Who could have possibly foreseen? Many of the activists in this 2018 picture who lead the effort to secure half a million dollars for consultants to write a climate plan are now unhappy with the climate plan the consultants wrote. Photo by Linda Hamilton

There’s a lot of angst and disappointment among Dallas green groups over the draft of the consultant-driven Dallas Climate Plan released a couple of weeks ago and headed to a final vote in April.

Despite Mayor Mike Rawlings vowing to adopt, honor, and uphold the commitments to the goals enshrined in the Paris Agreement” in 2017, the actual 2020 plan achieves less than 50% of the emission reduction goals by the deadlines set in that international agreement.

Since its unveiling, local green discontent with the Plan has been bubbling up in a variety of ways. There’s an appeal to join a protest rally at this Tuesday’s official roll-out of the Plan at the City’s day long “climate symposium” to show support for a “stronger,” and “better” plan. Another group’s online plea states that “many” of the Plan’s 93 action items are “inadequate” and not immediate enough. There are lists of demands that include the commitment to actually fund the recommendations proposed, accelerate vehicle and fleet electrification by a decade or more, and “more quantifiable actions” to insure the city meets its own goals.

What makes these criticisms both sad and instructive is that they’re coming from some of the same green groups that literally went door-to-door in 2018 trying to effusively sell Dallas residents on the idea of the consultant-driven climate plan they’re now faulting. Having campaigned and won City Council approval to spend $500,000 of the $750,0000 in earmarked “environmental funding” leftover from the city’s short-lived plastic bag fee, they were rewarded for that sales job by having their representatives appointed official “stakeholders” in the plan’s drafting.

That’s apparently all they got from the City for their effort. Because those representatives are now stoking the newfound discontent with the plan they presumably helped draft.

Was it naive of these groups to put their trust in the same City Hall that approved illegal gas drilling, Joppa batch plants, and Shingle Mountain? Undoubtedly. The largest disappointment with the Dallas Climate Plan isn’t the action items it does or doesn’t include, but the blank check of support it got from those who had the leverage to ask for more at the beginning of things. At exactly the time when they had the most real power to produce a more creative, effective Plan, they said no thanks and gave all the power to City staff and the consultants whose pay they had secured. That’s the original sin from which all other shortcomings flow.

Confronted with the City’s intent to create its own climate plan after Rawlings made that very public promise in 2017, a more successful effort might have tried to assemble some kind of Dallas Green Alliance-type response from the widest possible spectrum of groups, many of whom are experts in their respective interest areas – Urban Ag, Water, Solid Waste, Transportation, Environmental Justice, and Air Quality.

Despite the diverse interests, maybe it would have been possible to wrangle a grassroots residents’ plan that identified 1 to 3 make-or-break reforms or procedures out of a longer list of recommendations. At that point, with most green local groups on the same page about what they wanted from the plan, this coalition could have said to City Hall  “If you want our support for that half million in consultants fees you have to promise X, Y, and Z be included in the adopting resolution.”

There are no guarantees such a path would have produced a better plan, but the tragedy is that it was never even tried.

All the original cheerleaders seemingly just wanted to cut a deal for a climate plan in name. For the most part, that’s exactly what they got. The only ones who seem surprised by its lack of serious content are the ones who signed-off on that superficiality.

Instead of building on reforms already negotiated up front, critics are now left to complain from the sidelines at the last minute, only weeks before the final vote. That’s rarely a recipe for successful change.

After Tuesday’s rollout, it looks like the full council might be briefed by staff on the Plan Wednesday, April 15th, with a symbolically-laden vote on the 50th anniversary of Earth Day, Wednesday April 22nd. Amendments are possible but need eight votes to pass a city council that has yet to be tested for its green bone fides.

Other “interest groups”  have accumulated, organized, and leveraged their power to insure they weren’t cut out of the action at City Hall – the amazing LGBTQ Stonewall groups who are a force of nature in local politics, black and brown business associations, church and civil rights groups, and of course developers and the Citizens Council.

Some future Earth Day you’ll know the DFW green movement will have grown into a mature political force when it has the self-interest, wherewithal, and ambition to negotiate from a position of collective power. For now, among the costs we incur by the absence of that strategy are disappointing, timid climate plans.

Want to learn more about the Dallas Climate Plan process? Read our coverage:

February 2019: “All Plan, No Action: Dallas City Hall’s Approach to Climate Change”

 

March 2019: “Dallas Climate Plan’s ‘Public Participation’ is Neither Very Public nor Participatory”

 

May 2019: “Dallas’ Climate Plan Rolls Out Public Engagement Plan. Public is MIA.”

 

November 2019: “The Only Thing Missing in Dallas’ Climate Plan “Focus on Equity” is…any measure of Equity”

 

February 2020: “How the Dallas Climate Plan Baits and Switches on Air Pollution”

 

 

 

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Civil Rights legend Peter Johnson talking community organizing with this year’s class.

 

There might be no better symbol of Downwinders’ transformation from a local clean air group to Something More than our successful College of Constructive Hell-Raising.  We just began our fourth year with a class of 22 students that will push the number of alumni to over 50 at this May’s graduation. Seven of our 12 current board members are graduates.Unlike other seminars for political activists that examine electoral strategies or specific skills like public speaking or fundraising, the College enables its participants to “think like an organizer.” Its sessions are a combination of the same principles taught to professional organizers at the nation’s oldest schools of community organizing and the local history of effective social change as told by the people who made it.

Environmentalism is not its focus. Rather it’s a deep dive into the mechanics of how “Davids” beat “Goliaths.”

Per custom, original Southern Christian Leadership Conference (SCLC) organizer Peter Johnson was the semester’s lead-off guest speaker. As someone who knew MLK Jr. on a first name basis, Peter instantly brings history down from the pedestal many of us want to put it on. Other guest lecturers include John Fullinwider, Changa Higgins, Mavis Belisle, Sister Patricia Ridgley, Kim Batchelor, Luis Selpulveda, Patti Fink, Don Madison, Colette McCadden and Meagan Green.

As impressive as our speaker line-up is, it’s also the diversity of students who’ve fueled the success of the class – urban aggies, animal rights and police brutality activists, peace and immigration activists, LGBT, transit rights and anti-gentrification activists. We’re growing a network of relationships that transcend single-issue silos and making new friends that connect us to larger struggles.

Interested? Another class begins January 2021 with enrollment beginning in September. You can put your name on a waiting list to get an early heads-up here, and follow the College on FaceBook here.

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Gathering in an outdoor pavilion only feet away from the notorious Shingle Mountain, the illegal dump’s neighbors recently began to hammer together a very different future for what they want their community to look like.

Using Legos, pipe cleaners, and construction paper Neighbors United members built a 3-D version of their new vision as part of the first wave of meetings in preparation for the upcoming “forwardDallas!” land use planning process.

Facilitated by The Inclusive Communities Project’s Jennifer Rangel and Downiwnders’ Chair Evelyn Mayo, the group was following up on its successful petition for “Authorized Hearings” to trigger a reexamination of how every tract in their part of the “South Central Corridor” should be zoned. That petition is now winding its way through City Hall and the group’s recommendations will be critical in getting things changed.

Even as they continue to fight for a full-clean-up the residents are doing their best to make sure their neighborhood isn’t victimized again by unscrupulous grifters like Shingle Mountain’s Ganter brothers or the City of Dallas’ own neglect. Their taking their fate into their own hands, in this case, one Lego block at at time.

Last undertaken in 2009, “forwardDallas!” is a attempt to write a comprehensive plan for the entire city, block by block, that’s then (theoretically) referenced by residents, developers and City Hall planners in all future decisions. This time, there’s a grassroots campaign gearing up on behalf of environmental justice concerns in Southern Dallas using it to follow-through on previous promises to de-industrialize neighborhoods like Joppa and the South Central Corridors that are next door to the Great Trinity Forest but still dominated by heavy industry.

Obsolete racist zoning forces People of Color to live way too close to heavy industry polluters along the Trinity River floodplain. Success will mean undoing this kind of zoning in big chunks, improving public health and the chances of economic development in the process.

Important goals are restoring residency rights so everyone gets public notices, “down-zoning” tracts that aren’t being used by heavy industry now but could host them in the future, and pro-active pollution control measures new zoning could provide.

Zoning and land use decisions are a large reason why studies consistently show People of Color are exposed to more and higher levels of Particulate Matter air pollution than their white peers. Instead of continuing to battle Southern Dallas polluters permit by permit, zoning reform offers a way for residents to solve the underlying institutional problem. And because the “forwardDallas” review turbocharges the entire process, it offers the opportunity to make large gains faster.

Although the official start to “forwardDallas” isn’t scheduled until April now, Jennifer and Evelyn are getting a head-start so neighborhoods show up at the City meetings with something already in hand. If you’re interested in your neighborhood hosting one of their workshops, please contact us at: downwindersatrisk@gmail.com.

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A little after 5 pm Monday February 3rd, the Office of Environmental Quality and Sustainability (OEQS) at Dallas City Hall released its draft recommendations for the city’s climate “action” plan. There are 93 “action items” including transportation, buildings, green spaces, water management, solid waste, and urban agriculture. Most are without imagination or timelines, meaning that even the most milk toast-like recommendations being made will have to be fought for tooth and nail to be done in a timely manner.

Like the department that generated them, the list of recommendations is effusive about stormwater management and tree-planting and silent on more challenging issues such as inequitable pollution burdens and the City’s own reliance on natural gas. It once again puts the spotlight on the lack of any environmental health expertise at Dallas City Hall in the decision-making process. When Dallas OEQS staff talk about the environment, what they really mean is “conservation” – a definition that’s been obsolete since at least the 1970’s.

There’s no better example of how this tunnel vision affects policy than OEQS staff invoking DFW’s chronically poor air quality (i.e. an environmental health problem) to sell the need for its Climate Plan…only to see the actual Plan ignore poor air quality as a serious health issue that could use some innovative thinking.

For over a year now, anytime you saw a Climate Plan presentation by Dallas OEQS staff, it always cited DFW’s smog problem as something that would only get worse as the climate crisis played out. “Everyone here is probably aware of DFW’s longtime air quality problems” or some approximate was the standard riff. And of course, everybody was. Heads nodded. Audience members were sometimes asked if they knew anyone with asthma and hands immediately shot up. That was the point. The selling point.

Because, until recently at least, the abstract nature of “the climate crisis” made it difficult to get people excited about the idea of a plan. Staff/Consultants needed a hook. And that hook was something everyone could relate to and probably already knew about: DFW’s three decades of violating the Clean Air Act.  If you look at the results of the Ctiy’s online survey asking about frequency or intensity of climate change effects, “Poor Air Quality” was the second most cited concern.   Among the City’s own handpicked crew of “stakeholders” advisors, it tied for first, along with buildings/energy use, getting more votes than parks, “nature-based approaches,” and renewable energy.

And yet, in those same City Staff presentations that highlighted poor air quality as a reason to have a Climate Plan, air quality itself was completely absent in the staff’s list of anticipated recommendations. It wasn’t that they just didn’t have much to say. They had nothing to say. There wasn’t even a category for air quality.

So Downwinders complained. Loudly. Staff and consultants sprang into action and came up with a category of recommendations officially called…“Other,” the theme of which was “air quality standards” and “public education.” Opportunities cited included “location-specific initiatives (e.g. downtown)” and “Programs targeted outdoor workers (e.g. Landscapers, construction workers).”

So sure, we have a chronic air pollution problem that warrants a $500,000 consultancy fee to construct a plan, but in that plan we’re only going to continue to inform people of that problem and maybe do some kind of vague thing relating to the poor souls who work outside (limit hours, hand-out free oxygen, help find new employment, or maybe free health check-ups? Doesn’t give a hint). By the way, only the public education part of that slide made it to last Monday. Construction workers and landscapers are still up a creek.

Along with those snippets of text on the “Other” slide were large color pictures of the “Breathe Easy” 5K run sponsored by The Jerome Alston Memorial Foundation in May…during Ozone Season. We’ll give the City staff credit. In terms of public education, there might not be a better way to personalize the seriousness of DFW’s air pollution problem than having North Texas smog cause an emergency asthma attack while you’re running in it. But liability could be an issue.

As late as the final round of public meetings last Fall, staff still didn’t have an “Air Quality” category but said they would have “something” when the plan was published.

Turns out “something” looks a lot like nothing.

Among the 93 “actions” listed in the Plan’s draft, the category of Solid Waste gets nine recommendations. Water Resources 15.  Urban Ag 14. The brand new category of “Air Quality” has four – the fewest of any category in the plan. It’s practically stamping “Last-Minute Desperation” on the whole subject.

And tell us if any of these recommendations sound like anything you might have already heard about…

Let’s take them from the top.

The very first thing out of the gate, the lead-off, sexiest, out-of-the-box recommendation for improving air quality is…. somehow talk the State into adding more obsolete, state-run air monitors at some unspecified time in the future.

If you can, forget that the State environmental agency – the Texas Commission on Environmental Quality (TCEQ) – is a model for the Trump Administration. Forget that its official position is that smog is waaaaay overrated as a health threat. In other words, forget that this is akin to hiring Charlie Sheen to babysit your only child.

It’s not the baked-in, in-your-face cynicism of City staff knowing the state has every reason not to do this that’s so offensive. It’s the same cynicism applied to knowing full well what will happen even if the state says yes to the request: no real improvement in local information about air quality. Those state monitors are big, slow, and sparse.  They run two hours or more behind real time. They’re hard to find online. They’re needlessly expensive and take up lots of real estate that has to be purchased. Their placement is decided by TCEQ and city staff, not the communities most in need of them.  There is no stated OEQS goal for the number of monitors to acquire, or suggestions about where new monitors should be. No language in the recommendation about wanting real time monitoring or more modern equipment. It’s just an expansion of an already-obsolete system the state only runs because federal law requires them to (for now).

OEQS wants more of these lumbering and obsolete monitors from the state.

So let’s say the City talks the state into doubling the number of state PM 2.5 monitors in Dallas. Victory! The discussion will then be where to place the second slow, hard-to-find PM monitor for all of Dallas County’s 2.5 million residents.

Left unsaid in this recommendation is something we already know. For a year now Staff has tried to move that single Dallas County PM monitor located on Hinton Street north of Downtown to somewhere in Southern Dallas. Apparently the state has made that hard-to-impossible and so for the purposes of having something, anything, to recommend for this climate plan, staff  recommends more monitors – knowing there’s a snowball chance in Hell of getting them. It’s the perfect bureaucratic out.

Most importantly the City remains a spectator to the reporting to its residents of how bad their air is. Its staff doesn’t have to make any environmental health judgments as they’re busy promoting tree planting. They leave that up to the people who couldn’t care less about how much pollution you’re breathing.

In the wake of recent Gulf Coast chemical plant accidents, the TCEQ is under heavy criticism for its lack of current air monitoring technology. The system it operates in DFW hasn’t changed in over 20 years. TCEQ won’t even put an air monitor in the only DFW “non-attainment” county that doesn’t have one – Wise – where smog levels have been predicted to be even higher than in DFW proper.

Recommending a modest expansion of circa-1999 technology is the opposite of a “best practices” answer for our gap in local air quality knowledge.  The most alarming thing about this recommendation is that it got made at all.

The one-liner stapled at the end about offering free health screenings “with Dallas County” (who’s already in the business)  in “areas with poor air quality” is incredibly condescending. Here’s the ultimate “settlement house” approach to a social ill – addressing the symptoms but not the cause. “Well, we can’t do much to enforce code or keep those batch plants out of your backyard, but by God we’ll be around every 6 months to keep track of your asthma until you die from it.”

How does OEQS staff know where those “areas with poor air quality” are now unless they’re out monitoring them? Which they clearly do not want to do. Given there’s only one official PM monitor for all of Dallas County, how are they defining “areas with bad air?” If they’re making educated guesses where those “areas” are based on other factors besides monitoring, why not name those factors and the “areas?”  OEQS goes out of its way to avoid using the words “environmental justice” even as it makes recommendations based on the concept.

Recommendation #2 – let’s build our own “non-regulatory” air monitoring network sometime in the unspecified future with unspecified non-profits and community partner volunteers and put an unspecified number of monitors in unspecified places, for which we unspecified criteria. And these monitors “could be used to “to track progress for air quality improvements based on strategic initiatives deployed in CECAP, and the comprehensive plan.”

This is actually a great idea. It’s such a great idea that a specified alliance of local governments, non-profits, and community partners are already doing it in specified locations with specified monitors. Their effort is about to deploy over 100 locally-built air monitors that will increase PM 2.5 monitoring in Dallas County by 4000%. It’s called the SharedAirDFW Community Air Quality Monitoring Network and the City of Dallas officially walked out of it last year over a public participation requirement and a desire to refrain from being the source of bad news about bad air.

Dallas city staff is consistent in believing that telling you about air pollution is absolutely, positively necessary – they just want someone else to do it.

Having walked away from the SharedAirDFW network, OEQS set out to make one up of its own using the City Hall-friendly Nature Conservancy as its non-profit partner. The “Breath Easy” plan was to put 9-12 PM and smog monitors on the same number of DISD campuses, grow trees and implement anti-idling zones at those schools and see if asthma attacks/rates dropped in 24 months (2 growing cycles). Everyone seemed to agree how important a project this was and the city raised $500,000 or more to buy 12 very nice Aeroqual (Recommended by Downwinders since 2017!) air monitors. Everyone but the Dallas independent School District, who nixed the idea last summer. This detail somehow escaped the presentation staff gave to the City Council’s Quality of Life Committee on the Breath Easy project in September 2018.

An Aeroqual stationary air monitor like the 12 Dallas owns…but isn’t using

So far the City of Dallas is 0 for 2 in making their own recommendation a reality when it had the chance. But wait! Remember those 12 monitors the City bought for the defunct Breathe Easy project? They’re just sitting somewhere. They’re already paid for but aren’t being used. OEQS could implement this recommendation of theirs on its own tomorrow if it wanted to by placing these 12 monitors in locations based on where the most industrial facilities are and where the most air pollution complaints come from. Overnight it could have its own fleet of “non-regulatory” monitors in the field, with all the benefits cited by staff.

But there’s no mention of those 12 monitors, or of the City Hall’s ability to accomplish this goal on its own, right now, without waiting. Because it doesn’t want to. It wants someone else to do it.

Recommendation #3 . It’s that forlorn public awareness recommendation showing up in the form of continued support for an ozone season air quality campaign run by a group that did its part to make smog an issue for years. There’s no harm to this but there’s also no help. This campaign will go on for as long as DFW is in violation of the Clean Air Act and doesn’t mention climate change.

Finally, there’s recommendation #4. Perhaps (but perhaps not) heavy industry that pollutes a lot shouldn’t be close to homes. This is coming straight-faced from a OEQS that’s approved the last four batch plants seeking permits to set-up shop in Joppa and the South Central Corridor…next to homes. Do as we recommend, not as we actually, you know, do.

The TAMKO asphalt shingles plant and multiple diesel locomotives operate next to Austin’s asphalt batch plant…and residents in Joppa

When it says the City will review zoning, that’s not a special environmental health screening of sites. It’s just part of upcoming land use planning processes that will already be used to re-examine all zoning on a neighborhood-by-neighborhood level. They’re riding coat tails. The OEQS doesn’t make recommendations about suggested buffer zones, where those zones should be, or what criteria the city should use in pursuing buffer zones. And it doesn’t even say the City’s neighborhoods need any buffer zones between homes and industries at all, just that it may want to consider them at an unspecified time by an unspecified body for  unspecified neighborhoods.  Have we mentioned the staff at City Hall really really doesn’t like to deal with environmental health issues?

We get it. They had to have something or you’d be reading our criticism about the absence of ANY specific air quality recommendations, no matter how lame. And there are other items in other categories that will inevitably produce decreases in air pollution of all kinds – bus and vehicle fleet electrification being among the lowest-hanging fruit.

But City Hall’s cynical use of DFW’s air pollution problem to win support for a plan that ends up doing nothing about it directly makes these “Air Quality” recommendations particularly contemptuous.

What would more sincere “air quality” recommendations look like?

1. Acknowledging an historic imbalance in the air pollution burdens borne by Dallas neighborhoods and a commitment with a deadline to inventory the City’s air pollution threats by council district and zip code. You can’t fix what you don’t measure. Right now there’s no map of where concentrations of air pollution are in Dallas.

2. Acknowledging there’s no safe level of PM air pollution, i.e., no amount of exposure that isn’t capable of doing harm. Acknowledging People of Color are exposed to more, and higher levels of PM pollution than their white peers. These conclusions, supported by a multitude of good studies, including ones from EPA, are basic in prioritizing where to reduce air pollution in Dallas.

3. Recommendation to write an Environmental Equity Provision into City Code to discourage and prohibit siting new polluters in those zip codes hosting more permitted polluters than the citywide average, beginning in 2021.

4. Recommendation to quit siting polluters in any floodplain beginning in 2021.

5. Recommend a 2025 deadline for the electrification of all railroad switch yard operations in Dallas.

6. Recommend 1500 foot buffer zones on either side of new major highways where homes, day care centers, and schools would be prohibited from locating. Applied to existing highways as uses within 1000 feet come up for new permits and zoning.

7. Recommend the immediate amortization and relocation of the GAF asphalt shingle factory in West Dallas and the TAMKO shingle factory in Joppa. These factories are among the City’s largest industrial polluters in Dallas, accounting for over 420 tons of air pollution in 2017 alone.  They operate in the middle of dense urban residential areas populated primarily by People of Color. They need to be relocated elsewhere. Building new facilities will automatically trigger modern pollution controls requirements. They’ll be cleaner and doing business in a less harmful location.

8. Recommendation to rewrite city codes giving incentives for cleaner industries and more requirements for dirty ones.

9. Join UTD’s SharedAirDFW Community Air Monitoring Network – plug OEQS’ 12 unused monitors into the Network and begin to take responsibility for telling Dallas residents what their air quality actually is.

10. Acknowledge the conflict of interest the City has in producing and selling gas from its landfill recovery operation and commit to electrification of all city-owned vehicles by 2025. Dallas’ own city-run McCommas Bluff methane gas recovery facility is the fourth largest air polluter in Dallas, releasing over 160 tons of air pollution in 2017 alone. Recommend contracting only with electric vehicle fleets for additional services. Los Angeles recently committed to an all electric garbage truck fleet in five years, and Dallas could do the same – but it still wants to use its own landfill gas to power combustion vehicles.

11.  Implement stronger enforcement of the city air quality and nuisance ordinances, including hiring new staff and publicizing how to request an investigation.

12. Beginning in 2025 begin collecting municipal clean air mitigation fees of $50 a pound on permitted air pollution from major sources to incentivize pollution controls and pay for new staff. In 2017 such a fee would have collected over $1 million.

13. Implement no idling zones in all Dallas warehouse districts.

14. Recommend Low-Emission Zones in Downtown Dallas where combustion vehicles are banned or restricted, permanently or on a schedule. Consider expanding to other parts of Dallas such as Deep Ellum and Bishop Arts where congestion is already a problem.

15. Recommend PM pollution protection be designed into new bus shelters.

16. Recommend establishment of an Electric Bus Procurement Pool with DISD, DART, Trinity Metro, other area schools districts, and transit companies for cheaper purchases of electric buses.

17. Restoration of the Dallas Environmental Health Commission.

18. Hiring a City of Dallas Environmental Health Scientist.

DFW does have a chronic bad air problem. The Climate Crisis will make it worse. It is a legitimate area of policy planning in any thoughtful, modern Climate Plan.

Just not this one.

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Downwinders Welcomes New Board Members

by jim on December 10, 2019

November brought a round of new board members joining our ranks. It also brought an historic milestone. For the first time in our 25 year history, we’re now governed by a board whose majority is composed of people of color.

   Marsha Jackson

A year ago not many people at Dallas City Hall knew Marsha Jackson’s name. That’s not the case this December. Ms. Jackson is both the founder of her own neighborhood group, Neighbors United, and the citywide Southern Sector Rising Campaign for Environmental Justice. She’s also the nearest neighbor to Shingle Mountain, Dallas’ largest illegal dump and the highest profile symbol of environmental racism in North Texas since the RSR lead smelter clean-up in the early 1990’s. Like Luis Sepulveda almost 30 years ago Marsha Jackson’s name has become synonymous with the fight for Environmental Justice in Dallas.

Michelle McAdam

Michelle is a long-time friend of Downwinders who finally decided to join the board. She was a student in the very first year of our College of Constructive Hell-Raising, where she met her unlikely Southern Dallas doppelganger and provided us with one of our favorite college stories. She’s a true Daughter of Dallas nobility but instead of resting on our laurels or trust funds, she’s worked tirelessly her whole adult life for people who haven’t been as fortunate, including being on staff at the International Rescue Committee and now as an Economic Empowerment Specialist at New Friends New Life, a group working to transition women out sex trafficking or exploitation.

Justina Walford

Justina is a former District 4 City Council candidate, Southern Dallas dog rescuer and advocate, and member of the Southern Sector Rising Campaign Steering Committee. She’s also Director of the annual Women Texas Film Festival. Born and raised in Southern California, Justina owned a theater in Hollywood during the early 2000’s where she produced full length plays and storytelling events that included her original work.

Amber Wang

Amber has degrees from Rice in Mechanical Engineering and trouble-making from our own College of Constructive Hell-Raising. She’s Technology Manager at the Victory
Co-Working space Hatchways and has bravely decided to help us in developing more sustainable local funding source. At Rice Amber led a student design organization that developed pro bono solutions for nonprofit organizations and social ventures in the Houston community. We hope she can do the the same for us.

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An important part of Downwinders’ 2020 agenda got a big boost this last month when we learned we’d received a $20,000 Communities Foundation of Texas grant to take on Dallas’ environmentally unsound and racist zoning as part City Hall’s upcoming “forwardDallas!” land planning process.

Touted as a meeting-intensive opportunity to reshape Dallas neighborhoods by the residents who live in them, the last time the city went through “forwardDallas!” was also its first time, in 2006.

With our allies at the Southern Sector Rising Campaign for Environmental Justice, we proposed to use this new round of planning to reverse dangerously obsolete zoning in Southern Dallas where polluters are operating next door to homes, especially in predominantly black and brown neighborhoods like Joppa and West Dallas.

Employing the on-going Shingle Mountain scandal as a rallying cry, both groups see an opportunity to win real environmental justice progress if neighborhoods can be mobilized. Toward that end we’ll be engaging residents with door-to-door canvassing, neighborhood meetings, and appointments with officials from Pleasant Grove to West Dallas. Thanks to the Communities Foundation, we’ll be able to devote a sizable amount of resources to this campaign.

Working in our favor is the expertise of the recently-named “forwardDallas!” Chair District 11 Plan Commission Jaynie Schultz. Ms. Schultz earned an MA in Urban Studies from UTA, is Chair of the Plan Commission’s Urban Design Committee, and most importantly for this new assignment has been on the Plan Commission since 2014 consistently opposing the default dumping of new polluters in Southern Dallas in one battle after another.

Although this grant was written in part to help provide salary to our lone staff person, we’d really like to use the whole thing for program work. We can only do that if folks such as yourself respond with End-of-Year contributions and help us raise the $5-10,000 we need to pay the region’s only full time environmental community organizer.

Having the endorsement of the Communities Foundation is a huge plus for our local fundraising efforts and we’re very appreciative. Having your endorsement is even more important. Please help us stretch this grant. Thanks.

YES, I’LL HELP YOU MAKE THAT COMMUNITIES FOUNDATION GRANT GO FURTHER

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A new regional air quality network bringing 21st Century science to some of Dallas’ most polluted neighborhoods had it’s official coming out party on December 5th in the former Freedman’s community of Joppa.

A community meeting at New Zion Missionary Baptist Church sponsored by Downwinders at Risk in association with Paul Quinn College and Habitat for Humanity drew a standing room only crowd.

Food from Jason’s, door prizes, and the opportunity for a Parkland Hospital health screening made the meeting into a real community event.

Residents got to see a monitor up close and hear a presentation by the University of Texas at Dallas graduate students building them for distribution over the next year. 11 of the monitors are due to be installed in Joppa, with another 11 installed in near-by Southern Dallas neighborhoods by Paul Quinn College. In total, over 100 are scheduled to be distributed from Plano to Fort Worth to Midlothian in the largest non-government network of its kind in Texas.

Joppa is surrounded by multiple sources of Particulate Matter air pollution, including a concrete batch plant, an asphalt batch plant, a Union Pacific railroad switch yard, Loop 12 and the Tamko asphalt shingle factory. Because of its compact size an relatively small population, it has the highest per capita air pollution burden in Dallas.

That’s why Downwinders chose to begin building its part of the network in Joppa. Thursday’s roll out was the first attempt to find hosts for the monitors among the neighborhood’s residents.

There were lots of questions and lots of enthusiasm. At least two Joppa residents didn’t need any more convincing and wanted to know how fast they could get a monitor at their house.

The answer is….soon. District 7 Council Member Adam Bazaldua is assisting the network in coordinating the electrical and internet connections we need for the “mothership” that carries the load for 10 smaller solar-powered and wireless sensors. A utility pole Downwinders bought from Oncor for that very purpose is only about 30 feet down the street road the New Zion Church where the meeting was taking place. All we need now are the connections.

Downwinders will be following up this meeting with door-to-door canvassing in Joppa and updates to everyone who signed-in. Meanwhile, we should be scheduling similar meetings in West Dallas and Midlothian after the first of the year.

After years of planning and preparation, we’re finally beginning to see the payoff of our vision. Thanks to all of our supporters for helping us achieve this first, but important milestone

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Monitors are being assembled.

 

Software is being written.

 

Community meetings are happening.

 

Downwinders is helping build the region’s

 

first 21st-Century Air Network

 

The first images from the mapping app UTD students are building for the new SharedAirDFW Air Quality Monitoring Network. Here data is being received by monitors already installed on the UTD campus. Residents will be able not only to see current conditions but levels over the last 24 hours or more.

One of the over 100 new SharedAirDFW air quality monitors being built in the UTD laboratory that will be distributed throughout DFW, including Joppa, West Dallas, Southern Dallas, and Midlothian.

UTD students working with Downiwnders’ consultant Robert “the map” Mundinger on the SharedAirDFW mapping app software and interface.

By this time next year the Network plans on having over its first 100 air quality monitors distributed throughout DFW, including the “front line” communities of Joppa, West Dallas, Southern Dallas and Midlothian.

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Real Time Air Quality Information is Coming to DFW

It’s taken years of work and a lot of patience but with any luck a new citizen-friendly regional air monitoring network will debut in 2020.

Under the working title of “SharedAirDFW” over 100 new custom-built air quality monitors are being distributed throughout the DFW region in the next 12 months that will be able to give residents real time information about the air they breathe for the first time. When it’s up and running, it’ll be the first network of its kind in Texas and one of the largest in the U.S.

Based out of the University of Texas at Dallas laboratories and fueled by its graduate students, as well as Downwinders’ grant monies, these monitors will offer real time information through a easily accessible app.

Right now a handful of official EPA monitors provide air quality readings up to one or two hours behind real time conditions. SharedAirDFW willl increase the number of calibrated air quality monitors in DFW by a factor of four while giving readings updated every few seconds.

Almost half of the new monitors are going to front line communities in the DFW area: 33 monitors purchased by Downwinders are going to Joppa, West Dallas, and Midlothian, while another 11 purchased by Paul Quinn College are slated for the Southern Dallas neighborhoods surrounding its campus.

Joppa residents will get a preview of the system at a December 5th community roll out involving UT researchers, Habitat for Humanity, Paul Quinn, and local elected officials. Community events in Midlothian and West Dallas will follow.

This is one of the most important projects Downwiders has helped birth in its 25 year history. We’ll be bringing you updates as we get closer to bringing the whole system online. Thanks for you support.

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Downwinders at Risk’s new Chair Evelyn Mayo gets a huge shout out in D magazine’s popular online manifestation with her very own “Earburner” podcast.

D magazine reporter Matt Goodman and D Managing Editor Tim Rogers interview Evy about her new report on Southern Dallas zoning for Legal Aid, her Roller Derby years in Singapore, and of course, Particulate Matter.

CLICK HERE to link to the podcast and learn more about one the new dynamic leaders of Downwinders at Risk.

 

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A staff presentation focusing on Dallas environmental equity lacks any metrics for comparing residential pollution burdens, or even for measuring the success of its own outreach effort.

So how does City Hall know what environmental “equity” looks like?

 

According to management guru Peter Drucker, “If you can’t measure it, you can’t improve it.”

Then what does it mean that a full year into a Dallas climate planning process heavily touted as reflecting the city’s emphasis on “equity” there’s still no map showing how pollution burdens are distributed across Big D? And what does it tell you when a presentation meant to advertise the inclusiveness of the City’s outreach effort for its climate plan doesn’t document participation by residents of color?

It tells you that despite all the rhetoric on the subject, Dallas City Hall isn’t serious about environmental justice yet.

Office of Environmental Quality and Sustainability Susan Alvarez presents the City’s climate plan through “an equity lens.”

Exhibit A: “Dallas’ Climate Action Through an Equity Lens.”  

This was a presentation that Susan Alvarez, Assistant Director of the City of Dallas Office of Environmental Quality & Sustainability, gave as part of Eastfield College’s Sustainability as a Social Justice Practice: Developing Resilient Strategies held last Friday, November 8th.

Context is everything and so it’s important to note that the entire thrust of both the Conference and the City’s specific presentation was aimed squarely at how to respond to current environmental challenges in an equitable and just way.  Here was a chance for Dallas OEQS city staff to display their embrace of equity as it relates to the climate plan it’s been paying a half-million dollars to consultants to construct. It was their very own EJ report card.

Equity and the Climate Plan:

And sure enough, there was no turning away from Dallas’ racist history in Alvarez’ presentation. Maps showing the City’s chronic segregation and poverty were included, as well as allusions to the Trinity River as the city’s dividing line between Haves and Have-Nots. Alvarez spoke about the current “Redlining Dallas” exhibit at City Hall that traces the City’s history of racism across 50 feet of photographs and stories.

In fact, just about every impact of the City’s official segregation was referenced, except for the one you’d expect.

There was not a single slide or sentence expended on the disproportional environmental impacts of 100 years or more of Dallas racism. No maps of where heavy industry zoning is allowed in the City. No maps of where most of the City’s largest polluters are located. No maps of what zip codes or Council Districts have the highest pollution per capita numbers. No references to past environmental justice struggles with the City like the West Dallas RSR fight, or gas drilling.

Watching the presentation you’d get the impression that racism infected every aspect of life for Dallas residents of color except for their exposure to pollution. But of course, we know that’s not true.

During this and other presentations on the climate plan-in-progress, staff go out of their way to point out that industry makes up “only 8% of emissions.” But if you’re interested in applying “equity” to this number the next slide should show the audience where that industry is distributed in Dallas – a map showing you where industrial polluters are allowed to set-up shop.  A slide to show you the amounts of permitted pollution by Zip Code, or maybe actual 2017-18 emissions by Council District. But there is no next slide.

If there were, it would show that most of that industry is located in predominantly Black and Brown neighborhoods. Racist zoning is at the heart of not just banking, education, and employment inequities in Dallas. It also means the dirtiest industries have always been located in close proximity to people who were institutionally considered Second-Class citizens.

This one slide is already more information on Dallas environmental equity than you’ll find in the entire City staff presentation on equity and the climate plan

Disproportional exposure to industrial pollution by residents of color is not just AN equity issue. It’s THE single most important equity issue when you’re speaking about environmental justice in Dallas. The City’s Black and Brown residents are more likely to be exposed to harmful pollution than their white peers because the City’s own zoning designed it that way – but you’d never know it watching this presentation, on equity, at the social justice conference.

The “Redlining Dallas” exhibit that Alvarez cited thinks so. Along with other insidious effects of racism, it gives space to the RSR clean-up fight Luis Sepulveda and his West Dallas Coalition for Environmental Justice waged in the early 1990’s.  But there was no mention of that fight or any other Dallas examples during the presentation on equity, at the social justice conference.

Staff referenced every other kind of red-lining on display at the City Hall exhibit – except the one most relevant to the topic.

Nor was there any mention of how much industry was located in the Trinity River floodplain, doing business in Black and Brown neighborhoods founded because the City wouldn’t allow these so-called “undesirables” to live anywhere else but side by side with “undesirable” industries. Alvarez made the point in the presentation that climate change means more flooding in general and more severe flooding. The next slide should show who and what is affected by that new flooding risk. A slide showing what percentage of heavy industry is located in the flood plain. A slide showing what the racial make-up and income levels are of those who’ll be more affected by increased flooding…and contamination. But there was no next slide, in the presentation on equity, at the social justice conference.

If you don’t have accurate maps of the inequities plaguing the status quo, how do you know when or if you’re ever getting rid of them? How do you judge success without a baseline?

PR, Process and Equity:“I don’t think it’s important to say I’ve got four black people in my stakeholders group.”

Alvarez lowered expectations for the presentation by saying it would only look at the question of equity in how it was applied to the City’s climate plan “community engagement.” No actual equity policy options from other plans were on the table, just how well the plan’s public relations campaign did.

Not very well, she admitted. In fact the initial meetings and publicity were so anemic that she said the professional PR folks at Earth X had a come-to-Jesus-meeting with staff about a reboot. So that’s tens of thousands of dollars wasted on PR consultants only to be usurped by better free advice from locals.

A meeting of the Dallas climate plan advisory group.

In her recounting of the climate plan’s PR rollout and planning process Alvarez gave an overview of the mechanics. “X” number of  meetings attracted “X” numbers of people. The City’s survey got “X” number of responses. An “X” number of people serve on an advisory stakeholders group.

Considering the very specific circumstances of the presentation, the next slide should have been how the results of those attending meetings, or completing a surveys, or advisory committee memberships reflect Dallas’ population as a whole. How do we stack up to who we’re representing? According to the Statistical Atlas Dallas is approximately 25% Black, 41% Hispanic , 30% White and 3% Asian. So the next slide should compare what percentage of those attending climate plan meetings, or completing surveys, or becoming advisory committee members were Dallas residents of color vs the city demographics.

But there was no next slide about how inclusive the City’s climate plan community outreach or advisory process has been in the presentation on equity, at the social justice conference.

In response to a question about the lack of such information Alvarez said it was irrelevant to the topic at hand. “I don’t think it’s important to say I’ve got four black people in my stakeholders group.”

Since the advisory group membership is only listed online by organizational affiliation it’s impossible for anyone outside the meetings to know what the ethnic or gender make-up of it is. There are 39 separate entities listed. 25% of that number would be nine to ten black people.

In elaborating, Alvarez challenged the idea that mapping Dallas’ racial or ethnic disparities in pollution burdens was necessary to understanding “Dallas’ Climate Action Through an Equity Lens.”  She more or less stated it didn’t matter. (the presentation was recorded by Eastfield College and Downwinders has asked for access to it in order to quote Alvarez accurately).

Nothing could better summarize the kind of Catch-22 “don’t confuse me with the facts” approach to “equity” the City staff has taken in regards to environmental racism than the belief that actual data about Dallas environmental racism is of no use to the study or remedying of Dallas’ environmental racism.

And nothing makes a better case for the need to pass environmental justice reforms the Southern Sector Rising Campaign is advocating at Dallas City Hall, including an environmental justice provision in Dallas’ economic development policy, restoration of the Environmental Health Commission, and creation of a Joppa Environmental Preservation District. If residents want environmental equity considered in city policy they’re going to have to enlist their City Council members, do it themselves, and enact reforms like these.

The same is true as City Hall ramps up to take on citywide land-use planning in its “forwardDallas!” process early next year. When staff recently released the City’s “equity indicators” report, there was an indicator for everything but the environment. It only reinforced the idea that the environment, and environmental justice, are still after-thoughts in Dallas city government. Residents will have to arm themselves with the information the City staff can’t or won’t provide. They should start with the recent Legal Aid report “In Plain Sight” that demonstrates deep neglect for code and zoning regulations in Southern Dallas.

And it also goes for the climate plan. Southern Sector Rising’s first recommendation for the city’s climate plan last May was “Remove industrial hazards from the flood plain.” On the other hand, the idea of land use reforms in the floodplain hasn’t appeared in any official literature or presentation associated with the city’s climate plan.

Grist recently published an article about the Providence Rhode Island climate planning process that looks to be the exact opposite of the model Dallas has adopted. But that city benefited from having an environmental justice infrastructure already in place when the climate crisis assignment arrived. Where’s the home for Environmental Justice in Dallas City Hall? Right now, it’s with staff that doesn’t think metrics about equity are important, in its presentation on equity, at the social justice conference.

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October 17th is also the date of the only public hearing being offered on one of the most far-reaching rule-rollbacks of the Trump administration – allowing more methane to be released from the nation’s oil and gas wells. And it’s right here in Dallas.

In August, the Trump EPA officially proposed its rollback of the methane emissions regulation put in place by the Obama administration. This one-day hearing in Dallas is the single chance for citizens to speak-up and be heard in person. You can bet industry will be out in force to support it.

As many of you already know, Methane pollution is less plentiful than CO2 but is approximately 85 times more potent as a climate destroyer. This is part of what makes it so important to decrease emissions.

But Methane is also a surrogate pollutant for a host of chemicals called VOCs – Volatile Organic Compounds – like the carcinogen Benzene. When you decrease methane emissions from an oil or gas well, you’re also decreasing VOC emissions across the board.

Many VOCs are dangerous toxins and as a class of chemicals contribute to smog. Downwinders at Risk landmark 2015 study of smog sources in DFW identified 50 tons a day of VOCs from regional gas wells and production facilities that contributed up to almost 4 parts per billion of smog.

Rolling back the Obama Administration rule to limit methane emissions means more toxic exposures to thousands of residents in DFW living within hundreds of feet of wells and facilities. it also means our chronic, three-decade old smog problem, which got worse this summer for the first time in five years, will keep going further south.

It’s no coincidence that these hearings take place during working hours when professional lobbyists can attend but working people can’t. Nevertheless DFW residents must step up and represent all those folks from around the US who are not being given a chance to speak.

The public hearing will be held at the Earle Cabell Federal Courthouse, 1100 Commerce Street, in Dallas, in the Red River and Live Oak conference rooms on the 7th floor. According to the official notice, “Because this hearing is being held at a U.S. government facility, individuals planning to attend the hearing should be prepared to show valid picture identification to the security staff to gain access to the meeting room.”

To register to speak, you have to use the online registration form available at https://www.epa.gov/​controlling-air-pollution-oil-and-natural-gas-industry/​proposed-policy-amendments-2012-and-2016-new  or contact Virginia Hunt at (919) 541-0832 to register to speak. The last day to pre-register to speak at the hearing will be October 14, 2019.

Spend the day defending the planet.
Testify downtown and then come and hear Dr. Bullard testify at Paul Quinn.

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Environmental Justice issues in Dallas will get a higher profile next week as the “Father of Environmental Justice” comes back to Big D to help promote the release of a new landmark report on zoning in Southern Dallas.

Texas Southern University’s Dr. Robert Bullard is no stranger to DFW, having included a chapter on the struggle to get the West Dallas RSR lead smelter Superfund Site cleaned-up in his 1994 book “Unequal Protection.” But it was 1990’s “Dumping on Dixie” that’s widely recognized as the very first comprehensive look at what he termed “environmental racism” in the US – how rural Southern communities of color became national dumping grounds.

Dr. Bullard returns to Dallas on Thursday October 17th for a full day of appointments and visits concluding with a presentation that evening at Paul Quinn College of a new Legal Aid of Northwest Texas report on the continuing impact of racist land use policy in Dallas’ “Southern Sector.”

Entitled “In Plain Sight”  this Legal Aid effort is a blockbuster.

It’s the first close-up look at industrial zoning in Southern Dallas, comparing what’s on the books versus what’s actually taking place on-site. And it’s Dallas residents themselves who did the investigation, with teams of unofficial neighborhood inspectors visiting each site, taking pictures, and recording observations. In effect, it’s a citizen report card on the City’s enforcement of its own land use policies in the most neglected, abused parts of Dallas.

Inspired by the example of the now notorious Shingle Mountain illegal dump, which was allowed to operate by the City of Dallas without either the correct Certificate of Occupancy or the correct zoning, the study finds there are plenty of other examples of this kind of “non-compliance” throughout Southern Dallas. In fact, violation rates were found to be extremely high in some neighborhoods. It’s Exhibit A for why there must be systematic zoning reform in Dallas.

There are lots of events happening on the17th, but you really don’t want to miss the roll-out of this important, game-changing report and a chance to meet and talk to a living legend.

Here’s a link to the official FaceBook Event page for Dr. Bullard’s visit, sponsored by Legal Aid of Northwest Texas.

Marsha Jackson standing in her backyard

 

 

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After some technical and bureaucratic hitches, momentum is starting to build toward the 2020 operation of a true 21st Century DFW regional air quality monitoring network.

A small army of University of Texas at Dallas graduate students are assembling over 100 solar-powered wireless air monitoring units to be dispersed throughout the metro area. A third of those have been purchased by Downwinders for placement in Joppa, West Dallas, and Midlothian. 40 or more or going to Plano. Three Dallas County Community College campuses are receiving one, along with the Fort Worth and Richardson school districts.

And now news has come that Paul Quinn College has received an EPA grant to purchase 11 of these monitors for placement around its Southern Dallas campus. Downwinders is working to coordinate the location of its Joppa area monitors with Paul Quinn to provide Southern Dallas with its own mini-network of monitors.

Meanwhile another group of UTD students are working on the mapping software and app residents will be able to use to access the data in real time. They’re being led in this effort by Robert “The Map” Mundinger, who Downwinders hired for the job. All in all, Downwinders has now invested almost $50,000 in this network, which we hope will become a model for the rest of Texas and the nation.

Last Monday, the Dallas Observer featured a piece summarizing the Network, with quotes from UTD’s Dr. David Lary, the City of Plano, Dallas County Commissioner Theresa Daniel and Downwinders’ own Jim Schermbeck. You can read it here.

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In Europe, LafargeHolcim is a multinational cement manufacturer based in Switzerland and France – two countries on the cutting edge of climate crisis planning and members of the progressive European Union. The Company portrays itself as a climate-conscientious corporate citizen, to the point of its Swiss CEO declaring the reduction of CO2 emissions as his first, most important priority.

In Midlothian Texas, LafargeHolcim runs the most conventionally dirty cement plant in Texas and is seeking a permit that could make it one of the most climate-hostile one as well. In fact, there’s some reason to believe the Holcim plant in North Texas is preparing to burn by-products from either the Canadian Tar Sands, the Permian Oil Field, or both, as fuel.

Baking rock to make cement takes a lot of heat. Regardless of how new or old a cement kiln is, regardless of the pollution controls a kiln has, every cement maker in the world still has to employ the same age-old process of applying a 2000 degree open flame to a mix of limestone and other ingredients. A third or more of the cost of running a cement plant is keeping that open flame consistently hot enough to do the job.

This is the reason cement kilns will always try to find cheap, free, even profitable sources of fuel for that flame. Hazardous and industrial wastes that can be diverted from incinerators or landfills can be burned in cement kilns for slightly less money because they don’t have to meet the same standards. Used tires and oil. Lottery tickets. Dashboards from cars. Even municipal waste is now being burned in kilns.

Burning anything causes air pollution. Burning wastes causes lots of conventional and exotic air pollution, including CO2. But just baking limestone rock also releases a lot of stored CO2. Even if there was some was to make cement without a flame, the heat needed would still release tons of CO2.

Worldwide the cement industry is estimated to be responsible for 5 to 7% of the planet’s CO2 emissions – larger then the airline industry. If the industry were a country, it would be the third largest emitter on earth, behind the United States and China.

Companies like LafargeHolcim are facing both public and financial pressures to reduce that number. In July European funds managing $2 trillion in assets called on cement companies to slash their greenhouse gas emissions, warning that a failure to do so could put their business models at risk. The mangers specifically mentioned LafargeHolcim and urged it to adopt the goal of net zero carbon emissions by 2050 and align itself with the Paris Climate Accords.

LaFarge Holcim has responded by initiating a series of technical innovations and pilot projects under the banner of “The Plant of Tomorrow” to prove its forward thinking.

Almost 300 facilities around the globe are targeted for inclusion in one or more of these “Plant of Tomorrow” projects, including a Canadian kiln installing a carbon-capture pilot project, an Ohio kiln building three wind turbines to secure its electrical needs, and kilns burning industrial waste as “low carbon” (if not low toxic) fuel.

Left out of this mix so far is Holcim’s woe-be-gone Midlothian plant. You might call it Holcim’s “Plant of Yesterday.” Despite having lots of stiff competition, Holcim not only operates the dirtiest cement plant out of the three doing business in Midlothian, but it’s the dirtiest in the entire state.

Holcim’s Midlothian plant is the largest Carbon Monoxide (CO) polluter among all 10 Texas cement plants – a sign of poor combustion. It’s the second largest Nitrogen Oxide (NOx) polluter among the bunch, emitting almost twice as much smog pollution as the other two Midlothian cement plants combined. It’s the largest PM 2.5 (Particulate Matter) polluter by far – almost 100 tons a year separate it from second place. It’s the largest Sulfur Dioxide (SO2) polluter by a large margin and releases four times as much Volatile Organic Compounds (VOCs) than the next highest plant. Almost all 2017 pollution numbers for Holcim have gone up over the last five years.  A plant that was already bad is getting worse.

Now add Holcim’s request for a new permit to burn 100% Petroleum Coke in one of its two kilns.

Pet Coke is a byproduct of oil refining. It’s a concentrated carbon solid residue that is left behind after the refining process has converted the bulk of the oil into liquid fuels such as gasoline and diesel.

Pet Coke is like coal, but dirtier. Pet Coke looks and acts like coal, but it has even higher carbon emissions than coal. On a per-unit of energy basis Pet Coke emits 5 to 10 percent more carbon dioxide than coal.  A ton of Pet Coke yields on average 53.6 percent more co2 than a ton of coal.

As well as significantly higher co2 emissions, Pet Coke also has high sulfur and toxic metals content than coal.

Because its a waste product, Pet Coke is cheap for Holcim to buy or it could even be free if a refinery wanted to get rid of its supply. And now, thanks to the exploitation of the Tar Sands and the oil boom in the Permian the US has lots and lots of Pet Coke. The heavy oil refining capacity in America is now the largest in the world, with over 40 percent of the global market.  Much of that production takes place on the Texas Gulf Coast in huge new expanded refinery complexes like Motiva and Total in Port Arthur. The capacity to produce Pet Coke in U.S. refineries has doubled since 1999. In fact, the annual production of Pet Coke is so large these days, it’s outstripped most of the usual uses for it and is “priced to move.”

Because Holcim wants to burn 100% Pet Coke, and it must have a reliable source to burn it 24/7, there’s reason to believe the company has signed a sweetheart deal with one or more refineries to supply it. Probably from the Gulf Coast, and probably from one of the refineries dealing in Canadian Tar Sands oil or Permian Basin product. Both are poster boys for irresponsible fossil fuel development with the Tar Sands and the Keystone Pipeline igniting modern Climate Crisis activism and the Permian becoming one the planet’s largest sources of Methane as tons of unused natural gas are burned off from thousands of rigs.

Currently, Holcim is “only” the third largest CO2 polluter among all ten cement plants in Texas, and fourth among all of Holcim’s U.S.  plants. But burning 100% Pet Coke in its Kiln #2 could change that rapidly by adding a whopping 400,000 tons more of CO2 to its annual totals. That would send it to #2 in Texas and #2 in the entire US Holcim fleet of cement plants. Not very climate conscientious. And probably not a number you want to tout in trying to sell your “Plant of Tomorrow.”

At the same time Holcim is trying to project an image of a concerned 21st Century corporate entity to the rest of the world, it’s doing business in Texas like its still 1999.

Officially, the State of Texas doesn’t care about CO2 pollution. Heck, officially it doesn’t even believe there’s a climate crisis. There is no regulatory system for controlling its releases and only the EPA bothers to track CO2 releases at all. So this increase in planet-melting pollution will go completely unaddressed in the permit proceedings themselves.

Also officially, despite the evidence, the State and Holcim both say no other kinds of pollution will increase when 100% Pet Coke is burned at Holcim. No increase in PM 2. 5. No increase in SO2. No increase in metals. Citizens don’t believe them. A group calling itself “Midlothian Breathes” has formed to fight the new permit and has already caught regulators off guard asking tough questions about new emissions.

But trying to get the State of Texas to do the right thing about air pollution is an uphill fight. Instead, perhaps citizens should take these embarrassing numbers directly to LafargeHolcim, who’s claims of new fund corporate responsibility are belied by them. Contrasting its Texas operations with those of the rest of its facilities may be a way to shame the company in its own European backyard. Officially the company may still be able to be embarrassed. Texas state government left that possibility behind years ago.

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2019’s “ozone season” came in like a lamb but is headed out as big, wheezy lion.

A three-day stretch from Thursday September 5th to Saturday the 7th that combined triple digit temperatures with lots of air pollution was enough to push Dallas-Fort Worth smog numbers for the year over 2018’s annual average.  It was the first year-to-year increase in ozone levels since 2015, and more than enough to insure DFW will be in violation of the Clean Air Act for the 28th year in a row.

Because the formula for arriving at these averages is so convoluted, discounts the highest three numbers, and is stretched out over 8-hour periods, it takes a lot ozone to make them go up even incrementally. Raising the annual average by even one part per billion (ppb), from 76  to 77, as occurred by Saturday evening, hides a lot of Really Bad Air. Smog levels were in the 90’s and even close to 100 parts per billion at monitoring sites in the northern part of the Metromess. EPA’s national standard for 8-hour exposure to ozone is a 70 ppb average.

Three sites saw their 2019 highs set during this 72 hour period. Frisco had an eight hour average of 88ppb on Saturday, Keller 84 ppb and North Dallas 83ppb. There were four hours on the afternoon of the 6th when smog was over 90 ppb in Frisco.

That’s reminiscent of the bad ‘ol days from the Turn of the Century when levels in the upper 90’s and even topping 100 ppb were routine. Since 2000, there’s been a more or less steady fall in smog in DFW thanks to better controls on combustion-powered vehicles, and the citizen-induced decreases in pollution from Midlothian cement plants and the retiring of East Texas coal-fired power plants. In 2000 DFW’s annual ozone average was 102 ppb. It’s taken 20 years to lower that number to the high-to-mid 70’s. For the last three years we’ve seen decreases of 3, 1 and 3 ppb. 2019 halts that downward trend.

Beside the human health toll these numbers represent – an increase in asthma attacks, ER visits, strokes and heart attacks. – they also represent a challenge to government. This increase comes as the usual planning process to reduce dirty air in DFW sits in tatters. In fact, there really is no process anymore.

In the past, the North Central Texas Council of Governments (NTCOG) would bring the Chambers of Commerce, elected officials and some environmentalists together to cobble out a list of proposed strategies to reduce smog, then submit it to the Texas Commission on Environmental Quality in Austin where it would get watered down by corporate lobbying. Nevertheless, those past plans did have an influence on tightening emissions for ancient cement kilns and other industrial sources and they can take some credit for the two-decade decrease in smog.

But that process hasn’t taken place since even before the current administration took office. The last plan submitted by the region to the state was in 2013. Because Austin kept ignoring most of the region’s recommendations, NTCOG just gave up trying after that. It’s Clean Air Steering Committee was disbanded and hasn’t met for six years now. Despite approaching our fourth decade of illegally bad air there’s no official body in DFW working on a regional clean air plan. Everything is being run by Greg Abbott’s state agency  – one that doesn’t believe there’s a climate crisis, wants to increase permissible exposure for dangerous pollutants, and whose former Toxicologist in now leading the Trump administration’s efforts to roll back federal pollution standards.

It’s doubtful a single part per billion rise in the regional average will prompt reconsideration of this laissez-faire approach. But it should.

Before the 2016 election, Downwinders was trying to pave a path for the federal government to take away the power of Austin to determine DFW’s clean air progress. We had hoped to have EPA delegated as the “final cut” author of a new clean air plan. Trump’s election made that impossible. But should this administration be gone by 2021, that strategy is still one local residents would be wise to pursue. As long as the State’s environmental agency is in the hands of anti-science flunkies and fanatics, there will be no concern about DFW smog in Austin.

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One of these is not like the other

What if you found out an industrial polluter was operating in your densely-populated neighborhood and the state told you not to worry because an obsolete computer model of the polluter’s releases 17 years ago and 500 miles away, in a desert, performed by the polluter themselves, said everything was OK?

That’s exactly the situation Joppa residents find themselves in as the Texas Commission on Environmental Quality (TCEQ) goes through the motions of renewing one of the permits of the many industrial polluters located in the community.

Austin Industries’ asphalt batch plant sits next to the Marietta Martin (TXI) concrete batch plant in Joppa, and both are in the Union Pacific switch yard and all of those are adjacent to the giant Tamko asphalt roofing factory.

Austin has applied to the TCEQ for a renewal of its 10-year old air permit for its Joppa plant and gave notice last December. Legal Aid of NorthWest Texas requested a contested case hearing on behalf of the Joppa Freedman’s Town Association and Downwinders at Risk requested one on behalf of resident Jabrille McDuffie.

To absolutely no one’s surprise, TCEQ’s Executive Director recommended against such a hearing at the beginning of August in comments mailed out to all parities. He argued that contrary to the opponent’s claims there was sufficient evidence that Austin Industries permit in Joppa was following the law and was “protective of human health.” Previous “air quality analysis,” the Executive Director says, have concluded such already.

The entire basis of that “air quality analysis” is the computer air modeling performed by Austin Industries’ hired contractors and supposedly double-checked by the state…in 2002.

Just like any other computer model, it all depends on the variables: volume of air pollution, local meteorology, stack height, local “receptors” aka people or animals who live by or near the facility, and even local terrain. Winds do one thing to air pollution on the open plains and another in the middle of a city block.

Because of these variables, an Exxon refinery that wants to build a facility in Houston with the exact same design as is has in Arkansas still has to submit a separate computer model to account for the distinct surroundings in the new location. The one from Arkansas just won’t do for Houston.

Or at least that’s the way things are supposed to work. But like so much else in Southern Dallas these days, things aren’t working the way they’re supposed to.

According to the TCEQ the Austin Asphalt facility is a portable asphalt batch plant operation. That means it wasn’t built specifically for its current Joppa site. It was moved there and it can be moved somewhere else.

In 2002 it first operated in Hockley County, a rural part of Northwest Texas near Lubbock some 400 miles west of Joppa. It moved to its current location in Joppa in 2008.

In 2002 the TCEQ let Austin Industries use what’s called a “SCREEN3” air model to determine if the air pollution from its asphalt batch plant’s was a threat to anyone in Hockley County. Again unsurprisingly, the firm hired by Austin Industries to do the computer modeling found it was “protective of human health.”

TCEQ says the Austin Industries’ asphalt plant has never been subject to any additional “impacts evaluation.” besides this 2002 review. 

That means the only air modeling ever done for this Austin asphalt plant was while it was operating in rural Hockley County in 2002. There has been no air modeling of the plant since it came to Joppa in 2008.

In 2002 the Austin plant was in West Texas and used a rural air model. In 2019 they’re still using for it for operation in Joppa.

Besides the most obvious and important difference in population density between unincorporated Hockley County near Lubbock and inner city Dallas, all of the variables in the 2002 modeling apply only to the Hockley County location. Meteorology, stack height, and surrounding terrain among them. In fact, the entire model was defaulted to a “rural” versus “urban” option in 2002.  This renders the modeling scientifically useless in its current location in Joppa.

But that uselessness isn’t keeping the Executive Director of the Texas Commission on Environmental Quality from citing it to justify renewal of Austin’s air permit.

There’s also the matter of the age and limitations of the SCREEN3 model. In 2011 EPA replaced it with something called the “AERSCREEN” model. In doing so the agency called the old model “outdated and said “there are no valid reasons” to keep using SCREEN3.

And it’s not just the EPA. State environmental agencies, like the Arizona Department of Environmental Quality, have quit accepting SCREEN3 modeling.

Alex De Visscher, Associate Professor and Canada Research Chair in Air Quality and Pollution Control Engineering at the University of Calgary, writing in an 2013 text book entitled “Air Dispersion Modeling: Foundations and Applications,” said SCEEN3 is a product of a previous generation of air dispersion modeling” and “is no longer a recommended model… it does not allow for multiple sources, and it does not include atmospheric chemistry or deposition.” 

These exclusions are important. There are multiple sources of Particulate Matter 2.5 air pollution at Austin Industries’ plant in its Joppa location, including piles of raw material, and industrial combustion at the site. SCREEN 3 modeling didn’t and wouldn’t reflect these multiple sources of pollution. And of course when you’re talking about PM 2.5 pollution, as you are with an asphalt batch plant, the atmospheric chemistry and deposition, or fallout, is critical.

TCEQ’s own air modeling guidelines say so:

“Air dispersion models utilize dispersion coefficients to determine the rate of dispersion for a plume. Dispersion coefficients are influenced by factors such as land-use / land-cover (LULC), terrain, averaging period, and meteorological conditions. Evaluating the LULC within the modeling domain is an integral component to air dispersion modeling. The data obtained from a LULC analysis can be used to determine representative dispersion coefficients. The selection of representative dispersion coefficients may be as simple as selecting between rural or urban land-use types. For the ISC, ISC-PRIME, and SCREEN3 models, the dispersion coefficients are based on whether the area is predominately rural or urban. The classification of the land use in the vicinity of sources of air pollution is needed because dispersion rates differ between rural and urban areas.”

The TCEQ itself says it makes a fundamental difference whether the air model for a polluter is run for urban or rural terrain. Yet for over a decade TCEQ and Austin Asphalt have misused the results of a “rural” computer model to misleadingly assure inner-city Joppa residents that the company’s asphalt plant posed no harm.

What’s more, the modeling performed in 2002 only examined “asphalt vapors,” a made-up, vague pollutant category that can’t be monitored or measured. It didn’t examine Particulate Matter 2.5 pollution or specific Volatile Organic Compounds that make up those “vapors” and was therefore incomplete in the extreme.

So despite all the verbage the TCEQ’s Executive Director uses to tell Joppa residents that past “air analysis” has shown Austin Industries’ plant to be protective of human health, in truth the only “analysis” ever done was performed 17 years ago in a sparsely-populated rural location 400 miles away from its current location, with what TCEQ admits are totally inaccurate modeling inputs by company consultants. It didn’t include all priority pollutants or even all sources of air pollution from the facility and the model used is now considered obsolete by EPA, modeling experts, and other state environmental agencies.

Joppa residents deserve better.

In its response to the Executive Director, Downwinders at Risk specifically requested TCEQ delay further regulatory action on this permit renewal until it can conduct a modern comprehensive air modeling impact analysis for Austin Asphalt’s current operation in Joppa that requires an evaluation of all on-site sources of pollution, including fugitive and mobile sources, on the Austin Asphalt site, off-site near-by sources of pollution within a three kilometer (1.86 mile) radius of Austin Asphalt’s facility, and representative monitored background concentrations obtained from local Joppa neighborhood monitoring as well as modeling of permitted maximums emission rates form all sources.

On September 11th the Texas Commission on Environmental Quality will take up the Austin Industries permit renewal at its headquarters in Austin. Both Legal Aid and Downwinders at Risk representatives will be present to answer any questions from the Commissioners but will not be allowed to make any statements. We’ll let you know the outcome.

One might reasonably ask why the City of Dallas itself isn’t fighting this permit renewal? After all in 2007, the city took on a string of proposed coal-fired power plants that it said would increase air pollution for Dallas. But to date that same city has never bothered to try and stop an industrial polluter from opening shop or renewing its permit in one of its most abused neighborhoods.

This dishonest use of a irrelevant model by the state’s discredited environmental agency shows why it’s imperative the City of Dallas – and all municipalities in Texas –  change the way they do business and be proactive in addressing their environmental justice and environmental health issues in their own city limits.

Too often city representatives default to state or federal officials on the environment when they should be the first line of defense, not the last. City officials’ reliance on a failed state agency to perform its job as environmental protector is what caused Shingle Mountain. It’s what caused this situation in Joppa. To change that means changing both policies coming out of City Hall and current City Hall culture. Environmental Protection is a Do-It-Yourself proposition these days.

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