution for every ton it wanted to release. Gas facilities don't have to do this – even though collectively they emit more smog-forming pollution than all the cement plants and power plant in the non-attainment area!

EPA has tried to argue that a company's different facilities are all tied together and should be counted as a single source, and so subject to off-setting regulations. But the courts have ruled against them.

Rising gas industry pollution and the absence of any official brake on its growth like off-setting is a large reason, maybe the primary reason, why DFW hasn't seen the kind of air quality progress it should have by now. Until this last summer's cooler and wetter weather gave us relief, ozone levels had been stagnating or even rising since 2009 – or about the time the industry invaded North Texas in large numbers. There's no question that had the Barnett Shale boom not happened, we'd have much cleaner air by now.

But it did and we don't. And so that's why a lower ozone standard is perhaps the only way that the gas industry will ever be forced to clean-up its act – especially on the widespread regional level we require to get to safe and legal air. Just like it has with the Midlothian cement plants, the need for lower smog levels can force the state's and industry's to act to add controls. It's a long-term fight, but one of the only paths to across-the-board change versus the city-by-city slog activists have had to rely on.

National Resources Defense Council lawyer John Walke has a great takedown of Steve Everley's spin on Thursday. And the tireless cross-country DeSmogblog reporter and photographer Julie Dermansky has a good read on the Mansfield fight that you should check out. But the most compelling rebuttal to both industry PR and local governments who want to ignore their own responsibility in this mess is probably Wilson and Irwin's two and a half minutes of video.

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Health BadgeThere's still some five-minute speaking slots available for Thursday's all-day EPA National public hearing at Arlington City Hall on a new ozone standard  – mostly in the afternoon and evening. So if you haven't signed up yet, please do so. The EPA staffers will stay as long as there are people who want to testify. So if you get off work and want to come over and speak out at the last minute – you can. Some of you may remember the 2009 national cement plant hearing where we had almost 100 speakers and kept things going until 8:30 pm. We need to repeat that performance.

To sign-up today, e-mail EPA staffer Eloise Shepard at shepherd.eloise@epa.gov Or just show up on Thursday in Arlington and grab an open slot.

As an added bonus and attraction, there's a special feature in at the end of the scheduled lunch break that may provide an incentive to attend. At 1:45 pm Downwinders will be sponsoring another mass swearing-in of its Citizens Clean Air Posse, complete with official badges. Because this is a national hearing, the original DFW-centric language from the earlier TCEQ hearing has been slightly re-written to read as follows:

As a member of the Clean Air Posse I pledge to do my duty to uphold the federal Clean Air Act and take responsibility to provide cleaner air to my fellow citizens – especially since the State of Texas doesn’t seem to give a damn anymore.

I pledge to help persuade the federal marshals at the EPA to make the State of Texas follow the law and provide safe and legal air to breathe.

I pledge to bring an end to the reign of lawlessness and disregard for public health, and the Clean Air Act, by the State of Texas, so help me God.

Membership in the posse entitles you to be your own Clean Air Act enforcer and make citizens' arrests of violators. It also allows you to join other members in organized round-ups to cajole and harass federal officials to do their job. Plus, you get to wear a nice-looking shiny badge while you're doing all of the above. But you don't get a badge unless you show up.

Immediately following the Posse swearing-in at 2 pm will be a panel presentation by at least three physicians coming to testify at the hearing. Because regardless of the politics involved in the decision to lower the federal smog standard, this is still a public health issue, one about how poisons in the air cause illness and disease among millions of Americans.

Dr. Susan Pacheo of the University of Texas Health Science Center in Houston specializes in Pediatric Allergy and Immunology and will speak to the threat posed by smog to children's health. Dr. John Kissel specializes in Internal Medicine in St. Louis, Missouri to discuss the impacts of smog of public health in general. DFW's own Dr. Robert Haley is a toxicologist at UT-Southwestern, and led last year's effort by the Dallas County Medical Society to close the oldest, dirtiest East Texas coal plants that affect North Texas air quality. He'll be speaking about the local impacts of smog on the air you breathe.

This is the closest thing to a rally for clean air as DFW has seen in some time, so please come out and be a supporter if you can make it. EPA needs to receive the very strong message that the public wants safe and legal air to breathe – especially in states like Texas that will never pursue that goal on its own. Your presence at the hearing tomorrow is a direct rebuke to the Texas Commission on Environmental Quality, Governor Greg Abbott, and every other Texas elected and regulatory official who takes the position that our air is just fine the way it is. Don't give them aid and comfort by sitting this one out. Show up and add your voice to those saying that Austin doesn't represent us in this battle.

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possibleattainable-1Something strange happened on the way to losing the battle in order to win the war. The battle was won. At least for now.

It wasn't a permit denial. It wasn't a ban. It wasn't even a new ordinance. But the Mansfield Gas Well Awareness group pulled off their first significant victory at the council level Monday night when a third and final reading of a new 34 multi-well pad site, plus compressor, plus storage tanks, plus dehydrators, plus re-boilers, plus separators, gas-industrial-complex that seemed like a done deal only 30 days ago was unanimously tabled until new rules for drilling in the city are put in place later this year.

Edge Resources' original Special Use Permit, acquired in 2008 (before the passage of the current gas drilling ordinance with its 600-foot setbacks), and hosting 2 current wells, had expired over a year ago. Yet instead of going back through the Planning and Zoning Commission and applying for a new SUP, the company pursued an unusual side deal with the city council that would allow "renewal" of the site permit with the two wells, plus permission for an additional 34 wells, a compressor, and a lot of other facilities only 3-400 feet from current homes –  in exchange for setting-aside some acreage next to this gasland extravaganza for "parkland." How could the council refuse?

Moreover, unpublicized negotiations for this swap were going on even as the council met on December 3rd to begin "an open dialogue" with the MGWA group at a special workshop to initiate a new gas drilling ordinance, including a request for a new setback of at least 1500 feet. No mention was made that night by any city official that the massive Edge Resources site reauthorization that undermined that request was in play. The first time residents learned about it was when it appeared on the council agenda the very next day for a "first reading,"re: approval.

Two weeks ago, the permit came up for a "second reading" and residents rallied. This time there was some news coverage and new opponents showed up at City Hall to speak against the renewal while a new ordinance was being considered. With gas prices at historic lows, the question was repeatedly asked, "What's the rush?"

In the glare of the spotlight for the first time, council members now sought new assurances from the company that the nice slide show about site development they were seeing actually represented what the city would be getting. Instead, all the company would say was that that level of industry best practices "could be deployed." With emissions from the proposed wells estimated at up to 13 tons per year alone, this was of more than passing interest to residents. City council members might have thought they heard real commitments, or maybe just pretended to hear them. Either way, the stage was set for final approval at the third reading at the end of the month.

Even though they were protesting the permit, Mansfield group members were so used to seeing their concerns discounted by an unresponsive council that they had no hope of actually stopping or delaying it. Still, they trudged on, wanting to turn this fight into an example of what was wrong with the current ordinance and get some mileage out of certain defeat. Lose the battle, win the war. They passed out fliers in surrounding neighborhoods, they met with individual council members, they sent out social media alerts. They put themselves in a position to be lucky, just in case.

On Monday night, more allies of the group came to City Hall for the third and final reading of the gas permit, along with opponents of a new medical waste transfer and sterilization facility that wants to set up in town. Now the council had a new problem. On the one hand it had a history of punting to the state over health concerns about drilling. Austin had the "experts" and the experts had claimed it was OK. On the other hand, those same Austin experts had now claimed the very, very unpopular newly-proposed medical waste facility was hunky-dory as well.  What to do?

Getting tough in front of the crowd, the Council pressed Edge for promises it would abide by all provisions of a new gas ordinance save any new setback requirements (since the new wells would be even closer than the current 600 foot setback normally allows). Edge countered with a carefully and lawyerly-crafted statement that left them an out to such a promise, seemingly in contrast to what the company had committed to only two weeks earlier – but only if you weren't listening. Remember, those state-of-the-art practices "could be" deployed – not necessarily had to be.

It became painfully clear why the city needs all operators and all wells to adhere to a routine SUP process instead of working side deals on its own behind closed doors. Even so, last year such a permit request would have sailed through the council. This year, the organizing done by the Mansfield Gas Well Awareness Group made it harder for business as usual to take place. Much, much harder.

The Mayor and council members signaled their frustration over the lack of a clear yes or no commitment from Edge to go along with a new ordinance. After recessing into executive session and giving the company's lawyers almost an hour to work up the nerve to approve conditional acceptance, the council came back and still confronted the same kind of wiggle-room language they were trying to avoid. As a result, the "done deal" got undone at the last possible minute, and the council voted unanimously to table the third and final reading of the permit renewal until after adoption of a new gas drilling ordinance. For the first time in two years, Mansfield residents got what they had asked for when it came to a gas well permit.

It's only a delay. And the stubbornness of Edge's lawyers is as responsible as any thing else for the win. And the really big war over a new ordinance is about to start with most of the council seemingly unwilling to retreat from a "Fort Worth model" 600-foot setback. But better to start such a war with an unexpected victory in battle than a routine loss, plus a lesson about what can be accomplished if you work hard enough to be lucky.

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All Day NATIONAL Public Hearing on a New Federal Ozone Standard

Thursday, January 29th, 9am to 7:30 pm

Arlington City Hall, 101 W. Abram

There are only three national public hearings on the possibility of lowering the national federal ozone, or smog, standard. One is in Washington DC, another is in Sacramento, California and the third is right here in Arlington, Texas. We need everyone that can come and speak for 5 minutes on the importance of cleaner air to do so. You know industry and elected officials hostile to the EPA and the Clean AIr Act will be well-represented

To secure your 5-minute speaking slot, e-mail Eloise Shepard and ask for one in the time period during the day on Thursday most convenient for you. Please do it asap: shepherd.eloise@epa.gov.

There are at least two very good reasons why North Texas residents should support a new lower smog standard of 60 parts per billion – the lowest standard under consideration by the EPA.

CHAPPs study result1. DFW has Epidemic Childhood Asthma Rates 

According to a first-of-its kind survey in 2008 by Cook Children’s Hospital, one out of every four DFW children ages 5-9 suffered from asthma. That was more than twice the national average, and more than three times the average for the state of Texas. Asthma is the most common cause of missed school days and is one of most common causes of Emergency Room visits and hospitalizations.

The DFW Hospital Council estimates nearly 1500 children in Dallas County visited an emergency room or were admitted to a hospital due to asthma in 2012. Dallas County has the highest number of child asthma hospitalization in the state.

According to EPA itself, a new 60 parts per billion (ppb) standard for ozone would eliminate roughly 1.8 million asthma attacks, 1.9 million missed school days, and 6,400 premature deaths nationwide – 95% of all ozone-related deaths. Few regions would benefit more from such a lower ozone standard than DFW.

2. It’s One of the Few Ways to Force Reductions in Harmful Air Pollution in Texas plumes-of-dark-smoke-are-released-into-the-air-from-a-smokestack copy

Texas is a place where industry rides rough shod over state regulators and citizens don’t have a level playing field to seek relief from the adverse health consequences of air pollution. Tougher federal ozone standards are one of the only ways to reduce air pollution from large local sources like the cement kilns in Midlothian, gas facilities in the Barnett Shale, and coal plants in East Texas.

Lower federal ozone standards over the last two decades, combined with grassroots campaigns have resulted in the lower volumes of smog pollution from the Midlothian cement kilns, plus reductions in other kinds of harmful pollution from the kilns as well, like particulate matter, and carcinogens. A new 60 ppb ozone standard would mean the kilns would have to add state-of-the-art controls to bring down those totals even more – to as much as 90% reductions. The same is true with the East Texas coal plants and with polluting gas facilities. To get down to 60 ppb ozone levels in DFW could mean deep cuts from the largest sources of industrial air pollution in North Texas. Something that probably won’t happen without a new, lower federal ozone standard.

And that won't happen without a lot of you showing up on Thursday to say you want and need cleaner air to breathe. Reserve your 5-minute speaking slot now. It's a good investment if you live in Texas.

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DFW Childhood Astham Rates

 

All Day NATIONAL Public Hearing on a New Federal Ozone Standard

Thursday, January 29th, 9am to 7:30 pm

Arlington City Hall, 101 W. Abram

(To secure a 3-minute speaking slot, e-mail Eloise Shepard and ask for one in the time period most convenient for you. Slots are going fast (and not necessarily to citizens), so do it asap: shepherd.eloise@epa.gov)

It's Round Two of January's clean air public hearing marathon, and the biggest has been saved until last.

One of only three national public hearings on lowering the federal ozone, or smog standard, is taking place here in DFW, at Arlington City Hall all day next Thursday January 29th, from 9 am to 7:30 pm.

Last week saw a state-sponsored hearing on another TCEQ do-nothing DFW clean air plan. But the state wouldn't even have to pay lip service to such plans were it not for the requirement to meet a federal ozone level and the region's inability to do so over the last two decades. 

Lowering the federal ozone level means it will be tougher in the future for the state to claim it doesn't have to implement any new pollution controls on cement kilns, coal plants, or gas facilities. More importantly, enforcement of a tougher standard means better public health: fewer "bad air days," fewer asthma attacks, fewer trips to the emergency room because your child can't breath, and fewer deaths caused by dirty air. 

That's important because reports like the child heath survey from Cook Children's hospital in 2009 showed that childhood asthma rates in DFW were twice the state average and almost 10% higher than the national average. It called the prevalence of asthma among local children an "epidemic."

Currently, the national ozone standard is 75 parts per billion (ppb) – which DFW is still at least three years away from reaching even under the rosiest of scenarios. (Right now our average is 81 ppb, and that's only because of a wetter and cooler summer in 2014). But that 75 ppb number is a political compromise – not one grounded in science. Based on public health studies the EPA's own independent board of specialists has recommended a range of 60 to 70 ppb at least three times since 2008, with an emphasis on the lower end of that range. Now it looks as if the EPA is finally willing to follow through on that recommendation.

EPA's national ozone standard sets the goal of cleaner air that every state must work toward. It drives all new clean air plans. like the one the state of Texas is proposing for DFW right now. The lower the standard, the more pollution has to be reduced. The more pollution has to be reduced, the more controls have to be added to major sources of air pollution to get that reduction. That's how you get long-term clean air progress in states like Texas that refuse to act on their own.

A significant reduction in the federal standard – from 75 (ppb) to as low as 60 ppb would make it much, much harder for Texas to avoid new controls on industry. To give you some idea of how much harder, consider that the state's "plan" for compliance with the current 75 ppb level is completely dependent on a new EPA gasoline mix coming onto the market in 2017. Even then, it's own estimates say that it won't get down below 75 at least three or four monitoring sites. Just one monitor site out of compliance means the whole region is in violation. Short of a huge rise in the use of electric cars, more huge decreases in vehicle pollution aren't expected. Additional significant drops in smog that would be required under a new, lower standard would have to include controls on major industrial sources – like the cement kilns, coal plant and, yes even gas facilities.

When you have a much lower ozone standard, you have to reduce smog by addressing ALL sources of air pollution. 

Finding a way to comply with a lower national ozone standard is how more modern pollution controls were mandated almost a decade ago at the Midlothian cement plants. Meeting that new ozone standard meant pollution from the kilns had to be reduced and that made it more possible for Downwinders' "Green Cement" campaign to work with local governments. Today, there are no obsolete "wet kilns" left in Texas – they've all been replaced with more modern dry kiln operations. This has resulted in a reduction of hundreds, even thousands, of tons of smog-forming air pollution from these huge sources every year. We still have to require state-of-the-art Selective Calaytic Reduction (SCR) on the kilns, but they're releasing far less pollution than they were even five years ago because they've had to comply with a new federal ozone level. 

With a new, lower ozone standard, the same could be true of new controls on gas facilities, like the 650 large compressors in North Texas, and the East Texas coal plants. That's why it's important for Texas residents to fight for the lowest possible standard this time around. When you testify, please make sure you request a new standard of NOT MORE THAN 60 PARTS PER BILLION.

According to a recent EPA staff analysis, an ozone standard of 60 ppb would reduce asthma deaths in the US by 95%, compared to only a 50% reduction under a 70 ppb level. If you want air that can eliminate all but a small fraction of respiratory problems associated with outdoor pollution, you need to press for a 60 ppb standard.

Needless to say industry is fighting back hard against such a standard, using its usual doom and gloom forecasts of economic hardship. This is the same argument that was used against the current ozone standard – the one we have now in the middle of the biggest economic boom in a decade. In fact, the technology for bringing down pollution levels currently exists in many industries – including kilns, coal plants and compressors. It's not experimental and it's not too expensive to use, as demonstrated by its use right now in those industries.  We just have to require its use in states like Texas that are refusing to implement progress. That's why this new standard is so important – it will make the state take action it would not otherwise take. It's one of the only ways citizens who care about cleaner air in Texas can force progress.

Likewise, the Texas Commission on Environmental Quality's own toxicologist, Michael "Smog Ain't Bad For You" Honeycutt will also be testifying. TCEQ knows that a lower standard will force its hand on new controls. It will be pulling out all the stops to use its influence and that of sympathetic elected officials to scuttle any change. Using ideologically-based arguments supported by industry-financed studies, the TCEQ will say there are no real benefits to reducing DFW smog. Those of you that know better have to show up and say so.

Speaking slots for the 29th are going very fast. Industry will be well-represented. Please don't get left out.  We need your voice that day to call for a 60 ppb national ozone standard. E-mail the EPA at shepherd.eloise@epa.gov and reserve your time today.

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Dallas smog aerial croppedYou don't have to have any special technical knowledge. You don't have to know regulatory or legal jargon. You just have to believe we still have a problem with smog in Dallas-Fort Worth. That's all it takes to participate in the air quality extravaganza happening tonight in Arlington. It's a rare two-for one chance to help the fight for cleaner air.

Public Hearing on the State's New DFW Air Plan 6:30 pm Tonight, Arlington City Hall, 101. W Abram                                        

All you have to do is sign-up to speak, wait for your name to be called, and tell the state and the EPA representatives who'll be present that you want something better than a clean air plan that does nothing to get cleaner air except wait for a new federal gasoline formula to hit the market a year before the plan's deadline. The more people that do this, the more pressure EPA is under to reject this terrible state plan. Nothing fancy. Just show up and say you want better – that this region deserves better after two decades of being in violation of the Clean Air Act.

Click here to send prepared written comments to the state and EPA. You can add your own as well.                                                      

Roasting and Toasting of Retiring State Representative Lon Burnam – A Fundraiser for Downwinders at Risk, 7:30 -10 pm, Tonight, South Street Patio, 400 South Street – about four blocks east of Arlington City Hall

If you think DFW smog is still a problem, after you say your piece at the state hearing come and support the only group committed to trying making its elimination a priority – Downwinders at Risk.  Since the mid-1990's we've been using these air plans to raise issues, get information, and sometimes even win victories that actually do lead to cleaner air. A big reason there's no more burning of hazardous waste in the Midlothian cement plants, and all of those cement plants have upgraded their equipment is because of the work we did around smog. Lately, we've been using them to drive home how much gas and oil pollution contribute to regional smog.

But we need your help – in terms of attendance at public hearings, and in terms of financial assistance. For your donation of $35 to this roasting and toasting of Lon, you get an evening of entertainment and take part in a salute to a real local clean air hero.  And you make it more possible to keep challenging the status quo on behalf of your lungs.

CLICK HERE TO GET YOUR TICKETS ONLINE OR GET THEM AT THE DOOR TONIGHT

If you still think we have a smog problem, there's two things you can do about it tonight. Thanks.

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YoungerBroPosse1876(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.”

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flipflop111Pending Permit for an 18% Increase in City’s Well Count Wasn’t Disclosed to Citizens or Media at Special December 3rd Workshop on Gas Regulations

What: Mansfield City Council to Consider Large new Gas Facility Permit, including New Compressor Station on Debbie Lane

When: Monday Night, January 12th 7 pm

Where: Mansfield City Hall, 1200 East Broad Street 

Mansfield’s city council is scheduled to move forward tonight with a second hearing on a request from  Edge Resources to build 34 additional gas wells and a new compressor station despite a pledge by the council in December to  consider new ordinances designed to be more protective of public health, a process that is still ongoing and that concerned residents hope will reduce hazards posed by  drilling within the city.

Although City Hall had been working with Edge Resources for months on a renewal of its expired 2008 Special Use Permit that would raise the city’s well count by 18%, the Mansfield City Council and staff didn’t disclose that information to residents or the media when it convened a special workshop to discuss a new gas drilling ordinance on December 3rd.

It was very disappointing to know that while we were beginning good faith discussions on new ordinances with the Council, it had already made a decision to grant a second hearing to renew an expired permit that will significantly add to the number of wells and allows yet another compressor within city limits,” said Tamera Bounds, a Co-chair of of local citizen advocacy group, Mansfield Gas Well Awareness (MGWA).

City officials say they have no choice but to OK the renewal because the original SUP was filed before the city passed its current gas ordinance. But Bounds and others say the timing of council approval, and lack of transparency to the public about the permit makes the effort premature.

“Even if their hands are tied, they could wait until any revisions of the ordinance are in place and incorporate those changes into the Edge permit.” She specifically listed baseline air testing, vapor recovery, “flowback” control, and infrared camera monitoring as state-of-the-art features that every new gas facility permit should include.

Edge’s proposed permit calls for thirty-four additional wells to be drilled within 350 feet of homes near Debbie Lane with a new compressor and frack pond also constructed at the same site, where there are already two wells. Mansfield Gas Well Awareness is pushing for new ordinances with setbacks of at least 1500 feet between gas wells, compressors and homes.

Others were less circumspect in their criticism of what they called the council’s duplicity in dealing with residents. “It’s outrageous this pending permit wasn’t disclosed at the December 3rd council meeting called specifically to talk about how to regulate old and new gas facilities in Mansfield,” said Jim Schermbeck, Director of Downwinders at Risk, the local clean air group working with MGWA to change the city’s ordinance. “Even while City Hall representatives were talking about a dialogue with citizens to consider new regulations, they deliberately withheld notice about a huge new increase in gas drilling being requested.” He also called for a delay in council action on the permit until after a new ordinance was passed.

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alexander-pst mask 2
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.

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Irving Earthquake mapNo one really has any idea what's causing the "swarm" of earthquakes along the Irving Dallas border. What is known is that this is a new phenomenon. None of us who grew up here in the DFW area can ever remember having this kind of problem with the ground shaking – and certainly not with almost a dozen noticeable quakes in 24 hours.

Circumstantial evidence points to "human-induced seismicity" as the oil and gas industry folks call it, although one can't be certain. Ground zero for these earthquakes is along the Balcones Fault, about the oldest geographical feature in Texas – clocking in at one billion or so years old. It's the same fault that runs down Highway 67 and then I-35 by way of the limestone escarpment in Cedar Hill and Midlothian, the one the cement plants there mine for raw material. It snakes up to the Texas – Oklahoma border in less dramatic fashion, including along the Trinity River bottomland where the Irving/Dallas quakes are being recorded.

What's also known is that when you apply new pressures, or re-arrange the pressures, to an existing fault, you get movement. That why deep injection of anything – fracking wastes at a well disposal site or CO2 at existing wells, have been linked to triggering earthquakes – especially where there are already faults.

This is what was probably happening in December 2013 through January and February of 2014 in and around Azle, when that part of the Metromess was experiencing it's own earthquake "swarms." There are at least two injection wells in the vicinity that were at the center of many of the quakes and since their pressures and volumes have been decreased, those swarms have decreased as well.

We know that a couple of fracking waste injection wells at DFW airport on the edge of Irving were closed because of suspected links to earthquakes they were causing.

"And an earlier study by scientists at Southern Methodist University (SMU) and UT found links between disposal wells near the DFW airport and induced earthquakes for a series of quakes in 2008 and 2009. The study specifically looked at two injection wells in the area that were built in 2008. Seven weeks later, earthquakes started. “Were the DFW earthquakes natural or triggered by activities associated with natural gas production, most likely saltwater injection to dispose of brines?” the report asked. The study said yes, the “correlations are consistent with an induced or triggered source.”

Those DFW airport wells have been closed for years, but with millions of gallons of waste being stored deep underground, are they still capable of causing pressures on the Balcones and/or faults that feed the Balcones? We know less about the geology underneath us than we do the deep space above us.

In the middle of the earthquake swarm there are two gas wells on the University of Dallas campus - one that was producing until 2012 and one where the casing failed and shut down early on. They've been there since 2009 but we don't know the recent history of either.

No new drilling or injection activity is known to have occurred at or near the sites of the most recent earthquakes.

We've come a long way from the original perceived foil hat territory of fracking activity causing earthquakes. When many of us first heard about this association, it sounded like science fiction. Now we know it's science fact. Even the oil and gas industry concedes that injection wells have a connection to earthquakes. That's a huge change in the debate since only a few years ago.

What is less known, and what the industry does not concede yet, is that fracking alone has been linked to earthquakes.

A 2012 British study found fracking itself caused small earthquakes near Blackpool.

The report, undertaken by independent experts and commissioned by the UK’s Department of Energy and Climate Change, looked at the relationship between fracking operations by the Cuadrilla company at Preese Hall well, near Blackpool in Lancashire, and small earthquakes between April and May of 2011 – the largest a magnitude 2.3. The report agreed with previous studies that the earthquakes were caused by the process.

It said the stress in the fault was pre-existing and the hydraulic changes made by fracking initiated the earthquake sequence.

The same thing happened in Canada with fracking near the Horn River Basin.

"…a report released recently by the B.C. Oil and Gas Commission sheds light on the huge shale gas deposits in northeastern B.C. Quakes recorded by Natural Resources Canada ranged from 2.2 to 3.8 on the Richter scale, below the 4 mark and thus deemed minor.

"The investigation has concluded that the events observed within remote and isolated areas of the Horn River Basin between 2009 and 2011 were caused by fluid injection during hydraulic fracturing in proximity to pre-existing faults," the commission said in its report."

We don't know what's causing the Irving quakes, but we do know that fracking alone has been known to cause the size of earthquakes being recorded there now. To suggest that only injection wells have been linked to quake activity is just plain wrong.

We're messing with Texas geology in a way that we haven't before, in areas of the state where we haven't before. We really don't know what the long-term consequences of that messing are.

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Why We Fight: In 1996 and Now

by jim on December 29, 2014

Sacrificing Science for Conveneince Pic copyWe found a piece of Downwinder's legacy in a very unlikely place this month – on the desk of TCEQ Toxicologist Michael Honeycutt.

Right before Christmas, the Washington DC-based Center for Public Integrity published a great examination of how the Texas Commission on Environmental Quality goes out of its way to make sure the poisons citizens are being exposed to in the real world hardly ever reach "levels of regulatory concern." It spotlights Benzene, although you could easily find half a dozen other examples of where the state is moving the toxicological goalposts. This regulatory slight of hand is being directed by Honeycutt, the "smog isn't bad for you" guy that tries to provide the technical fig leaf for the blatant political motives behind the TCEQ's downplaying of pollution harms.

In the middle of the article is a photograph of Honeycutt at his desk with various reports splayed out in front of him. According to the reporter, she asked him to pull out some of the documents that have been influential in getting the TCEQ to re-examine the way it analyzes toxic exposures and human health harms. 

And what do you know, right there in front is Downwinders at Risk's own 1996 "Sacrificing Science for Convenience" report – the first-ever critical look at how the state of Texas was officially evaluating toxic exposures, authored by the late great Dr. Marvin Legator of the UT Medical Branch in Galveston and Jim Tarr, a former Texas Air Control Board engineer, who's become an independent consultant, and is in fact quoted in the Center's new article as well. 

This report, later turned into a peer-reviewed journal-published article, was a devastating methodical blow-by-blow examination of how the state's "Effects Screening Levels" (ESLs) for pollution were political tools for regulators to allow massive pollution without concern for any adverse human health effects. It led to an embarrassing Houston Chronicle series several years later that forced the state to revamp the ESL system.

Sacrificing Science CoverThis was the first time anyone had led an scientific inquiry into how the State of Texas regulated toxic exposures. This effort wasn't commissioned by a national or even statewide environmental group, with lots of money and a staff of its own. It was scrapped together by a grassroots group of citizens in DFW.

At the time, Downwinders' energy was aimed only at fighting the burning of toxic waste in the Midlothian cement plants. Such a report didn't directly serve that cause at all. That's why we're so proud of it. In the middle of the longest, most expensive hazardous waste permit fight in Texas history, we took the time and money to pay for a report that would expose a problem every citizen living near a polluter was facing. We looked at the fundamentals and saw a larger need than just our own self-interests in Midlothian. We took the longer view.

We're still doing that.

We're the only environmental group dealing with fracking as a regional air pollution issue –  taking it out of the city-by-city fights we're all accustomed to, and looking at the larger picture of how it adds to North Texas smog.

We're still the only group looking for ways we can disrupt the authority of the state in setting our local environmental  agenda. Over the next few weeks you’ll learn how Downwinders is sponsoring the very first effort to give local officials access to the same computer “modeling” the state uses to build its clean air plans. But this computing power is being used to do things the state is refusing to do – like looking at what pollution control measures work best in DFW. It’s the first time anyone has challenged the state’s exclusive ownership of the region’s air computer modeling.

Next month, you’ll see local DFW doctors and nurses testifying on behalf of cleaner air at public hearings on the state’s proposed new smog plan. They’re being organized by Downwinders in an effort to form a North Texas health professionals speakers bureau to put on the front lines of air pollution controversies. Not just our fights – everyone's fights.

Downwinders is doing work no other group is doing – work that benefits everyone who's being shat on by an industrial polluter – whether its a cement plant, a coal plant, or a gas compressor. Because, just like in 1996 when we published "Sacrificing Science for Convenience"  we see our job as a larger than our own fights. We understand that we're part of a larger citizens movement. One about the distribution of political power, and the autonomy of an individual to decide for themselves what risks to their health are acceptable.

Next Monday, we'll be sending out an e-mail alert that will be jam-packed with January news about state and national clean air hearings, tributes to our local heroes, and on-going local fights. 2015 is going to be another busy year for us. But we need your help to fund our work today and the next three days. We do what we do on a shoestring budget – usually not more than $30-50,000 a year – but we need new shoestrings. We're completely local, which means we're completely dependent on people like yourself who see the value in our work. If we can't put our organizer in the field, a lot of good things that we want to do next year won't happen. And that'll be a shame not only for our own causes, but for the larger cause as well.    

Please click here and give whatever you can.

Anything is truly appreciated – and will contribute to work that has a long shelf life. Thanks.

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