In preparation for next week’s public unveiling of its proposed DFW clean air plan, the Texas Commission on Environmental Quality has scheduled a last-minute, out-of-nowhere, meeting for this Thursday, July 7th, of something called the Dallas-Fort Worth (DFW) Photochemical Modeling Technical Committee.
This is a CYA development on TCEQ’s part to legitmize the switching of one transportation model for another in the DFW “plan.” After using the same EPA model/software for a number of years, including the first three-quarters of the time it was crafting the DFW effort, TCEQ decided it wanted to use a new EPA model/software. One it had been actively resisting using for over a year. Why? Because the new model gets them more estimated Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOC) pollution from vehicles. The more pollution assigned to a car, the more pollution you reduce when you take it off the road.
Since the entire TCEQ 2011 “plan” for DFW is predicated on a steady rate of trade-ins of older, more polluting cars for new, less-polluting cars over the next three years, this new model gives the Commission more reductions….in theory. You have to believe the TCEQ rate of return will stay constant, that the vehicles bought will indeed be significantly less polluting, and that other factors won’t cancel out any progress you make (no reining-in gas industry pollution). And you have to believe the TCEQ could be right about the effectiveness of one of its DFW air plans for the first time in 20 years. It could happen.
Downwinders has noted that, based on TCEQ’s timeline for the switch, the complete analysis of the new model/software will not be available until after the public hearing next week in Arlington. That means the public will have no opportunity to make comment on the adequacy of the new modeling, and thus the real plan – versus the one that used the old model being discussed up until last April. This strikes us as not honoring in spirit or letter the EPA’s renewed commitment to public participation, and could strike EPA the same way.
This Committee meeting this week may be an effort to dull that criticism, by saying that, “look, things are essentially wrapped up and ready to go and the hearing will actually be about the real plan and not that thing we discussed for most of the plan-building process.”
For those of you who want a preview of the gory details, or just want to see how creative the TCEQ can be in rationalizing this switch, the meeting is at the uncitizen-friendly time of 10 am this Thursday, July 7th in the Transportation room at the North Central Council of Government’s headquarters in Arlington at 616 Six Flags Drive.