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).
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.
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.
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.
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.
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.
Testify downtown and then come and hear Dr. Bullard testify at Paul Quinn.
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.
Increases Predicted in Air Pollution, including 100 more tons of PM a Year
Holcim Cement’s Midlothian cement plant has requested a permit application to the Texas Commission on Environmental Quality to release an additional 2700 tons per year of Carbon Monoxide and burn 100% Petroleum Coke in its Kiln #2. Holcim estimates these change will set of federally-mandated reviews for increases in emissions of Particulate Matter (PM), Nitrogen Oxide (NOx), Sulfur Dioxide (SOx), and Carbon Monoxide (CO).
Notice of the company’s permit amendment was published in the Midlothian Mirror earlier in the month.
Holcim is one of three very large cement plants doing business just south of I-20 in Midlothian in what is the largest concentration of cement manufacturing in the U.S. The other two are TXI and Ash Grove. These are not batch plants. These are where the batch plants get their product. With annual air pollution emissions in the thousands of tons, any one of these kilns would easily be the largest “stationary” industrial source of air pollution in North Texas. Combined, they represent a mega source of air pollution for DFW.
Review of the numbers in the permit application show the company wants to scrap its current limit of a little over 4000 tons a year for Carbon Monoxide and replace it with a higher 7112 ton per year ceiling. In addition, the difference between actual emissions and proposed changes could result in 100 tons more of Particulate Matter, 260 more tons of smog-forming Nitrogen Oxide, and 1700 additional tons of Sulfur Dioxide.
Missing from the permit analysis is the impact of the changes on CO2 climate crisis pollution. Petroleum Coke is nothing but carbon. It releases a lot of CO2 when burned. Burning 100% Petroleum Coke at Holcim will significantly increase this kind of air pollution. Cement plants are already a huge source of CO2 worldwide and Texas leads the country in CO2 pollution.
Overall, it’s the largest requested air pollution increase from any of the three Midlothian kilns in a very long time. And it reveals how badly the snake-bit 20th Century Holcim plant is aging.
Holcim’s current air pollution levels are already way out of sync with the other two, newer cement plants in Midlothian, and the Holcim facility has had a long troubled history with what its owners claim is a problem with the area limestone – the same patch of limestone the other two plants use. Holcim is already releasing 14 times the amount of four major air pollutants compared to Ash Grove’s 2014 renovated plant, and three times the amount of those same pollutants as TXI. This permit amendment would make the difference even starker.
Clearly Holcim has a problem child cement plant. Since Kiln #1 opened in 1999 it’s never performed to expectation. Because it would otherwise have set off a national non-attainment area for Sulfur Dioxide, Holcim had to add scrubbers to the plant before it even opened. When Kiln #2 was added in 2000, Holcim predicted it would cut pollution in half. Instead it doubled air pollution and by EPA decree the company had to add new pollution controls and buy Downwinders at Risk an independent scientist to monitor their operations. Now Holcim is saying their longstanding plan to reduce Carbon Monoxide pollution at that second kiln just didn’t work out and they need to increase their CO “permit allowables” by over 2700 tons a year.
Even for a very large cement plant, that’s a significant increase in pollution. CO pollution is a red flag for poor combustion, which is always worrisome when you’re looking at a facility of Holcim’s size that’s burning a flame at 2400 degree flame 24/7/365. Poor combustion at a cement plant burning tires and industrial waste, as Holcim does, or even coal and Petroleum Coke, means the creation of more “Products of Incomplete Combustion,” or “PICs.”
PICs are bad news. Dioxin – the poison in Agent Orange – is a PIC but there are thousands more. Some are extremely toxic. Holcim is already releasing 168 times more CO than the newer Ash Grove plant – located just across Highway 67, and nine times more than former Bad Boy TXI. That’s a lot of potential PICs. Something isn’t right in the basic design of the plant to make it so inefficient, but instead of investing in a new plant, Holcim just wants to increase its pollution levels.
There’s a second part of Holcim’s request that’s even more disturbing. Besides the increase in CO pollution, Holcim is seeking approval from the State to burn 100% Petroleum Coke as a fuel for its Kiln #2.
Cement kilns need a cheap source of fuel. Since 1960 the Midlothian kilns have burned gas, coal, hazardous waste, tires, used oil, car inards, plastic packaging, and other “industrial wastes” to keep a flame at 2400 degrees F or hotter. But never 100% Petroleum Coke.
Pet Coke is a refinery waste high in BTU value and sulfur content. It’s very dirty. It’s basically solid carbon. In the application submitted by Holcim, the company says Particulate Matter pollution could go up by 100 tons per year. There’s also a very good chance of increases in smog-forming Nitrogen Oxides and Sulfur Dioxide pollution. Separately there’s also a significant but undocumented increase in CO2 that will occur because of Pet Coke’s composition, so this is a very bad Climate Crisis move as well.
Holcim says not to worry – most of these increases are on paper only and they’re not really changing the emissions, just “refining them.” But with the plant’s history, it’s more likely air pollution will increase, and not by a little bit.
TCEQ’s permit engineer assigned to the Holcim case says this is only a preliminary application and that the company will have to answer more questions about pollution increases, and more importantly will have to stage a “test burn” to see what the impact of burning 100% Pet Coke will actually be (under ideal conditions when everyone is looking over their shoulder). Many long time observers of the modern TCEQ under Governor Greg Abbott are skeptical any of this will happen before Holcim gets their permit however.
Because of the increased volumes of pollutants, this application will be generating an official response from Downwinders requesting at least one public meeting for a briefing on the permit and objecting to any increase in PM and NOX, insisting on test burns using 100% Pet Coke before the permit is approved, and protesting any increase in Climate Crisis pollution.
There’s two responses you can take right now to oppose Holcim’s permit amendment:
1) You can request a public meeting in Midlothian to have the TCEQ and company brief the public on the permit amendment and have the opportunity to ask questions
AND ALL LOCAL STATE REPRESENTATIVES AND SENATORS
Requests should be addressed to the Texas Commission on Environmental Quality as well as local State Representatives and Senators – not just those representing Midlothian.
TCEQ, Office of the Chief Clerk, MC-105, P.O. Box 13087 Austin, Texas 78711-3087
Texas State Senators
St. Senator Brian Birdwell/Midlothian: Brian.Birwell@senate.texas.gov, 512-463-0122
St. Senator Royce West/Southern Dallas County: firstname.lastname@example.org 512-463-0123
St. Senator Beverly Powell/ Southern Tarrant County: email@example.com 512-463-0110
Texas State Representatives
Rep. John Wray/Midlothian: firstname.lastname@example.org 972-938-9392
Rep Yvonne Davis/ Southern Dallas County: email@example.com 512-463-0598
Rep. Carl Sherman/Southern Dallas County: firstname.lastname@example.org 512-463-0953
Rep. Chris Turner/ Southern Tarrant County/Arlington: Chris.Turner@house.texas.gov 512-463-0574
Contact all of these folks individually, or you can send them and the TCEQ the same email requesting a public meeting on Holcim’s permt via Downwinders’ ClickNSend feature. Leave your own personal message too.
2) Request a Contested Case Hearing
If you feel you’ll be affected by Holcim’s new air pollution, you have a right to ask for a contested case hearing – a formal legal proceeding that sets a higher bar for Holcim to get a permit. In order to request a Contested Case hearing, you must send the TCEQ Chief Clerk:
1) YOUR NAME, or GROUP NAME
2) MAILING ADDRESS AND TEL #
3) APPLICANT’S NAME AND PERMIT #: Holcim, Air Quality Permit 8996 and PSDTX454M5
4) THIS EXACT STATEMENT: ” I/We request a contested case hearing.”
5) A DESCRIPTION OF HOW YOU WILL BE HARMED BY HOLCIM’S AIR POLLUTION
6) THE LOCATION OF YOUR HOME OR BUSINESS AND THE APPROXIMATE DISTANCE TO THE HOLCIM CEMENT PLANT TO THEM.
7) A DESCRIPTION OF HOW YOU USE THE PROPERTY AFFECTED BY HOLCIM’S AIR POLLUTION (HOME OR BUSINESS OR RECREATIONAL)
8) A LIST OF DISPUTED ISSUES
Example: 1. Any increase in PM Pollution from Holcim will be harmful to my health and enjoyment of my property, 2. There has been no evaluation of the PM, NOx, SOx, or CO emissions of burning 100% Petroleum Coke in Kiln #2, 3. There has been no evaluation of the burning 100% Petroleum Coke in Kiln #2 on increase in CO2 4. Holcim’s cement plant isn’t applying Best Practices and Best Available Control Technology for emission reductions of PM, CO, NOx, and SOx.
Send your request to the TCEQ’s Chief Clerk:
TCEQ, Office of the Chief Clerk, MC-105, P.O. Box 13087 Austin, Texas 78711-3087
They had the PowerPoints. They had the hardcopies of the PowerPoints in Spanish. They had the Subject Boards. They had the Post It notes and purple dots. Lots of purple dots. They had staff. They had consultants. They had consultants hired by consultants.
All in all, Dallas City Hall had everything it thought it needed for its very first of six climate plan public engagement meetings…save the public itself.
Of the 23 people in attendance on April 29th at the Beckley Saner Rec Center, only three were members of “the public.” Staff and consultants outnumbered them a good five to six to one with the rest being members of the City Climate Plan’s handpicked “Stakeholders Group.”
And even that group was not a safe bet. One Stakeholder came armed with a flier complaining that the City had made “no promise your voice or ideas will actually be heard” while another wondered why there were being asked to attend. That was a easy question. To help fill seats.
It wasn’t a very auspicious beginning to the public interface phase of the city’s climate plan process. It’ll be interesting to see how much the city gets billed by the professional PR experts to generate less than a Poker game’s worth of participants.
That result prompted a memo which produced wave upon wave of new social media reminders about the great opportunity to attend the next five meetings from everyone at City Hall including, council members, Dallas Mayor Mike Rawlings to DART board members. That push was successful in tripling the size of the April 30th and May 2nd meetings to nine members of the public. But there hasn’t been a meeting yet where the public made-up a majority of those in attendance.
Maybe word got out about the, er, circumscribed nature of the “engagement” meetings. You arrive to find the categories for responses have already been defined by staff on big white boards surrounding the room. There’s “Buildings and Energy,” “Food and Urban Agriculture,” “Parks and Open Spaces,” “Solid Waste,” “The Water We Use,” and “Transportation.”
These follow the format of the online survey the City is pimping.
Missing are topics like “Air Quality,” “Flood Control,” “Zoning” and “Industry.”
Under each of these broad subject titles are exactly six prompted policy options already proposed by staff. Not five, or seven, always six. And they’re far from comprehensive. For example, despite the worldwide wave of electric bus fleet electrification (Paris just ordered 800 e-buses), that policy option is nowhere to be found on the Transportation Board. If you’re aware of that trend you can record a write-in vote for it but it’s not presented to the general public as an obvious climate change policy, which it most certainly is.
Otherwise, your job is to place purple dots by the policy options already outlined for you by City Hall staff.
This is after you get a 30-minute Dallas staff PowerPoint primer on climate change that tells most people showing up for this meeting what they already know. There’s never any opportunity for a back and forth discussion among participants or true brainstorming as a group about local remedies. You watch the PowerPoint, pick among the already chosen policy options on the big boards, or write your own suggestions in, and then….go home. This is the staff’s definition of “public engagement.”
Setting the tone-deaf basis for these public engagement meetings was the much ballyhooed “Town Hall” at this year’s Fair Park’s EarthX event, which was really just one looooong lecture. There you could immerse yourself in 45 minutes of staff talking at you about how great staff and Dallas had been doing so far. Want to ask questions about the process? No time. It was less a “town hall” than a “city closet.”
A good fifth or fourth of the Town Hall audience were Stakeholders already chosen by the city staff to participate in a sort of overview of what’s going on. These are the same Chosen Few who were asked to please show up at the public engagement meetings. There is no public listing of who’s in the group – it’s not there on the City’s website or anywhere else, but it looks to include all the usual suspects we predicted it would plus a few others. There’s also not a meeting schedule for the group or an indication whether the public is allowed to attend.
In fact, the City’s climate plan website is kind of a hot mess, full of 404 error messages and empty white space where details of the process should be housed. A question on the site’s “forum” asking about Stakeholder membership has gone unanswered for 6 days now. It’s “blog” is empty of posts. Like the process itself, it seems mostly for show and to serve as a funnel to take the city’s survey.
Official Stakeholders are sometimes asked to identify themselves in the meetings, but never actually introduce themselves to the public. They’re supposed to be a combination of business, government, and environmental group representatives but since there’s no listing of them, it’s hard to tell how representative they really are. During their first group meeting, the guy from the Trump EPA reportedly looked around the room and commented how “white the group was.” Not a good sign.
Nor do they seem to have much opportunity for real input. Stakeholders complained at the April 29th meeting that either that they hadn’t been asked to provide suggestions for the City’s survey and meeting format or the ones they’d offered were ignored.
So far, they’ve mostly served the purpose of filling out the very thin public presence at each of the City’s official climate plan events and being a PR backstop for staff to proclaim how inclusive they’re being.
There are three more city “public engagement” meetings scheduled if you want to assess the process for yourself:
MONDAY, MAY 6
Churchill Rec Center
6906 Churchill Way
6:00 – 8:00 p.m.
TUESDAY, MAY 7
Audelia Rd Library
10045 Audelia Rd
6:00 – 8:00 p.m.
THURSDAY, MAY 9
Eastfield College- Pleasant Grove
802 S. Buckner Rd,
6:00 – 8:00 p.m
Thursday, December 6th
Catch the bus at 6:30 or 7:00 pm
at the Green Door in the Farmers Market District
600 South Harwood Dallas 75201
Plug In. Get Lit. Stay Current.
How did we get from cement plants burning hazardous waste in Midlothian to transit or and school buses making runs in inner city Dallas?
The answer is PM, Particulate Matter. The two-decade fight against the cement plants was one long primer on PM pollution. They were, and remain the largest industrial sources of the pollution in North Texas. We learned firsthand about the toxicity, reach, and insidious health effects of PM pollution. Not just strokes and asthma, but IQ loss, Autism, Dementia, Diabetes, low-weight births. PM is the new lead.
Every boiler, furnace, fire, flame and combustion engine produce PM. Diesel engines emit an exceptionally toxic form of PM called Black Carbon.
Because they’re on the road so much, are diesel or natural gas-powered, and make people wait by the side of traffic-heavy roads to ride, bus systems turn out to be a major source of PM pollution. And climate change gases. And smog. A rough estimate shows DART’s bus fleet would be the 10th largest PM source in Dallas County if it were all parked in one spot. But of course its the dispersed nature of a bus fleet’s pollution that often makes it more of a widespread threat to public health than a stationary “point source” a.k.a. an industrial facility.
What’s missing is a constituency for electrification of school district bus fleets and transit agencies like DART and Trinity Metro. Because of the potential impacts and benefits, this could be a wide-ranging and powerful alliance – PTAs, transit riders, physicians, environmentalists, environmental justice advocates, and even the utilities that could buy the power from bus batteries. But until we get the ball, er wheel rolling, its all just that – potential.
One of the reasons we’re sponsoring the December 6th “Electric Glide bus pub crawl” as part of this year’s Root and Branch is that we wanted to start that rolling. And real, wheels-on-the-bus-go-round-and-round rolling discussions and presentations on the advantages of electric buses are part of the evening, but so is just showing your support for the goal of electrification as something local officials could accomplish right now, especially if they combine their collective purchasing power.
The more people that show-up on the 6th, the more DART and local school boards – whose memberships we’re inviting as well – will get the impression someone gives a damn and the more we’re a force to be reckoned with. We need a people’s lobby for 21st Century electric buses in DFW.
In exchange for coming out and forking over $25, we give you three custom drinks, Graham Dodds’ food, a presentation by Dale Hill, the co-founder of the Proterra electric bus manufacturer, and maybe, just maybe some food for thought about what we all can do right now to advance a bunch of causes in one campaign that’s winnable at the local level in the Trump era.
Thursday, December 6th
Catch the bus at 6:30 or 7:00 pm
at the Green Door in the Farmers Market District
600 South Harwood Dallas 75201
Plug In. Get Lit. Stay Current.
Anti-Litter Group “Keep America Beautiful” Teams-Up with Dow and Hefty to Burn Plastic Bags Full of Plastic Garbage in Cement Kilns
And They Want To Do It Here…
We’ve been warning you for a while that garbage burning was coming to North Texas one way or another.
What we didn’t anticipate was that “Keep America Beautiful” would bring it.
That’s right. The same group that gave you Oscar “Iron Eyes” Cody crying over litter is now prepared to make your own eyes water and sting from the air pollution it wants to encourage by burning municipal solid waste, especially “hard-to-recycle” plastics.
Touting bright orange “energy bags” as a quick and easy alternative to throwing those plastics away, a news release issued by the Keep America Beautiful folks, your friends at Dow Chemical, and Reynolds, the makers of “Hefty” trash bags, claims they’re “a convenient way to collect plastic materials that would otherwise end up in the landfill and offers a platform to promote positive behaviors to prevent this material from being wasted.”
What they don’t tout as much is their alternative to throwing these plastics into a landfill – throwing them into a furnace.
As long as cement kilns need a high-temperature flame to make their product, they have large energy costs. Typically, 30% or more of the costs of running a cement plant is in buying the flammable materials necessary to keep that flame lit.
History has taught us that cement kiln operators will burn anything, including the kitchen sink, if they think it will help reduce those high fuel costs.
Kiln flames in Texas used to be powered by natural gas exclusively. Then it was coal. Then it was hazardous waste and coal. Then industrial wastes. And now municipal solid wastes. In bright orange plastic bags.
Cement plants don’t have to pay for the wastes, now termed “fuel,” for regulatory loophole purposes. In fact, because it’s now a “fuel,” they often get the waste for free or even get paid to burn it. It becomes a new center of profit in the company besides making cement. Maybe even more important. In the 1990’s, there were plenty of rumors about how the TXI cement plant in Midlothian would burn a lot of hazardous waste they got paid a handsome fee to take, but not have much cement product to show for it.
While garbage burning cement kilns have been on the rise in the developing world, the practice hasn’t caught on in the U.S.
Dow’s and Keep America Beautiful’s friendly neighborhood “Energy bags” are a way to jump start it.
This is already happening in Omaha, where 8,500 homes have filled 13,000 “Hefty Energy Bags” since the program’s launch in October. That’s resulted in more than 13,000 pounds of plastics being burned in a near-by Ash Grove cement kiln. They’re so excited about burning plastics at Keep America Beautiful that they’re not only endorsing the practice, they want to bring it to a cement kiln near you.
At a news conference to announce the offering of cash money grants to local communities who wanted to try the option, they unveiled a contiguous states map of the US where they’d like to see the “energy bag” concept implemented. The approximately 50 locations on the map identified by a red (not orange?) star are almost all sites adjacent to large cement plants – including Midlothian, immediately south of the Dallas and Tarrant Counties line, and home of the largest concentration of cement manufacturing in the nation.
Local candidates for eager participation in the project include TXI, the cement plant that burned hazardous waste by the thousands of tons from 1987 to 2008, Holcim, which has sought permits to burn carpet scraps and shingles, and Ash Grove, the same operator as the one burning Omaha’s plastic bags now.
BURNING PLASTIC IS BAD FOR PUBLIC HEALTH AND PUBLIC POLICY
1. It replaces real recycling with burning.
Once you have a hungry garbage burner, you have to keep feeding it with more and more garbage, decreasing the market for real recycling.
This is already happening with tires. There are good tire recycling programs that can’t stay afloat because local governments have promised the local cement kilns a certain volume every year.
2. It gives an incentive to the plastics industry keep to just making plastics that you can’t recycle.
Burning plastic garbage is like a relief valve on the growing piles of “hard to recycle” plastics that industry is producing. Just throw it in a bag and send it to the kiln. Out of sight, out of mind. There’s no question it reduces the percentage of plastics going to landfill…only to increase the percentage of plastic going into your lungs.
The real answer is to reduce and quit producing those “hard-to-recycle” plastics, not giving them a cheap way to get out of doing so.
3. Burning plastic produces lots of toxic air pollution – and all of DFW is downwind of Midlothian
Burning plastics produces toxic air pollution, a percentage of which escapes the smokestack and ends up in the air you breathe, the soil in your garden, and the food you eat and drink. Specifically, burning plastic creates lots of Dioxins and Furans – the same ingredients that made Agent Orange so toxic. The same poisons that made the State of Missouri evacuate the town of Times Beach in 1983.
Burning plastic also releases metals into the air, like cadmium and lead.
Other chemicals released while burning plastics include benzo(a)pyrene (BAP) and polyaromatic hydrocarbons (PAHs), which have both been shown to cause cancer. If plastic film or containers are contaminated with pesticides or other harmful substances, those will also be released into the air. If plastics are burned with other materials, whole new toxic chemicals may be created from the interaction of the different substances.
But wait! Don’t you want to divert more garbage from going to landfills?
Yes you do, but by eliminating, reducing and recycling the garbage – not taking a match to it.
Landfills are nasty things. They’re big and smelly and they leak. Sometimes they leak and contaminate ground and surface water. But these days you usually can trace the plume of those leaks and contain them before they get in drinking water.
On the other hand, once a piece of dioxin-contaminated soot is shot through a smokestack into the atmosphere, you have no idea where it’s going. You’re turning the whole sky into a landfill, full of solid and gaseous residues of refuse. What you didn’t want to drink, you’re now breathing. That’s the opposite of progress.
Taking a look at the Board of Directors for Keep America Beautiful, it’s no wonder they have a soft spot in their heart for large plastics manufacturers. They have not one, but two members from DOW, who, we are sure, thought this was a splendid idea.
Howard Ungerleider is Vice Chairman and Chief Financial Officer of Dow, and Greg Jozwiak is the Business President for the Elastomers and Electrical and Telecommunications businesses for the company. Prior to assuming his current role, he served as North America Commercial Vice President for the Packaging & Specialty Plastics business. Hmmmm.
But wait, there’s more! KAB has a board guaranteed to offend just about everyone. Not content with two Dow executives, it also has two Nestle Corporation members, a representative of Waste Management Inc., McDonalds, Keurig, Anheuser-Busch, and Phillip Morris – yes, that Phillip Morris.
“PEOPLE START POLLUTION. PEOPLE CAN STOP IT.”
Those are the words, spoken in a deep baritone by William “Cannon” Conrad, that ended that famous 1971 Keep America Beautiful commercial in honor of Earth Day. They ring as true now as then.
And so, people, we’re asking you to take action to discourage this kind of BAD IDEA from ever coming-up at a Keep America Beautiful board meeting again – send an email to their new Chair, Helen Lowman.
Ms. Lowman is a former FEMA and Peace Corps executive in the Obama Administration. She’s from Texas, worked at TCEQ, and graduated from Austin College…. So maybe messages from her fellow Texans will have more of an impact.
TELL KEEP AMERICA BEAUTIFUL’s NEW CHAIR YOU DON’T WANT TO BREATHE TOXIC AIR POLLUTION FORM BURNING PLASTICS
And if you want to leave a public message for the group too, here’s the group’s FaceBook site.
Other citizens groups, including some national alliances and networks are gearing up to take on this latest proof that all wastes, no matter how toxic, roll downhill to cement kilns eventually.
Meanwhile, Downwinders is taking the lead and beginning the push back we hope buries this project in the bright orange trash heap of history. Join us in not just saying “No,” but “Hell No.” Send that email now and then find two other people that will do the same. Thanks.
GET OUT OF YOUR RUT AND JOIN THE FIGHT!
MONDAY, MAY 23rd
9am Dallas City Hall
1500 Marilla Downtown Dallas
Room 6ES (6th Floor, South)
Dallas City Council's Quality of Life Committee Considers/Votes
on the DFW AIR QUALITY RESOLUTION
WEDNESDAY, MAY 25th
7:30 am – 10 am
Morton Meyerson Symphony Center
2301 Flora Downtown Dallas
EXXON – MOBIL SHAREHOLDERS MEETING
MONDAY, the 23rd
Dallas could follow Dallas County and be the second North Texas local government to say they want the EPA to reject the state's air plan for DFW.
Think about that. In "Red" Texas, local governments are asking the EPA to intervene and give them cleaner air because of their own State's failure to do so.
Just like our Green Cement Campaign, and our Dallas Drilling Ordinance, an EPA- written air plan for DFW would be setting an important national precedent from right here in the Belly of the Beast.
Please email these council members and tell them you support Ms. Greyson's air quality resolution.
This is a Committee hearing. There is no public comment allowed, but public shows of support are encouraged and the council members may ask questions from experts in the audience.
We'll have plenty of DFW CAN BREATHE CLEAN AIR lapel pins. Feel free to wear one and/or show your support through other means.
If this Committee votes in favor of the resolution, it'll probably go to the full council for a vote in June.
Show up Monday and let the City Council know you care about clean air.
WEDNESDAY, MAY 25th
The national spotlight will be on Dallas again on Wednesday as Exxon-Mobil, our own hometown corporate Poster Child for climate change denial, will be holding its annual shareholders meeting in downtown Dallas.
Because of new revelations the company secretly knew about the dangers of climate change in the late 1970's, but continued to publicly deny the phenomenon, this year's annual meeting in Dallas is especially important. More than 500,000 people across the United States have called on the Department of Justice and State Attorneys General to look into Exxon's cover-up. So far, Massachusetts, U.S. Virgin Islands, New York, and California have launched official investigations.
350.org, the Sierra Club and other national groups have been leading the call to show up at the Exxon-Mobil meeting and make sure the company is held accountable for its past and current behavior.
Most of us never get to go to international conferences and protests like Paris last year, or even ones in DC or New York. But next Wednesday the 25th, the epic global fight against self-destruction comes to your own doorstep.
What are you going to do?
Don't let your activism end once you go off-line. Turn your "like" into an action.
Show up Wednesday morning bright and early and represent.
They'll be coffee and food. They'll be banners. They'll be media.
But we need you to be there too.
Help us show the rest of the world that we can do our part.
Help us keep the pressure on.
Help us win.
WEDNESDAY, MAY 25th 7:30 am – 10 am
Morton Meyerson Symphony Center 2301 Flora Downtown Dallas
6:30 pm Thursday
616 Six Flags Drive Arlington
When polluters cut smog pollution, they cut a lot of other kinds of pollution as well, including climate-damaging gases like CO2 and methane.
Hundreds of thousands of tons of this kind of pollution could be eliminated in the next air plan for Dallas-Ft. Worth as a result of requiring modern controls on coal plants, cement kilns, and oil and gas sources.
Luminant's Martin Lake coal plant in East Texas is the largest global warming polluter in the country. It released 16.3 million metric tons of carbon dioxide in 2012, the equivalent of 3.5 million cars.
Recent studies show facilities in the Barnett Shale Gas Play are leaking 50% to 90% more methane than the government estimates.
We need to cut pollution here, now.
That's why if you care about climate change, you'll want to show-up next Thursday night and speak in favor of the EPA rejecting a State of Texas plan that doesn't require any new cuts in pollution from any source.
Join your earth-hugging peers in calling for a new air plan written by EPA that includes cuts in local smog pollution that can also benefit the entire planet. In as little as two years, you could make a big difference to a big problem.
Think Globally. Act Locally.
Not just a bumper sticker.
When the Ash Grove cement plant in Midlothian modernized its operations to conform with new anti-smog rules and other regulations, it cut approximately 300,000 tons of CO2 pollution – a year. That's just one cement plant.
Methane is the main ingredient in natural gas, and a highly potent greenhouse gas, with over 80 times the 20-year warming power of carbon dioxide.
EPA estimates 750,000 to one million tons of methane is released by equipment leaks every year from facilities in the Barnett Shale, but a recent peer-reviewed study estimated methane emissions in the Barnett Shale may be twice as high as EPA thinks.
There are pending EPA rules to limit methane pollution at natural gas sites that could be rolled into this DFW air plan. Even a 50% cut in leaks in North Texas would mean an annual drop of 400-500,000 tons of climate changing pollution.
A good anti-smog plan from EPA will also put more pressure on the obsolete East Texas coal plants to close.These coal plants are the biggest reasons Texas status is the #1 Greenhouse Gas polluter in the U.S.
The fastest way to cut lots of greenhouse gases in the Belly of the Beast is with a good EPA anti-smog plan for DFW.
Come speak in support of an air plan for our region that would help reduce asthma attacks here, and the melting of glaciers in Greenland.
Thursday, January 21st
616 Six Flags Road in Arlington
First Floor Meeting Room
By this point, most of you will have been inundated with opinions and factoids about what President Obama's new "Clean Power Plan" will and won't do about climate change. Bottom Line: while it sets a precedent and an emissions floor for the largest sources of CO2, it does so in a way which turns out to be not so challenging for most states – including Kentucky deep in Coal County.
That's also true for Texas, where besides being Ground Zero for the fracking boom, we also have plenty of wind power and some solar. According to the EPA, the state must cut an annual average of 51 million tons of carbon to reach its target, a reduction of about 21 percent from 2012 emissions. We're well on our way to achieving most of that reduction with current or planned wind, gas, hydro, and solar. (In what might be a first concession that natural gas shouldn't be a long-term "bridge fuel," some analysts think tweaks performed by EPA prior to the Plan's release give more incentives to adopt real renewables earlier rather than leaning on gas in the interim.)
This is mostly good news. We want the wind and solar economies to grow. The trade-off is that, under Obama's Clean Power Plan, the rise of these technologies and their emissions reductions lets the obsolete East Texas coal plants off the hook because you don't need them to close to meet your CO2-cutting goals.
Five of those obsolete coal-fired power plants surround DFW's eastern side in a half circle (Big Brown, Martin Lake, Monticello, Limestone, and Welsh). They are, without a doubt, the worst examples of fossil fuel-generated pollution in Texas. They're huge emitters of Mercury, Particulate Matter (PM), Sulfur Dioxide (SOx), and Nitrogen Oxides (NOx).
These five East Texas coal plants are projected by the state to still be releasing 150 tons a day of smog-forming NOx pollution in 2018. Because of wind direction and volume, that pollution has a very large impact on DFW air quality – probably more than any other single phenomenon. We need those coal plants to either modernize or close ASAP to help solve our chronic smog problem. But from the initial survey of the policy, the Clean Power Plan is not going to force that outcome.
While the Plan probably signals the end of any new coal plants any time soon, or at least none without CO2 solutions like sequestration or capture, the fate of existing coal plants, especially in a state like Texas, is more ambiguous. More likely, they'll continue to linger on, beneficiaries of friendly state-created policies designed to nullify the requirements of the Clean Air Act, like loosening their PM limits by magnitudes.
Now, you might think that a federal goal that's been mostly accomplished without doing anything new would be a no brainer in Austin, but there are increasingly fewer and fewer brains in Austin. Because the state's environmental agencies are now completely ideologically driven, common sense just isn't a factor anymore. Instead of asking "how can we best solve this problem?" the response is now to deny there's a problem at all and go about ginning up anti-federal hyperbole to better position yourself in the Republican Primary.
Consequently, the Texas Commission on Environmental Quality is seriously considering not turning in a required state plan of how to get the reductions needed by the deadline of 2030. If the state doesn't submit one of its own, then the EPA would write one for them. This has the business community in Texas a little nervous, since they have a lot more influence here than in DC. But citizens, which kind of anti-climate change plan would you rather have Texas abide by – one written by a state agency that denies climate change is happening and is doing everything it can to obstruct policies to prevent it, or one written by a federal agency that's actually acknowledging the obvious and doing something about it?
Regardless of whose plan does what by when, the East Texas coal plants look to be able to ride this federal policy out thanks to an almost two-decade homegrown drive to open up the state to renewables. If we want these coal plants to stop causing problems for us, we're probably going to have to find other leverage points.
One of these leverage points is demanding the state of Texas follow the law and require the coal plants install modern Selective Catalytic Reduction controls as part of the new DFW clean air plan it submitted to EPA this summer for approval. SCR could reduce smog pollution from these plants by 90%. So far, Texas has refused to even acknowledge the need to do so. EPA has requested the state change its mind – without success.
Consider the five East Texas coal plants the energy sector equivalent of the obsolete "wet" kilns in Midlothian that burned hazardous waste for 20 years. They're technological dinosaurs, on their last legs, but still churning out tons and tons of harmful air pollution as they plod their way to the bone yard. The Clean Power Plan insures they'll be the last of their kind, but it's not a silver bullet.