Thank You. Citizens Might Have Just Saved The Local Air Planning Process…From Itself

kids-thank-you-cards copyA year from now, last Thursday' meeting in Arlington may be seen as a turning point.

Local residents refused to let the air quality planning process die, showing up in numbers that forced officials to switch to a larger room, and making sure their opposition to another state "do-nothing" air plan was heard loud and clear.

Their participation had already changed the day's agenda. Included was a breakthrough UNT study that directly challenges the Texas Commission on Environmental Quality's claim that natural gas emissions don't increase DFW smog.

UNT's Dr. Kuruvilla John's presentation of the new study received quite a bit of media coverage, before, during, and after Thursday's meeting. You can find some of the best coverage by clicking on the links below.

UT-Austin Study Reveals "Underestimates" 

Dr. John's presentation influenced another researcher's slide show as well. Scheduled to speak about older, more generic ambient air measurements for ozone, Dr. David Allen of UT Austin instead presented more recent research into gas pollution as well.

Overlooked in the debut of the UNT study, Allen's constant monitoring of one drill site in Fort Worth revealed that the TCEQ was underestimating emissions from the pneumatic valves at the site by 159%.

That was news to both citizens and TCEQ, who said they hadn't looked at Allen's research and hadn't corrected their inventories to account for such underestimates. Valves like these are powered by natural gas, are quite numerous on gas equipment, and account for a large percentage of VOCs released from a fracking site.

A Better Picture of Oil and Gas Pollution

Citizen cross-examination of TCEQ staff members present at the meeting also revealed a different look at the volume of Oil and Gas industry pollution in the 10-county DFW "non-attainment area"

Up to Thursday, TCEQ was dispersing Oil and Gas pollution across several categories, making it impossible to show the true total impacts.

Here's an example of the way TCEQ likes to present the info:

SOURCES OF SMOG-FORMING NITROGEN OXIDE POLLUTION (NOx)
IN DFW's NON-ATTAINMENT AREA

 
1. "On Road" vehicles            113.21 tons per day
2. "Non-Road" vehicles"          39.87 tpd
3. "Area"                                  30.76 tpd
4. "Other Point Sources"         24.95 tpd
5. "Locomotives"                     18.90 tpd
6. "Cement Kilns"                    17.60 tpd
7. "Electric Utilities"                   15.02 tpd
8. Oil and Gas Production   12.21 tpd
9."Airports"                              11.77 tpd
10. Oil and Gas Drill Rigs       5.83 tpd

TOTAL 290.12 tpd

This makes it look like Oil and Gas pollution is not that big a deal.

But it turns out TCEQ is hiding 28.44 tpd of NOx gas compressor pollution in the "Area" and "Other Point Source" categories.

This was brought out in questioning on Thursday. Once you add these figures to the other Oil and Gas emission numbers spread out over different categories, this is what you get:

SOURCES OF SMOG-FORMING NITROGEN OXIDE POLLUTION (NOx)  
IN DFW's NON-ATTAINMENT AREA

1. "On Road" vehicles         113.21 tpd
2. Oil and Gas Industry       46.48 tpd
3. "Non-Road" vehicles        39.87 tpd
4. "Locomotives"                    18.90 tpd
5. "Cement Kilns"                  17.60 tpd
6. "Area"                                15.93 tpd
7. "Electric Utilities"                15.02 tpd
8. "Other Point Sources"        11.34 tpd
9. "Airports"                            11.77 tpd

TOTAL 290.12
(Earlier today we put out an e-mail alert that left 10 tons off the "Area" category in this second chart, greatly affecting its ranking. That mistake is corrected in this version of the chart and we apologize for any confusion that might have caused)

When you quit playing the state's shell game with Shale pollution, the Oil and Gas industry becomes the region's second largest source of NOx pollution – the kind of pollution TCEQ says is the main driver of smog in DFW (not even counting all the pollution from O&G fracking trucks still hiding in the "On Road" category).

There have been control measures for cars to reduce NOx. There have been controls on heavy duty equipment and trucks to reduce NOx. There have been new controls on locomotives to reduce NOx pollution. There have been controls on airport ground equipment to reduce NOx pollution. There's even been middling controls to reduce the NOx from the Midlothian cement kilns. But where's the controls to reduce NOx from the Oil and Gas industry – the one source in this list that hasn't had the same kind of regulatory attention? Good question – save it for next time.

Citizen Participation is Crucial

This is the kind of close examination the TCEQ hopes to avoid by limiting debate on this new clean air plan, scheduled to be submitted to EPA by July next year. And it's exactly why citizens need to keep showing up.

Because of the momentum and interest coming out of Thursday's meeting, citizens also got the next scheduled pow-wow of the local air planning process moved up to late May or early June instead of waiting until July.

We're already taking suggestions for what you want to see on that agenda, so don't be shy. And thank you again for restoring some tiny amounts of integrity into a process that's been swamped by Rick Perry's indifference.

You're making a difference, and that's all anybody can do. This last Thursday it was a big difference. Let's try to do the same in May.

Some Coverage of Thursday's Air Planning Mtg.

Channel 8: "UNT researchers say fracking a contributor to North Texas smog problem"

Texas Observer: "Studies: Links Between Fracking and Smog Pollution Stronger Than State Claims"

Star-Telegram: "Natural Gas Production Contributing to Higher Ozone Levels, study Finds"

Denton Record Chronicle: "Officials: No New Plans to Clean Up Air"

 

HOW YOU CAN SAY "THANK YOU" BACK

Here's what Downwinders at Risk did  this past week to make sure Thursday's air quality meeting wasa success: 

1) Pressed for and got the UNT study linking fracking to smog on the meeting agenda after being told it would not be included.

2) Sent out releases to the media advertising the UNT presentation.

3) Sent out alerts to you and others to let you know about the new UNT study and the meeting itself.

4) Sent out a "Citizens' Guide to the Meeting" so you could be prepared for Thursday.

5) Showed-up at Thursday's meeting with handouts showing the lack of air quality progress in DFW and the lack of a complete plan by TCEQ

6) Used our questions to reveal how TCEQ was hiding Oil and Gas industry pollution totals in their data

7) Pressed for and got an earlier "next meeting" of the local air quality planning group

8) Sent out this follow-up so that everyone knows what went on and what the news is from the meeting

A local forum for clean air issues was about to disappear.

Only the last month's mobilization of citizens prevented that from happening on Thursday.

Who began that mobilization?

We did.

We really need your financial help to keep doing this. We don't get state or national funding – just local money from people like yourself.

Please donate here.

Thanks. We very much appreciate it.

We Won a Small Victory – Now Come Take Advantage of It

SmallVictoriesThis is why citizen participation matters.

Last week, local officials were balking at reserving a slot at next Thursday's regional air planning meeting for a presentation by UNT researchers on how gas industry emissions from the Barnett Shale could be adding to DFW's chronic smog.

After reading about the UNT research in the Denton Record Chronicle, Downwinders at Risk and State Representative Lon Burnam specifically asked the local Council of Governments to include the UNT work on the agenda.

At first, we were told that there was already one technical presentation scheduled for the meeting and there wouldn't be any time for a second.

That struck us as strange, since in the past, every such meeting has always had more than one technical presentation.

When we pointed this out in an e-mail with links to past meeting agendas to prove the point, we quickly got a different response. Suddenly, there would be time for the UNT presentation.

That wasn't so hard was it? All it took was a little logical push back. But if we hadn't supplied it, Thursday would be looking a lot different.

Now, we're asking you to please come and help us push back a little more.

State environmental officials are on record as saying the air pollution from gas mining and production in the Barnett Shale is not adding to DFW's smog.

A lot of us think otherwise.

Come next Thursday, on the 17th, you can listen to the new UNT research on fracking air pollution and ask Texas Commission on Environmental Quality officials directly what makes them so sure that gas pollution isn't hurting local air quality.

Because the format of these regional clean air meetings are now so informal, anyone in the audience can ask questions of a presenter. That means you – if you show up.

It doesn't matter if you don't know the technical lingo. This is all about wind direction, weather, and things that pollute. There are no stupid questions.

The new anti-smog plan that the state is building needs all the public scrutiny it can get. It needs tough examination by people who care about clean air and the truth.

Next Thursday, you can help us put the state on the spot.

This is the first opportunity in 2014 to speak up and sound off about our decades-long smog problem. Don't let the TCEQ leave town without hearing from you.

We fought and won the right for you to listen to this research because we thought it was important. Won't you please come and take advantage of this victory?

We need a good showing to prove DFW residents are still mad about breathing dirty air.

NEXT THURSDAY, APRIL 17th
10 am to 12pm
North Central Texas Council of Government headquarters
616 Six Flags Drive

(After the meeting, State Representative Lon Burnam and Downwinders will be hosting a lunch time de-briefing, location to be decided, so stay tuned.)

Look, we know this is a small victory. But state officials don't want to talk about how gas industry pollution may be making our local smog worse, even though there's evidence that it is.

That's exactly why we think we need to keep bringing it up.

Winning the right to hear a new scientific presentation on the connection between gas pollution and smog may not seem like much of a win, but it is when the Powers-That-Be don't want you to hear it.

We know that small victories like this can lead to larger successes.

In the 1990's the same state agency that's now denying gas pollution has any impact on DFW smog was saying exactly the same thing about the Midlothian cement plants.

It took lots of push back from citizens who knew better before we got the state to admit it was wrong.

Now, Ellis County is in the DFW non-attainment area and the cement plants have controls on them they would otherwise never have.

We need the same effort in 2014 to show the state is as wrong about gas industry pollution as it was about the cement plants.

Right now, Downwinders is the only group committed to organizing citizens around clean air issues in DFW.

But we just lost a funding source that was critical to us and we need your help to keep the pressure on. This money paid for staff work in the field.It's very easy to give securely online here, or you can send checks to our P.O. Box at the bottom of the page.

We really need your help. Thank you.

Don’t Let Rick Perry Hold Your Lungs Hostage

Perry A-OK cropped

Got Asthma?

Live Next to a Gas Site?

Downwind of a Cement Plant?

Just Concerned About What's in that Layer of Haze on the Horizon?

No Matter Your Cause, You Have a Stake in Building a Better DFW Anti-Smog Plan.

Beginning this month, things get serious about regional air quality.

THIS SUNDAY Citizens Strategy Meeting on the new DFW anti-smog plan/ 3-5 pm /Texas Campaign for the Environment offices/3303 Lee Parkway, Dallas (across from Lee Park)    Sponsored by State Representative Lon Burnam and Downiwnders at Risk.

THURSDAY, APRIL 17th Next official local meeting on the DFW anti-smog plan/10 am to 1 pm/ North Central Texas Council of Governments HQ/616 Six Flags Road, Arlington (just down the street from the entrance to the amusement park)

While the Texas Commission on Environmental Quality is moving ahead with a scheme that avoids new pollution controls, local officials are more skeptical of that approach and and are talking about additional "control measures" on sources of air pollution like cars, power plants, the gas industry, and cement kilns.

Despite three state air plans over 15 years, DFW has yet to meet the 1997 federal smog standard of 85 parts per billion (ppb) of ozone.
Now, even as we're still trying to meet an almost 20-year smog standard, a new standard of 75 ppb is being enforced across the country for the first time. The deadline for meeting it is 2018. The plan for how to meet it must be turned into EPA by 2015 for a three year implementation. That plan is what's being written now. And you can help make it much better.

THE MYTH OF IMPROVING AIR QUALITY

In 2009, DFW's three year running average for smog pollution was 86 ppb of ozone. Last year it was 87ppb. Is that progress to you? The state says it is.

The fact is that after a decade of steadily falling smog levels, that decline has stalled over the last five years. Is it merely coincidence that those five years correspond to the Barnett Shale gas play maturing in the middle of DFW? Or the development of gas fields to the Southeast of us? If it's not new gas emissions, what's causing this stagnation in progress? The state says it doesn't know. But the TCEQ is sure that it can get smog levels down without new pollution controls on any industry – including gas and oil. Just like it was sure in 2011, when the state proposed its last plan without any new industry controls and guaranteed we'd be enjoying record-low smog levels by 2013. Instead, smog levels actually rose.

The reality is that Austin is trying to avoid any new controls at all while Rick Perry is running for President. Our lungs are being held hostage by Governor Perry's political ambitions. That's why we need your help.

5-reasons-smog-is-good-for-you-TCEQTHE TCEQ RATIONALE FOR INACTION

TCEQ says that a new federal gasoline mix with lower sulfur content will make car exhaust so much cleaner that no additional measures will be necessary to meet the new 75 ppb smog standard by the deadline of 2018. It says it's computer program tells it so. But that new mix won't be on the market until 2017, impacting only one summer out of three that'll be used by EPA to give us our running average.  Even then, to reach the new goal of no more than 75 ppb of ozone by 2018, DFW smog levels would have to drop by double digits in just four years. That's never happened before. And many of us don't believe it has any chance of happening without reducing pollution from the gas industry, the Midlothian cement plants, and other large sources. We need to expose the TCEQ's junk science and make sure safe and legal air for six million people is more important than Rick Perry's presidential ambitions.


 
A CHANCE TO REDUCE POLLUTION FROM ALL SOURCES

The most successful air plan DFW ever had was in 2007, when coal plants, cement plants, vehicles and other sources of air pollution were addressed through new control measures.

That was the last time we had a comprehensive approach. And we almost met the 1997 85 ppb standard. This new plan offers an opportunity to do the same –  if citizens can get organized. The DFW air plan is the "biggest fracking fight that isn't being fought" with a chance to seek region-wide pollution controls on the gas industry. It's a chance to bring state-of-the-art pollution controls to the Midlothian cement plants and East Texas coal plants. It's a chance to commit North Texas to more renewable energy, mass transit, and cleaner technologies of all kinds.

But first you have to show up.

Please come to the public strategy meeting this Sunday in Dallas to learn more about this clean air plan and what's being done to improve it. 

Then on April 17th, come to the next official meeting of the DFW clean air plan in Arlington to listen and comment on discussions about local air quality.

These meetings are open to the public and public participation. Tell officials you want MORE pollution controls on ALL sources. 

Don't Let Rick Perry continue to hold your lungs hostage.

The Biggest Fracking Fight That Isn’t Being Fought – DFW Air Plan Mtgs This Month

fracking-protests-uk-620xaSince fights over fracking began in the Barnett Shale, they've been mostly fights over specific permits, leases, or rules fought in one city at a time.

Other than an occasional trip to Austin or DC to stop or support some piece of legislation, the action takes place in whatever community is putting up the most resistance. Front lines are fragmented and move around a lot. There's not a single cause that's united the energy from the multitude of ad hoc groups and individual "fracktivists" into a focused campaign for regional change. The closest thing to more encompassing battles have been the recent victories in Dallas and the current kickass campaign in Denton. These feel like old Cold War skirmishes – proxy clashes standing in for the on-going larger war over the Barnett Shale's soul. 

But from now until the summer of 2015 there's a regional fracking fight waiting to be fought. It involves new bureaucracies and terms and mechanics, so it makes a lot of traditional fracking foes nervous. But the payoff is the potential to affect change throughout a 10-county area, including the heart of the urban Barnett Shale – Tarrant, Parker, Denton, Johnson, Wise and Ellis – as well as Dallas, Collin, Kaufman, and Rockwall.

What's the fight? It's over the new regional anti-smog plan, called a State Implementation Plan, or SIP. When a region hasn't met the federal standard for smog, also called ozone, it has to submit a plan to the EPA to explain how it's going to comply by the end of a three-year deadline. Despite at least three previous plans, DFW has never met the 1997 federal standard for smog. It's 85 ppb, or "parts per billion" concentration over 8 hours measured by approximately 20 stationary monitors scattered over the area. The closest we've come has been 86 ppb of ozone in 2009.

The new DFW plan is supposed to be designed to meet an even more ambitious target – no monitor higher than a three-year running average of 75 ppb of ambient air by 2018. We're at 87 ppb now.  To reach the new goal, DFW would have to drop 12 parts per billion in ambient smog levels in four years -something that's never happened before.

Ozone/smog is created by a combination of Nitrogen Oxides (NOx) from combustion sources and Volatile Organic Compounds (VOCs) from combustion sources and evaporation sources mixing in daylight. The more sun, the more ozone.

What are combustion sources of NOx and VOCs? Power plants and cement kilns. Every boiler and furnace and oven. Every internal combustion engine. Every diesel engine. Anything with a flame or a spark.

What are evaporation sources of VOCs?  Gasoline pumps,tanks and paint shops. 

An anti-smog plan is supposed to look at all the sources of smog-forming pollution in a region and find the cheapest and easiest ways to reduce it. Past plans have been responsible for putting more controls on coal-fired power plants and the Midlothian cement plants, as well as creating HOV lanes and tightening inspection standards for vehicles. But one large category of smog-forming emissions has been left largely untouched by past air plans – the gas and oil industry.

It's not because gas and oil sources aren't capable of contributing to DFW smog. Start with all the trucks that are needed for each well and the NOx and VOC emissions they produce. Then the drilling rig itself. Some cities now require electric motors, others still allow diesel and the NOx and VOCs they produce. Think about all the chemicals being dumped into a well and then flowing back out, many of them VOCs. Flares are sources of both NOx and VOCs. Storage tanks and pipelines are huge sources of escaped evaporated VOCs. Diesel compressors are huge sources of NOx. There isn't a part of the oil and gas fuel cycle that doesn't produce smog-forming pollution.

It's not because the oil and gas emissions are insignificant.  In 2011, the Texas Commission on Environmental Quality estimated that the VOCs being released by all the oil and gas facilities in the DFW area were greater than the volume of VOCs being released by all the cars and trucks on the road in the same region. In 2012, a Houston Area Research Council report estimated that a single flare or compressor could raise downwind ozone levels 3 to 5 parts per billion as far as five to ten miles away.

No, the oil and gas industry haven't been touched by these state anti-smog plans because the state doesn't want to impose new regional regulations on an industry. It's nothing personal. Austin doesn't want to impose new regulations on any industry. The last serious SIP was in 2007 – before the Barnett Shale boom and Rick Perry's presidential campaign. Since then, it's been one excuse after another from TCEQ about why no new controls are necessary – even though DFW air quality progress has stopped and we're still in violation of a 20-year old smog standard.

It's also true that the oil and gas industry hasn't been touched by an air plan because no one's made them. No DFW anti-smog plan has been the focus of a fracking campaign like the recent Dallas Trinity East permits, or the Denton petition drive.  There been no pressure on state government to respond to a regional demand for action.

But the new DFW air plan does offer gas activists a chance to get reforms outside of their own city limits. For example, it could be the goal to include mandatory electrification of compressors in this plan. It's been estimated that 60 % or more of the air pollution from the gas fuel cycle comes from compressors. Electrification doesn't solve all their air pollution problems but it takes a huge bite out of them because the compressors are no longer being run by locomotive size diesel engines. Electrification of new compressors and a phase-in to replace existing diesel engines could reduce not just smog pollution, but toxic air pollution and greenhouse gases by thousands of tons a year.

Even if Austin rejects such proposals, there's a part of every plan called the "Weight of Evidence" category that's more inclusive to voluntary measures. A recommendation for cities and counties to demand electrification of all compressors in the DFW region isn't as immediate as a state-sponsored mandate, but it's an official good housekeeping seal you can take to local city councils and pass one by one until it does become a de facto regional policy.  This is exactly what happened with Downwinders' Green Cement procurement campaign from 2007-2011 aimed at getting rid of old wet cement kilns in Midlothian. A short recommendation to local governments about where to buy their cement in the 2007 SIP was turned into a model ordinance by Dallas and then passed by a dozen other entities, one by one, over the next two years. by the end of this year, there will be no wet kilns lift in Midlothian.

The same thing could happen with compressors in this new plan, or green completions, or tanks, or pipelines in this new DFW air plan – if activists are willing to invest the same amount of time and energy into a regional fight as they do in their own backyard battles.

You have a couple of chances in April to dip your toes into the SIP Process. This coming Sunday, April 6th, from 3 to 5 pm at the Texas Campaign for the Environment office in Dallas, State Rep Lon Burnam and Downwinders at Risk will be hosting a strategy meeting for folks who want to know more about how to take advantage of this new air plan. Central to this strategy is involving more gas activists to win a regional fight, so y'all come.

Then on April 17th, at 10 am at the North Central Council of Governments Headquarters in Arlington, there's a meeting of the SIP "technical committee" that will be hearing presentations from the state and others about DFW's smog problem. Don't let the "technical committee" name fool you. These are open to the public and anyone can attend. In fact, this is your chance to ask questions of the state and the experts.

And to make it more interesting, we think we've managed to convince the Powers That Be to include UNT graduate student Mahdi Ahmadi's presentation on Barnett Shale contributions to DFW ozone as part of the April 17th meeting. This was the study recently featured by Peggy Heinkel-Wolfe in the Denton Record Chronicle:

According to the results, the air monitoring sites surrounded by oil and gas production activities, generally on the west side of DFW, show worse long-term trends in ozone reduction than those located farther from wells on the east side of DFW.

His spatial analysis of the data showed that ozone distribution has been disproportionally changed and appears linked to production activities, perhaps an explanation why residents on the western side of DFW are seeing more locally produced ozone, particularly since 2008.

If this one fails, another new air plan will not be due until at least 2019 or 2020 at the earliest. This is our only chance until then to affect the gas industry over a wide area instead of just one permit or one city at a time. Let's try to make it count.

DFW Anti-Smog Plan Strategy Meeting

Sunday April 6th 2-5 pm

Texas Campaign for the Environment Offices

3303 Lee Parkway #402 • Dallas, TX 75219 – across from Lee Park

Hosted by St. Rep. Lon Burnam and Downwinders at Risk

 

DFW Air Plan Committee Meeting – open to the public

10 am to 12 noon

Thursday April 17th

North Central Texas Council of Governments

616 Six Flags Drive, Arlington  – across the street from the amusement park