There was at least one truth uttered by Steve Everley, the professional PR spokesperson for Energy in Depth, itself the PR arm of the Gas Industry, during his testimony at last Thursday's EPA ozone standard hearing in Arlington:
"…natural gas producers will be significantly impacted by EPA’s proposal to reduce the National Ambient Air Quality Standard for ozone from 75 parts per billion to between 65 and 70 ppb."
Indeed. At the rate things are going in Austin and DC, it might be the only thing to impact the industry's large emissions of pollution for many years to come. Left unsaid by Everley was why the industry would be impacted by such a lower ozone standard – because in many parts of the country now, including the DFW area, smog-forming pollution from the gas industry is contributing significantly to higher ozone levels.
Even the governmental affairs branch of the gas industry, otherwise known as the Texas Commission on Environmental Quality, admits that facilities like compressors, storage tanks, pipelines, and de-hydrators found by the thousands in the western part of the Metromess contribute more smog-forming Volatile Organic Compounds (VOCs) than all the "on-road" vehicles in North Texas combined. This is true not only at the present time, but will be true at least three years into the future, according to TCEQ's own estimates.
Gas facilities also account for the third largest source of smog-forming Nitrogen Oxide pollution in DFW, according to TCEQ numbers included in their recent air plan submitted to EPA – only a ton per day less than all "non-road" vehicles in North Texas like construction equipment, and well ahead of "point sources" like the Midlothian cement kilns and local power plants.
In all, TCEQ predicts that 35,335 tons per year of smog-forming pollution will still be coming from the region's gas industry in 2018. That's a lot. It's so much that, as the TCEQ also demonstrates with its computer modeling, even a tweak here and there in gas pollution estimates can make big differences in the levels of ozone at monitors in places like Denton and Keller and Eagle Mountain Lake – traditionally the worst-performing air quality monitors in North Texas.
And that's why a lower ozone standard is a threat to the industry. The very air quality monitors the industry affects most with its pollution are the ones driving the region's high smog levels. Lowering the ozone standard means it would have to spend money to reduce those emissions significantly. It means it would have to spend money to prevent the kind of huge "accidental" releases of smog-forming pollution released by the Mansfield compressor on Thursday even while Steve Everley was testifying to EPA.
After giving her own testimony to EPA on Thursday morning, Earthworks' Sharon Wilson and Mansfield Gas Well Awareness board member Lance Irwin headed out to the Summit Midstream Partners Compressor Station behind Mansfield's Performing Arts Center, with an infrared, or FLIR "thermal imaging" camera. Such a device is capable of recording the kinds of VOC emissions that are often smelled and inhaled by surrounding residents, but can't be seen with the naked eye.
The Summit compressor and the two nearby Eagleridge gas wells have been the scene of many different complaints from the surrounding Mansfield neighborhood – everything from airborne foam landing in backyards to oily deposits landing on car finishes. On Thursday, Wilson and Irwin were responding to a new series of complaints about awful smells. When they showed up, what the two recorded was a massive "emergency blowdown" (versus the "planned" kind). While filming the event, Wilson suffered health effects familiar to gas facility neighbors and was overwhelmed by the obvious hydrocarbon fumes. Once you see her video, you understand why:
Such a blowdown was exactly what Lance Irwin had warned the Mansfield City Council about only three days before, during comments directed at slowing down or denying the permit for a new compressor, 34 wells, 12 tanks and a assortment of other facilities at an Edge pad site near Debbie Lane in town. He pointed out that industry and government estimates about emissions never take these kind of catastrophic events into account – form a short-term toxic exposure perspective, or as it turns out, from an air quality, smog-creating perspective. And he's right.
In this regard, these kinds of accidents are no different than the infamous industrial "burps" from refineries and chemical plants along the Houston Ship Channel that lead to smog spikes downwind. There are 650 large compressor stations in the DFW "non-attainment" area. How many are experiencing blowdowns on any given day? How many are affecting ozone levels in the spring and summer? The TCEQ estimates included in its DFW air plan don't even try to quanify them.
Because gas facilities like compressors are subject only to "standard permits," are located diffusely around a region, and don't officially emit a de minimus amount of air pollution, they're not subject to the federal rule of off-setting. That's when a new polluting facility locates in an already smoggy area like DFW and has to pay to cut smog pollution elsewhere if it wants to emit the stuff itself. If a new cement plant or power plant were to locate in DFW, it would have to pay to reduce a ton and a half of smog-forming pollution for every ton it wanted to release. Gas facilities don't have to do this – even though collectively they emit more smog-forming pollution than all the cement plants and power plant in the non-attainment area!
EPA has tried to argue that a company's different facilities are all tied together and should be counted as a single source, and so subject to off-setting regulations. But the courts have ruled against them.
Rising gas industry pollution and the absence of any official brake on its growth like off-setting is a large reason, maybe the primary reason, why DFW hasn't seen the kind of air quality progress it should have by now. Until this last summer's cooler and wetter weather gave us relief, ozone levels had been stagnating or even rising since 2009 – or about the time the industry invaded North Texas in large numbers. There's no question that had the Barnett Shale boom not happened, we'd have much cleaner air by now.
But it did and we don't. And so that's why a lower ozone standard is perhaps the only way that the gas industry will ever be forced to clean-up its act – especially on the widespread regional level we require to get to safe and legal air. Just like it has with the Midlothian cement plants, the need for lower smog levels can force the state's and industry's to act to add controls. It's a long-term fight, but one of the only paths to across-the-board change versus the city-by-city slog activists have had to rely on.
National Resources Defense Council lawyer John Walke has a great takedown of Steve Everley's spin on Thursday. And the tireless cross-country DeSmogblog reporter and photographer Julie Dermansky has a good read on the Mansfield fight that you should check out. But the most compelling rebuttal to both industry PR and local governments who want to ignore their own responsibility in this mess is probably Wilson and Irwin's two and a half minutes of video.