Toxic Particulate Matter – “PM” – is the New Lead

PM is the scientific name for industrial soot. It comes from burning things. Wood. Gasoline. Diesel. Coal. Waste. Everything that depends on on burning something, produces Particulate Matter: cars, trucks, buses, locomotives, boilers, furnaces, kilns, etc.

PM pollution is tiny. It’s much smaller than nature’s dust particles that our nose hairs, throat and lungs have evolved to handle most of the time. Because its so small PM pollution can actually pass through your lungs’ lining and goes directly into your bloodstream. From there it goes to any organ it’s carried to – the liver, the reproductive system, the brain.

Numerous studies have shown the terrible impact of PM pollution on human lungs and hearts.It causes heart attacks, strokes, asthma and COPD.  More recent studies have shown a whole new threat. Exposure to PM is now linked to AHAD and Austim in children, and Dementia and Parkinson’s disease in adults.  Immune system and reproductive organ damage have also been ties to PM exposure. Like lead in paint and gasoline, this pollution can do damage to a person’s social and intellectual capacities, not just physical ones


 

PUBLIC INFO & BRAINSTORMING SESSION:

The Dangers of PM Pollution and What We Can Do About It in DFW

Saturday, December 9th

2 – 4 pm

2900 Live Oak in East Dallas

ALL ARE WELCOME

 


 

This year the most comprehensive study on PM pollution health effects ever produced was published by Harvard’s School of Public Health. It covered 60 million people over 12 years.

It found significant health damage occurring at levels well below the current EPA standard and concluded there is no “safe” level of exposure to PM pollution. That is, there is no exposure that is not capable of doing some harm to you, no matter how small.

That same study found African-American seniors were three times more likely to die from PM exposure than any other group, with Latinos and Asians also suffering disproportionately. “Point Sources” (smokestacks) of PM are more likely to be in located in low-income communities of color. People of color are more likely to ride diesel-powered buses used for public transit or live along PM-spewing freeways. There’s no other type of pollution that’s linked so closely to how “undesirable” industries and people were forced to live next to one another over the decades.

Here in DFW we’ve flirted with high regional levels of PM pollution but we really don’t know the extent of it since the EPA and State only have four PM monitors for the entire DFW area of seven million people.

That’s why our first job is to help map PM pollution hot spots in DFW. Downwinders is building a “Citizen’s Guide to PM Pollution” that identifies all the largest sources of PM pollution – factories, railways, freeways, transit and school bus routes.

We’re purchasing portable PM pollution monitors citizens can use to police their own neighborhoods and helping to build a new monitoring network that cities can use to track events like the one on Oct 19th – that still remains a mystery.

What can be done in DFW to reduce our exposure to PM pollution? New controls on industry of course, including the cement kilns and coal plants. But also electrification of bus fleets, buffer zones beside freeways, and a detangling of pollution and people in places like West and South Dallas and the Northside of Fort Worth that require pushing the reset button on local planning.

Just turning bus route shelters 180° around so they don’t openly face street traffic has been found to reduce exposure to PM pollution by 30-50% for transit riders – one of the populations at highest risk for PM exposure.

PM pollution is everywhere. It’s so ubiquitous we take it for granted. Much like people took cigarette smoking for granted 40 years ago. And that’s where we’re at with this campaign, at the very beginning of a massive public health education and advocacy effort, a no-smoking campaign for machines that also has the potential to reshape planning, politics, and culture. We have a huge task ahead of us. And we need your help.

Come join us on December 9th to learn more about this insidious from of air pollution and help us come-up with the best approaches for where to start reducing it in DFW.

Saturday, Dec. 9th    2-4 PM    Meadows Conference Center    2900 Live Oak

A note of explanation: There are two meetings next week in DFW concerning the large and complicated Volkswagen legal settlement over the company’s lying about the air pollution its diesel vehicles emit. Each state, as well as about 20 counties in Texas, are looking to score millions for various reasons and programs.

The two DFW meetings are sponsored by Public Citizen/Texas. We love Public Citizen and when they asked us to co-sponsor these meetings, we reflexively signed-up, even without knowing the details. There are efforts around the country to use this money to electrify school and city bus systems and challenge the status quo in interesting unconventional ways that might not be possible without large wads of cash.

But…what we didn’t know at the time we agreed to be co-sponsors was that the meeting is really a larger effort by something called the Texas Clean Air Working Group – an official statewide organization of local county governments working with other officials and businesses  – to solicit comments…and most likely, direct the money to their priorities.

As a result, the North Texas Council of Governments is the major local coordinating entity for the Working Group. The COG will be presenting its version of a “DFW air quality update” and helping to coordinate responses. We did not know this until last Thursday, when we asked for details of who was doing what presentations.

This is problematic for Downwinders at Risk on a couple of fronts.

For one thing, NTCOG is one of the reasons DFW is STILL in violation of the Clean Air Act after 26 years. They have a perpetually overly optimistic perspective. They have a close relationship with TCEQ because they get so many grants from them, and they frequently side with the State on air quality issues. They see air pollution only thru the prism of federal transportation dollars at risk over our “non-attainment: status – not public health. In 2015 citizens had to raise money to do the DFW air computer modeling that neither TCEQ nor COG would do. You aren’t going to get a very realistic picture of DFW air quality, or the need to do more about it, from a COG presentation.

Secondly, the preferred use of the VW settlement money by many of these local governments and NTCOG is either expansion or replacement of their own natural gas fleets, or supplementing existing state programs the state legislature has refused to adequately fund, like the Texas Emissions Reduction Program (TERP). In effect the goal of most of the members of the Working Group is to reinforce the status quo, not change it. 

Because of these reasons, we’ve asked to be taken off the list of co-sponsors. We don’t feel comfortable with our name being used to promote a more rose-color than-real picture of DFW air pollution. or natural gas as the solution to that not-as-bad-as-it looks problem.

The suggestions made at these meetings will be channeled through the NTCOG, who has already given the state a quote for the amount of money it wants and a list of what it wants to spend it on. There is no citizens lobby being organized separately to argue for different priorities.

Looming over all of this is the fact that the Texas Commission on Environmental Quality and/or the Governor’s office determines where the state’s part of the settlement goes. So don’t expect much. In fact, Ken Paxton, the Texas Attorney General is suing over the settlement, specifically trying to eliminate the $2 billion set-aside for “zero-emissions” vehicle development as “unconstitutional.” 

Paxton is also suing to get 20 Texas counties, including almost all the major urban areas, to drop their own VW suits. Why would the counties want that money? Because they don’t trust the state to spend it on improving air quality. Dallas County Commissioners Court sent the state the same message this last month when it voted to stop collecting the $6 inspection fee the state is supposed to be reimbursing to local governments for air quality programs, but instead is just sitting in the general revenue pile to cover-up cuts in other programs.

So even while local governments in Texas are already lobbying hard to get their share of money from Austin, Austin is trying to make their pool of money smaller and eliminate zero emissions vehicle funding all together. Cross-purposes? Yep. But that’s Texas government in 2017.

If the counties win their separate lawsuit and money, there’ll be a much better chance for citizens to influence those local choices one Commissioners Court at a time than to try and steer the entire COG or state in the right direction. That’s your best chance to make something different happen and we’ll certainly be trying to keep track of how at least the North Texas counties use their possible winnings.

doogie door runThis plan won't work.

That's the simple message from the three pages of new comments Region 6 EPA staff submitted to the Texas Commission on Environmental Quality last month concerning its anti-smog plan for DFW.

That message begins with the cover letter, written by Mary Stanton, Chief of the State Implementation Plan Section for Region 6. "… additional local and regional ozone precursor emission reductions will be necessary to reach attainment by 2017."

How much in reductions? EPA estimates an additional 100-200 tons per day more in cuts of smog-forming pollution will be necessary to achieve compliance with the current 75 parts per billion ozone standard. "Without emission reductions on this scale, it is unlikely that the area will attain by the attainment date.”

To give you some idea of how large a number that is, TCEQ calculates that all gas and oil air pollution in DFW equals 78 tons per day, the Midlothian cement plants belch out over 18 tons per day, and all the power plants in the immediate DFW area, 21 tons per day.  Totaled, those three sources add up to 117 tons of pollution a year. 

All the cars and trucks on DFW roads are said to add up to 180 tons per day of pollution.

So the decrease in pollution EPA is saying is necessary to get down to the current ozone standard is huge. 

Martin Lake Coal Plant

But take a look at those obsolete East Texas coal plants outside the boundaries the DFW nonattainment area. TCEQ says they account for a total of 146 tons per day.  Add Selective Catalytic Reduction (SCR) which can get you up to 90% reductions in coal plant emissions, or close them down completely, add decreases from new controls on the cement kilns and oil and gas sources, and you're well on your way to amassing 200 tons a day of cuts in pollution. 

Which do you think is more attractive to most DFW residents: permanently parking their cars, or putting new controls on the coal plants? Even though the coal plants harm the whole DFW airshed more than any other major source, they're not held accountable to the same regulatory requirements as sources closer to the center of the urban core, but which have less impact. Our cars must have special gasoline formulas in summer, we have to have HOV lanes, and we still go through Ozone Action Days, but the coal plants party like it's 1979. TCEQ is taking a hands-off approach to the plants and as a result the DFW region will continue to be in violation of the smog standard or huge cuts from other sources will be necessary.

TCEQ could have added new controls to the coal plants to the plan, but it chose not to. In fact, there are no new controls in the state's plan on any major sources of air pollution affecting DFW. EPA's new comments go to the heart of that choice. "Without additional emission reduction measures, we don’t see how the area will meet the standard of 75 ppb by the end of the 2017 ozone season," writes EPA staff.

EPA goes on to say TCEQ's computer modeling supporting it's do-nothing plan is "unrealistic," severely underestimating future smog levels, and delivering projections of decreases "that seem unlikely to be reached." 

DV 98-2015With this stance, EPA seems poised to reject this "attainment demonstration" part of the air plan as being insufficient. But it must wait to see how TCEQ responds to EPA comments about its modeling shortcomings and need for new cuts when the state officially submits its plan this July. Then, and ony then can the Agency approve or disapprove. We're going out on a limb here and predicting TCEQ won't change a thing, thus inviting EPA disapproval. 

That's the pattern TCEQ has already established with its "screw you" response to the EPA's comments about the part of the plan dealing with "Reasonably Available Control Technology," or RACT, last February.  This second part decides what new controls should be required of major sources of air pollution within the 10-County DFW "non-attainment" area – like the Midlothian cement plants and the thousands of oil and gas facilities checkerboarding the western half of the Metromess.

TCEQ says nothing new is required. EPA disagrees. EPA told TCEQ last year it had to do a new RACT review and lower the kiln's emission limits to account for a new generation of technology or it would have to reject the state's plan. TCEQ ignored the request, daring the EPA to disapprove. EPA seems more than willing to take them up on the offer.

And so while you're waiting for the state's computer modeling and suspect math to be rejected by EPA in July, you can probably expect to see EPA officially rejecting the RACT part of the state's plan sooner – maybe as soon as the next 60-90 days. 

Despite the TCEQ going out of its way to submit an unacceptable plan to EPA, if the Agency pulls the trigger and begins a federal takeover of the DFW air plan, the Commission and the whole of Texas State Government will cry bloody murder about the usurpation of the state's authority and once again proclaim how "out of control" the EPA is on their way to filing suit.

Hearing PresserThis is why the rowdy eruption of public sentiment for an EPA plan at the hearing in Arlington two weeks ago was so critical (Thank you again).  It's also why we now have to be about the business of getting DFW local governments, hospitals and school districts to pass resolutions in favor of an EPA takeover. The Agency will need this kind of public support to counter all the criticism it will take from the Usual Suspects in Austin and DC. If you're interested in helping us pass one of these resolutions in your county, city, school or hospital district, please let us know at: downwindersatrisk@gmail.com

And as always, it's why you, and people you know should:

1) Send EPA officials an email urging them to reject the TCEQ air plan for DFW and substitute one of its own.

2) Sign the CHANGE.ORG petition in favor of an EPA plan.

3) Send out our SOS@EPA short video far and wide. 

DFW Childhood Astham Rates

 

All Day NATIONAL Public Hearing on a New Federal Ozone Standard

Thursday, January 29th, 9am to 7:30 pm

Arlington City Hall, 101 W. Abram

(To secure a 3-minute speaking slot, e-mail Eloise Shepard and ask for one in the time period most convenient for you. Slots are going fast (and not necessarily to citizens), so do it asap: shepherd.eloise@epa.gov)

It's Round Two of January's clean air public hearing marathon, and the biggest has been saved until last.

One of only three national public hearings on lowering the federal ozone, or smog standard, is taking place here in DFW, at Arlington City Hall all day next Thursday January 29th, from 9 am to 7:30 pm.

Last week saw a state-sponsored hearing on another TCEQ do-nothing DFW clean air plan. But the state wouldn't even have to pay lip service to such plans were it not for the requirement to meet a federal ozone level and the region's inability to do so over the last two decades. 

Lowering the federal ozone level means it will be tougher in the future for the state to claim it doesn't have to implement any new pollution controls on cement kilns, coal plants, or gas facilities. More importantly, enforcement of a tougher standard means better public health: fewer "bad air days," fewer asthma attacks, fewer trips to the emergency room because your child can't breath, and fewer deaths caused by dirty air. 

That's important because reports like the child heath survey from Cook Children's hospital in 2009 showed that childhood asthma rates in DFW were twice the state average and almost 10% higher than the national average. It called the prevalence of asthma among local children an "epidemic."

Currently, the national ozone standard is 75 parts per billion (ppb) – which DFW is still at least three years away from reaching even under the rosiest of scenarios. (Right now our average is 81 ppb, and that's only because of a wetter and cooler summer in 2014). But that 75 ppb number is a political compromise – not one grounded in science. Based on public health studies the EPA's own independent board of specialists has recommended a range of 60 to 70 ppb at least three times since 2008, with an emphasis on the lower end of that range. Now it looks as if the EPA is finally willing to follow through on that recommendation.

EPA's national ozone standard sets the goal of cleaner air that every state must work toward. It drives all new clean air plans. like the one the state of Texas is proposing for DFW right now. The lower the standard, the more pollution has to be reduced. The more pollution has to be reduced, the more controls have to be added to major sources of air pollution to get that reduction. That's how you get long-term clean air progress in states like Texas that refuse to act on their own.

A significant reduction in the federal standard – from 75 (ppb) to as low as 60 ppb would make it much, much harder for Texas to avoid new controls on industry. To give you some idea of how much harder, consider that the state's "plan" for compliance with the current 75 ppb level is completely dependent on a new EPA gasoline mix coming onto the market in 2017. Even then, it's own estimates say that it won't get down below 75 at least three or four monitoring sites. Just one monitor site out of compliance means the whole region is in violation. Short of a huge rise in the use of electric cars, more huge decreases in vehicle pollution aren't expected. Additional significant drops in smog that would be required under a new, lower standard would have to include controls on major industrial sources – like the cement kilns, coal plant and, yes even gas facilities.

When you have a much lower ozone standard, you have to reduce smog by addressing ALL sources of air pollution. 

Finding a way to comply with a lower national ozone standard is how more modern pollution controls were mandated almost a decade ago at the Midlothian cement plants. Meeting that new ozone standard meant pollution from the kilns had to be reduced and that made it more possible for Downwinders' "Green Cement" campaign to work with local governments. Today, there are no obsolete "wet kilns" left in Texas – they've all been replaced with more modern dry kiln operations. This has resulted in a reduction of hundreds, even thousands, of tons of smog-forming air pollution from these huge sources every year. We still have to require state-of-the-art Selective Calaytic Reduction (SCR) on the kilns, but they're releasing far less pollution than they were even five years ago because they've had to comply with a new federal ozone level. 

With a new, lower ozone standard, the same could be true of new controls on gas facilities, like the 650 large compressors in North Texas, and the East Texas coal plants. That's why it's important for Texas residents to fight for the lowest possible standard this time around. When you testify, please make sure you request a new standard of NOT MORE THAN 60 PARTS PER BILLION.

According to a recent EPA staff analysis, an ozone standard of 60 ppb would reduce asthma deaths in the US by 95%, compared to only a 50% reduction under a 70 ppb level. If you want air that can eliminate all but a small fraction of respiratory problems associated with outdoor pollution, you need to press for a 60 ppb standard.

Needless to say industry is fighting back hard against such a standard, using its usual doom and gloom forecasts of economic hardship. This is the same argument that was used against the current ozone standard – the one we have now in the middle of the biggest economic boom in a decade. In fact, the technology for bringing down pollution levels currently exists in many industries – including kilns, coal plants and compressors. It's not experimental and it's not too expensive to use, as demonstrated by its use right now in those industries.  We just have to require its use in states like Texas that are refusing to implement progress. That's why this new standard is so important – it will make the state take action it would not otherwise take. It's one of the only ways citizens who care about cleaner air in Texas can force progress.

Likewise, the Texas Commission on Environmental Quality's own toxicologist, Michael "Smog Ain't Bad For You" Honeycutt will also be testifying. TCEQ knows that a lower standard will force its hand on new controls. It will be pulling out all the stops to use its influence and that of sympathetic elected officials to scuttle any change. Using ideologically-based arguments supported by industry-financed studies, the TCEQ will say there are no real benefits to reducing DFW smog. Those of you that know better have to show up and say so.

Speaking slots for the 29th are going very fast. Industry will be well-represented. Please don't get left out.  We need your voice that day to call for a 60 ppb national ozone standard. E-mail the EPA at shepherd.eloise@epa.gov and reserve your time today.

alexander-pst mask 2
TCEQ Public Hearing on the new DFW Anti-Smog Plan
Thursday, January 15th  6:30 pm
Arlington City Hall, 101 W. Abram

Over the last two decades, we've seen some pretty lame DFW clean air plans produced by the state, but the newest one, scheduled for a public hearing a week from now, may be the most pathetic of the bunch.

From a philosophical perspective, the Texas Commission on Environmental Quality stopped pretending to care about smog in DFW once Rick Perry decided to run for president around 2010 or so. Computer modeling was scaled back, staff was slashed, and the employees that were left had to be ideologically aligned with Perry's demand that no new controls on industry (i.e potential or existing campaign contributors) was preferable to six or seven million people continuing to breathe unsafe and illegal air.

TCEQ's 2011 anti-smog plan reflected that administrative nonchalance by concluding – in the the middle of the Great Recession – that consumers buying new cars would single-handedly deliver the lowest smog levels in decades. It did not. It went down in history as the first clean air plan for the area to ever result in higher ozone levels. The first, but maybe not the last.

This time around, it's not the cars themselves playing the role of atmospheric savior for TCEQ, but the fuel they'll run on. Beginning in 2017, the federal government is scheduled to introduce a new, low-sulfur gasoline that is predicted to bring down smog by quite a bit in most urban areas. Quite a bit, but not enough to reach the ozone standard of 75 ppb that's necessary to comply with the Clean Air Act by 2018. It's the gap between this official prediction and the standard where the state is doing a lot of hemming and hawing.

TCEQ staffers really did tell a summertime audience in Arlington that that estimated 2018 gap of between 1 and 2 ppb was "close enough" to count as a success. Now, you might give them the benefit of the doubt, but remember this is an agency that has never, ever been correct is its estimation of future ozone levels. After five attempts over the last two decades, TCEQ has never reached an ozone standard in DFW by the official deadline. Precedent says this plan won't even get "close enough."                      

Plus, we know getting "close" to 75 ppb isn't protecting public health in DFW. Even as this clean air plan is being proposed by Austin, the EPA is moving to lower the national ozone standard to somewhere between 60 and 70 ppb (There's a hearing on that at Arlington City Hall on January 29th). That new EPA ozone standard is due to be adopted by the end of this year. So this entire state plan is obsolete from a medical perspective. Instead of aiming for a level of ozone pollution closer to 70 ppb as soon as possible, it's not even getting down to a flat 75 ppb at all DFW monitors by 2018. It wil take an entirely new plan, and pulling TCEQ teeth, to do that much later. In other words, millions of people will have to wait as much as a five to seven years longer to get levels of air quality we know we need now in 2015.

What are the major flaws this time?

1. TCEQ is Using 2006 in 2014 to Predict 2018.

The EPA recommends that states use an "episode" of bad air days from the last three years – 2009-2013 – in trying to estimate what ozone levels will be three years from now. The more recent the data, the better the prediction.

TCEQ is ignoring that recommendation, relying on a computer model that's already nine years old. This has all kinds of ramifications on the final prediction of compliance. Instead of having more recent weather data, you have to "update" that variable. TCEQ doesn't have to compensate for the drought DFW is experiencing now or factor in a year like 2011 where the drought caused a worst case scenario for ozone formation.

TCEQ isn't using more recent data on how sensitive monitors are to Nitrogen Oxide (NOx) and Volatile Organic Compounds (VOCs) – the major kinds of pollution that cause smog . That's important because gas production in the Barnett Shale has put a lot more VOCs in the air. But instead of getting a more accurate post-drilling boom read on what's driving smog creation, the TCEQ is relying on a picture that starts out before the boom ever started. 
The further you reach back in time for a model to predict future levels of smog, the fuzzier that future gets, and the less accurate the results. TCEQ is using a model that's twice to three times older than EPA guidance recommends. What are the odds that TCEQ estimates will be correct based on this kind of methodology?

2. TCEQ is Downplaying OIl and Gas Pollution

Citizens attending the air quality meetings in Arlington over the past year have seen the TCEQ try and hide the true volume and impact of oil and gas pollution at every turn. Instead of all the industry emissions being listed under the single banner of "Oil and Gas Pollution," the Commission has tried to disperse and cloak them under a variety of categories in every public presentation.

"Other Point Sources," a classification that had never been seen before, was the place where pollution from the 647 large compressor stations in DFW could be found – if you bothered to ask. "Area Sources" was where the emissions from the thousands of other, smaller compressors could be found – again, only if you asked. "Drilling" was separate from "Production." And despite other agencies being able to tease out what kind of pollution came from the truck traffic associated with fracking within their jurisdictions, the TCEQ never bothered to estimate how much of the emissions under "Mobile Sources" was generated by the Oil and Gas industry.

The reason the TCEQ has tried so hard to hide the true volumes of oil and gas pollution is because once you add up all of these disparate sources, the industry becomes the second largest single category of smog-forming pollution in DFW, second only to on-road cars and trucks (and remember many of those trucks are fracking-related). According to TCEQ's own estimates, oil and gas facilities in North Texas produce more smog-forming VOC pollution than all of the cars and trucks in the area combined, and more smog-forming NOx pollution than the Midlothian cement plants and all the area's power plants combined.

TCEQ is loathe to admit the true size of these emissions and place them side-by-side next to other, traditional sources, lest the public understand just how huge a impact the oil and gas industry has on air quality. Austin's party line is that this pollution isn't contributing to DFW smog – that it's had no impact on local air quality. But such a claim isn't plausible. If cars are a source of smog, and cement kilns and power plants are a source of smog, how can a category of VOC and NOx pollution dwarfing those sources not also be a source of smog? Think how much less air pollution we'd have if the Barnett Shale boom of the last eight years had not taken place?

In it's last public presentation in August, the TCEQ made the impact of oil and gas pollution clear despite itself. According to the staff, oil and gas emissions were going to be decreasing in the future more than they had previously estimated. As a result, a new chart showed that certain ozone monitors, including the one in Denton, would see their levels of smog come down significantly. It was exactly the proof of a causal link between gas and smog that TCEQ had been arguing wasn't there. Only it was.

In terms of forecasting future smog pollution, TCEQ is underplaying the growth of emissions in the gas patch. Everything it's basing its 2018 predictions on is years out-of-date, leftover from its last plan.

Drilling rig pollution is extrapolated from a 2011 report that counts feet drilled instead of the actual number of rigs. TCEQ predicts a decline in drilling and production in the Barnett Shale without actually estimating what that means in terms of the number of wells or their location. It also assumes a huge drop-off in gas pollution after 2009 that hasn't been documented by any updated information. It's only on paper.

While recent declines in the price of oil and gas have certainly put a damper on a lot of drilling activity, there's still a significant amount going on. Look no further than Mansfield, where Edge is now applying for permit to build a new compressor and dozens of new wells on an old pad.

In 2011, nobody was building Liquified Natural Gas terminals up and down the Gulf Coast for an export market the way they are now. Analysts say those overseas markets could produce a "second boom" in drilling activity between now and 2018, but the TCEQ forecasts don't take that into account.

Gas production pollution numbers – emissions from compressors, dehydrators, storage tanks – are even more tenuous. Every gas industry textbook explains that as gas plays get older, the number of lift compressors increases in order to squeeze out more product. Increase the number of compressors and you increase the amount of compressor pollution. But TCEQ numbers fly in the face of that textbook wisdom and predict a decline in compressor pollution because wells in the Barnett Shale are getting older!

The best analogy for how TCEQ is estimating oil and gas pollution is its poor understanding of where those thousands of smaller compressor are and how much pollution they're actually producing. No staff member at TCEQ can tell you how many of those compressors there are in the region – they literally have no idea and no idea of how to count them in the real world. There are just too many, their locations are unknown, and they were never individually permitted.

Instead, the TCEQ takes production figures from the Railroad Commission and guesses how many of those small compressors there are, as well as their location, based on where the RRC tells it production is going on in the Shale. Then staff guesses again about the emissions being emitted by those compressors, because there's no data telling them what those emissions actually are. In the end you have a series of lowballed guestimates, stacked one atop the other, presented as fact. It's smoke and mirrors.

3. TCEQ Isn't Requiring Any New Controls on Any Major Sources of Air Pollution

Like its previous 2011 DFW air plan, which resulted in an increase in North Texas ozone levels, TCEQ's new plan requires no new controls on any major sources of air pollution, despite evidence showing that such controls in smog-forming emissions from the Midlothian cement plants, East Texas coal plants, and Barnett Shale gas facilities could cut ozone levels significantly.  

Selective Catalytic Reduction (SCR) is already used extensively in the cement plant industry in Europe to reduce smog pollution by up to 90%. Over a half dozen different plants have used the technology since 2000. The TCEQ's own 2006 report on SCR concluded it was "commercially available." Holcim Cement has already announced it will install SCR in its Midlothian cement plant. Yet the TCEQ makes no mention of this in its plan.

That's right, a cement plant in Midlothian has decided SCR is commercially viable, but the State is looking the other way and pretending this development in its own backyard isn't even happening. TCEQ is stating in its proposed plan that SCR just isn't feasible!

In 2013, a UTA Department of Engineering study looked at what happened if you reduced Midlothian cement plant pollution by 90% between 6 am and 12 Noon on weekdays. Ozone levels went down in Denton by 2 parts per billion. That may not seem like a lot, but in smog terms it's the difference between the Denton air monitor violating the 75 ppb standard under the TCEQ plan and complying with the Clean Air Act.

In 2012 a UTA College of Nursing study found higher rates of childhood asthma in Tarrant County "in a linear configuration" with the plumes of pollution coming from the Midlothian cement plants. SCR means less pollution of all kinds: smog, dioxins and the particulate matter the Nursing College thought was causing those increased rates of childhood asthma. By delaying the requirement that all the Midlothian cement plants install SCR by 2018, the state is turning its back on a problem that Cook Children's hospital described as "an epidemic."

The same is true of SCR in the East Texas coal plants. The technology is being used in other coal plants around the world and in the US to reduce smog pollution. There's no reason it shouldn’t be required for the dirtiest coal plants in Texas that impact DFW air quality. After decades of being out of compliance with the Clean Air Act, DFW is one of the places the technology is needed most.

Last year the Dallas County Medical Society, led by Dr. Robert Haley, petitioned the TCEQ to either close those coal plants or install SCR on them. The doctors' petition was rejected by TCEQ Commissioners and they were told their concerns would be addressed in the DFW air plan. They aren't. Those concerns, along with the proof they presented about the impact of the plants on local air quality, are being ignored.

Electrification of gas compressors is a commonly used technology that could cut smog pollution as well, and yet the TCEQ is not requiring new performance standards that would force operators of hundreds of diesel and gas-powered compressors in North Texas to switch to electricity. 

A 2012 Houston Advanced Research Center study found that pollution from a single compressor could raise local ozone levels by as much as 3 to 10 ppb as far away as ten miles. There are at least 647 large compressor stations in the western part of the DFW area. Dallas and other North Texas cities have written ordinances requiring only electric-powered compressors within their city limits based on testimony from industry that electrification was a commonly used technology in the industry. And yet, TCEQ's official position is that electrification isn't feasible.

In ignoring these types of new controls the TCEQ is violating provisions of the Clean Air Act to implement "all reasonably available control technologies and measures" to insure a speedy decrease in ozone levels. Each of these technologies is on the market, being used in their respective industries, and readily available. Studies have shown that each of these technologies could cut ozone levels in DFW significantly, but the TCEQ is refusing to implement them. In doing so, many observers believe it's blatantly in violation of the law.

We don't expect TCEQ to change its position. That well has been poisoned for the foreseeable future. But we do expect a higher standard of enforcement from the Obama Administration EPA. That's why we're asking you to show-up at the public hearing and oppose this dreadful state air plan a week from now in Arlington. We need to demonstrate to the federal government that citizens are concerned about getting cleaner air now, not in the next plan or the one after that. Now. We need to put pressure on the EPA to reject this TCEQ plan, to either send it back to the drawing board or substitute one of its own. Without you showing up, that pressure isn't there.  

Between now and Thursday – and all the way through January 30th, you can send prepared comments opposing the TCEQ plan to Austin and the EPA Regional Administrator with a simple click here – and add your own comments as well.

As a reward for coming over and venting your frustration, we'd like you to stay and party with us at the official "retirement party" of State Representative Lon Burnam, beginning at 7:30 pm just four blocks down the street. It's a roasting and toasting of the best friend environmentalists ever had in the Texas Legislature, as well as a fundraiser for Downwinders to continue our work to defend your air. JUST CLICK HERE FOR TICKETS.

Next Thursday you can support clean air two ways in one evening. Help us beat back a terrible, horrible, no good, very bad air plan, and then come celebrate the wonderful, righteous, very good work of a dedicated public servant. See you there.

traffic jam_EQAfter a review of over 30 years of studies, the Centers for Disease Control concluded that children living near high-volume roads and highways were 50% more likely to suffer from childhood leukemia. The cancer risk is linked to postnatal exposure.

In the April issue of the American Journal of Preventative Medicine, researchers for the CDC explain how they examined all the published studies concerning traffic air pollution risks from 1980 to July of 201. Out of nine relevant studies, seven, covering approximately 8,000 children, reveled a correlation between exposure and leukemia.

"The review found that children diagnosed with leukemia were "50% more likely to live near busy roads than children without leukemia," said Vickie Boothe, a CDC health scientist and lead author of the Journal article. "While the study found a link, it does not prove that living near a busy road causes leukemia."

Previous studies have linked proximity to road traffic with higher childhood asthma and autism rates.

Haz mat suit - picnic tableEven though this EcoNews article is about air poisons that result from fossil fuel production, it applies to just about any combustion source, including cement plants, manufacturing plants, vehicles, and so on. It's a pretty good top ten list, although you wonder why Dioxins and Furans got left off, since they're toxic by the gram instead of pound. Also missing is Particulate Matter as a stand alone threat, although it gets a shout out as a by-product. Nevertheless, these are the among the most dangerous pollutants that have caused and are still causing a lot of problems in North Texas and elsewhere:

1. Benzene

Benzene is a well-established carcinogen with specific links to leukemia as well as breast and urinary tract cancers. Exposure to benzene reduces red and white blood cell production in bone marrow; decreases auto-immune cell function (T-cell and B-cells); and has been linked to sperm-head abnormalities and generalized chromosome aberrations.

Benzene is one of the largest-volume petrochemical solvents used in the fossil fuel industry. It is a major component in all major fossil fuel production: oil, coal and gas. People are exposed to it from inhaling automobile exhaust and gasoline fumes, industrial burning such as oil and coal combustion, and exposure to fracking fluids.

There's a recent Emory University study concluding that risk for leukemia fell with every mile between a person's home and facilities that release benzene.

2. & 3. Sulfur Dioxide (SO2) and Nitrogen Oxides (NOx)

Sulfur dioxide (SO2) and nitrogen oxides (NOx) are two primary examples of particle-forming air pollutants (particulate matter). Particulate matter is known to contribute to serious health problems, including lung cancer and other cardiopulmonary mortality. SO2 and NOx are both highly toxic to human health, and contribute directly to thousands of hospitalizations, heart attacks and deaths annually.

SO2 is particularly dangerous for children. Studies correlate SO2 emissions from petroleum refineries—even in lower exposure levels over time —to higher rates of childhood asthma in children who live or attend school in proximity to those refineries. Similarly, small particles of NOx can penetrate deeply into sensitive lung tissue and damage it, causing premature death in extreme cases. Inhalation of such particles is associated with emphysema and bronchitis.

4. Petroleum Coke (Pet Coke)

Pet coke is a by-product of oil processing that's also used as a fuel. It's a heavy dust which resembles coal. It's burned in power plants and cement plants. It contains dozens of dangerous chemicals and heavy metals, including chromium, vanadium, sulfur and selenium. It's a huge contributor to particulate mater and NOx and SOx formation 

5. Formaldehyde

Formaldehyde is a carcinogen with known links to leukemia and rare nasopharyngeall cancers, according to the International Agency for Research on Cancer. Formaldehyde is highly toxic regardless of method of intake. It is a potent allergen and genotoxin. Studies have linked spontaneous abortions, congenital malformations, low birth weights, infertility and endometriosis to formaldehyde exposure. Epidemiological studies link exposure to formaldehyde to DNA alteration. It is also contributes to ground-level ozone.

Independent studies,  have detected dangerous levels of formaldehyde in both wastewater and ambient air emissions from fracking operations. One researcher, with the Houston Advanced Research Center, said reading from one test site in North Texas, “astoundingly high,” and, “I’ve never heard of ambient (formaldehyde) concentrations that high… except in Brazil.”

6. Polycyclic Aromatic Hydrocarbons (PAHs)

In actuality, this is not a single listing—polycyclic aromatic hydrocarbons (PAH) is an entire class of toxic chemicals, linked together by their unique chemical structure and reactive properties.

Many PAHs are known human carcinogens and genetic mutagens. In addition, there are particular prenatal health risks: prenatal exposure to PAHs is linked to childhood asthma, low birth weight, adverse birth outcomes including heart malformations and DNA damage.

Additionally, recent studies link exposure to childhood behavior disorders; researchers from Columbia University, in a 2012 Columbia University study, found a strong link between prenatal PAH exposure and early childhood depression. Infants found to have elevated PAH levels in their umbilical cord blood were 46% more likely to eventually score highly on the anxiety/depression scale than those with low PAH levels in cord blood. The study was published in the journal Environmental Health Perspectives.

7.  Mercury

Mercury is a dangerous neurotoxin emitted from coal-fired power plants and any other combustion source using coal for fuel – like the Midlothian cement plants. It damages the brain and the nervous system either through inhalation, ingestion or contact with the skin. It is particularly dangerous to pregnant women and children. It is known to disrupt the development of the in-vitro brain. In low doses, mercury may affect a child’s development, delaying walking and talking, shortening attention span, and causing learning disabilities. High dose prenatal and infant exposures to mercury can cause mental retardation, cerebral palsy, deafness and blindness. In adults, mercury poisoning can adversely affect fertility and blood pressure regulation and can cause memory loss, tremors, vision loss and numbness of the fingers and toes.

One out of every six women of childbearing age in the U.S. have blood mercury levels that could be harmful to a fetus, according to EPA reports. The EPA estimates that  300,000 children are born each year at risk for significant development disorders due to mercury exposure.

8. Silica (Silicon Dust/Sand)

Crystalline silica (“frac sand”) is a known human carcinogen; breathing silica dust can lead to silicosis, a form of lung disease with no cure. This is a hazard in the cement industry and threat to those living downwind of cement plants, and now it appears to be one for natural gas roughnecks and adjacent homeowners as well.

Silica is commonly used, in huge amounts, during fracking operations. Each stage of the process requires hundreds of thousands of pounds of silica quartz–containing sand. Millions of pounds may be used for a single well.

The presence of silica in fracking operations, simply put, is a major safety risk with a high likelihood of dangerous exposure. Case in point: researchers from the National Institutes of Occupational Safety and Health (NIOSH) recently collected air samples at 11 fracking sites in five different “fracking states” (CO, ND, PA, TX and AR) to evaluate worker exposure to silica. Every single site had measures higher than the NIOSH threshold for safe exposureso high, in fact, that about one-third of the samples collected were even above the safe threshold for wearing a safety respirator mask. This was reported in May 2013 in the Journal of Occupational and Environmental Hygiene.

9. Radon

Radon is a colorless, odorless, tasteless radioactive gas which causes lung cancer. It is the second largest cause of lung cancer in the U.S. after cigarette smoking. About 20,000 people per year die from lung cancer attributed to radon exposure according to the National Cancer Institute. Further, there is no known threshold below which radon exposures carries no risk.

Radon exposure can come from a variety of natural sources. However, fracking (natural gas) represents a significant new and increased source of radon exposure to millions of citizens. Radon is released into local groundwater and air during fracking operations. It also travels through pipelines to the point of use—be it a power plant or a home kitchen.

The science behind radon release and exposure is complex but explained well here by Christopher Busby, the Scientific Secretary of the European Committee on Radiation Risk, who warns that radon dangers from fracking “have not been addressed properly (or at all) by the environmental impact statements published by the operators, or by the Environmental Protection Agency in the USA.”

10. Hydrofluoric Acid (HF) / Hydrogen Fluoride

Hydrofluoric acid (HF) is “one of the most dangerous acids known.” HF can immediately damage lungs, leading to chronic lung disease; contact on skin penetrates to deep tissue, including bone, where it alters cellular structure. HF can be fatal if inhaled, swallowed, or absorbed through skin.

The senior laboratory safety coordinator at the University of Tennessee said, “Hydrofluoric Acid is an acid like no other. It is so potent that contact with it may not even be noticed until long after serious damage has been done.”

Hydrofluoric Acid is a common ingredient used in oil and gas extraction.

Numerous studies, including recent ones conducted by both The Center for Public Integrity (CPI) and the United Steelworkers Union (USU) cite the oil industry’s abysmal safety record as a high risk factor for a major HF accident; over the past decade, more than 7,600 accidental chemical releases from refineries have been reported by the industry. In the past three years alone, a total of 131 “minor” accidents involved HF.

snakeoilBy 2018 the Texas Commission on Environmental Quality predicts DFW will finally be in compliance with the federal ozone standard. The 1987 federal ozone standard. The 2012 ozone standard? Not so much.

That was the bottom line of last Tuesday's very defensive TCEQ staff presentation on the new effort to rein-in North Texas smog at the Council of Government's headquarters in Arlington, in what could be considered the kick-off meeting of yet another "State Implementation Plan," or SIP, for DFW. A plan drawn up by the state has to be submitted in place by June of 2015, with a goal of meeting the new 75 parts per billion ozone standard by the summer of 2018.

But even giving generous credit for the effect of new, lower sulfur gasoline standards, the TCEQ's computer model predicts the area will fall short of the 75 ppb goal at four very familiar monitor sites, with final estimates just a fraction above 75 ppb at Keller, readings of 76 ppb at Grapevine and Eagle Mountain Lake and as high as 77 ppb in Denton. To understand how optimistic even this result is however, you have to know that the Denton monitor is sitting at an average of 87 ppb as of this last summer. It took 10 years for that monitor to come down from an average of 97 ppb of ozone in 2003 to 87 ppb in 2013. With its new model, TCEQ is asking everyone to believe that ozone levels will come down another 10 ppb in less than five years.

As this excellent Denton Record Chronicle piece about the TCEQ effort points out, there's plenty of reasons to be skeptical. The agency has been wildly inaccurate in its past predictions. According to the last computer model the TCEQ ran, DFW was supposed to be enjoying record low ozone levels by now. It never happened, and in fact we're still in violation of the old 1987 standard of 85 ppb.

It's this lack of progress, particularly in the last thee years, that Downwinders and others cite when we're making the argument that more aggressive control measures are needed. In countering us, the state keeps insisting that – compared to 2003 – we're doing much better. And that's true -if you stretch things out over a decade we have gotten better. But compared to 2009 and 2010, we're doing the same or even worse. Look at the last three years of results and there's no way to conclude that DFW air quality is "getting better." It's just not true.

And all of this is really just a proxy for the fight over how much natural gas pollution is to blame for that stagnation. If there's no stagnation, there can be no cause of that stagnation. If there's a rollback in air quality, there must be a cause for the rollback. And many of us think that it just might be the pervasiveness of gas productions facilities within and surrounding DFW that are contributing factors.

Chris Kite, the TCEQ computer modeler that produced the new plan, used his presentation to mostly try to rebut specific quotes and arguments cited by Downwinders Director Jim Schermbeck about the lack of local air quality progress. It was a rare and raw indication of just how much TCEQ's Austin Headquarters considers Downwinders a threat. Too bad that even his own charts betrayed Mr. Kite's counter-thesis.

For instance, look at the numbers from 2008 to 2012 for average smog levels in DFW and see if you can cite the progress in this slide from the TCEQ PowerPoint:

DV 2009-2012

 

 

 

 

For the past two years, our average has been higher than the two years before that. That ain't progress. Especially if you look at the previous four years, 2006 to 2009:

DV 2006-2009

 

 

 

 

We're trying to think of what might have happened since 2008 to make it more difficult for the DFW region to attain a 1987 ozone standard at a time when emissions from just about every traditional source of smog pollution have been going down. Oh yeah, there was a huge natural gas field that opened up in the heart of the western part of the Metromess. But don't try telling the TCEQ that. They're convinced, absolutely convinced, that gas industry pollution couldn't possibly be responsible for any lack of progress in DFW air quality. Because hey, there hasn't been any lack of progress, and even if there wasn't, it wouldn't be due to the thousands of new gas sources. They're as sure of this as they are about their new computer model. Which is why the rest of us should keep an open mind.

TCEQ is hoping that coming close is good enough for EPA, that they can take advantage of something called "weight of evidence" that says that a clean air plan's parts are larger than its actual numerical sum and EPA reasonably expects the thing to succeed despite not all monitors hitting 74 ppb or below by 2018. In this way, Austin once again hopes to avoid any discussion about new control measures. But that's hanging your hat on a very precarious hook, given the agency's poor prognostication, and the EPA may demand a larger margin of safety.   

In fact, an honest review of TCEQ's track record for past DFW clean air plans would necessarily place the "weight of evidence" in this new one on the agency itself to show that they'll get at least 10 ppb or more below the 75 standard just to make sure they come close to achieving compliance.

Bull Shit protectorsThis curt announcement went out last Friday courtesy of the Texas Commission on Environmental Quality:

The Texas Commission on Environmental Quality (TCEQ) will host a public information meeting to provide information on the development of revisions to the SIP for the 2008 ozone National Ambient Air Quality Standard (NAAQS) in the 10-county Dallas-Fort Worth (DFW) nonattainment area. The meeting will take place on Thursday, September 5, 2013 at 10:00 a.m. at the North Central Texas Council of Governments (NCTCOG), Transportation Council Room, 616 Six Flags Drive, Arlington, Texas 76005. NCTCOG and United States Environmental Protection Agency (EPA) representatives will also provide updates on local and federal initiatives.

What this doesn't say is that the last local clean air plan drafted by Rick Perry's TCEQ failed miserably last summer when DFW actually ended up with worse air than when it had begun in 2010. The state can't even bring itself to admit that. It's never had a successful smog plan in DFW, but only Rick Perry's TCEQ plan actually made the air worse. Maybe that's why they're holding this "public information meeting" at a mid-morning time guaranteed to result in a low rate of participation by actual DFW citizens.

You'd also never guess from this release that DFW has a local advisory board for drafting its own clean air plans. The North Texas Clean Air Steering Committee was constituted specifically for the purposes of working with the state on such plans. It hasn't met in two years. Nor is it likely to meet anytime soon if Rick Perry's TCEQ has its way – the state considers it a nuisance to have to come up here and explain itself to local elected officials and environmentalists.

Did we say environmentalists? Since the 2006-2007 smog plan, citizen groups have held three seats on the Committee to balance out the three seats given the local Chambers of Commerce. Right now those seats are held by Downwiders at Risk, the Sierra Club/Public Citizen and the Environmental Defense Fund.  The rest of the slots are filled by local city council members, Mayors, County Commissioners and County Judges.

Downwinder's own Jim Schermbeck is a member and has used the meetings of the Committee to cross-examine Rick Perry's TCEQ officials who otherwise receive a mostly unquestioning  welcome everywhere else they go. Committee meetings are the one place that representatives fo citizens groups can ask questions like a legislator in an Austin hearing. And the TCEQ reallly doesn't like that. Especially when we've been right about so many things and the TCEQ so wrong.

It's also true that Rick Perry's TCEQ really doesn't even bother to start any kind of consultation or planning process in DFW until a year before the plan is due. Since a new plan to achieve the new ozons/smog standard of 75 parts per billion doesn't kick in until 2015, it's doubtful the Committee will be called to order before next Spring. That way the pollution control measures needed by any plan have no chance of passing a state legislature at the last moment in 2015, ensuing that no real changes take place and DFW remains smoggy.

Perhaps you think that's way too cynical a perspective. But that's exactly what happened this last cycle in 2010-2011. And it was actually worse, because the biggest part of that last plan was to sit back and watch as DFW residents bought new cars. No moving parts.

Meanwhile, can anyone name a current local elected official who's known for their advocacy of clean air? Dallas Mayor Laura Miller fought Perry's coal plants in 2006. in 2013, her successor, Dallas Mayor Mike Rawlings protects secret deals with gas drillers. Dr./Mayor Cluck in Arlington has voted in favor for dozens, if not hundreds, of gas wells near homes, parks, and day care centers even as he recites his familiar litany about running into childhood asthma victims in the hospital emergency room. Fort Worth? Bought and sold to Chesapeake. Dallas County? They're too busy indiscriminately dropping pesticides on us. Mayor Evans of Plano used to be a voice of reason in Collin County. Now you've got Judge Keith Self who never met an air polluter he didn't liked.

Some stalwarts like Parker County Judge Mark Riley and Tarrant County Judge Glenn Whitley still represent moderate Republican views, but many of their peers have been replaced by Tea Party members who think smog is as imaginary a problem as climate change. We're actually going backwards in our local political engagement of the issue.

If TCEQ is emasculating the local advisory group on clean air, it's certainly getting a valuable assist from a feckless DFW indigenous officialdom, who seemed to have all walked away as a group from clean air as a goal they were willing to strive to achieve.

So mark your calendars for another citizen-friendly TCEQ  "public information meeting"….at 10 am on a Thursday morning, September 5th, in Arlginton at North Texas Council of Government headquarters, when most people will be working and unable to attend. For for the sensitive among you, we suggest also attending with some handy BS protectors for your ears so as not to irrevokably damage logic receptors in the brain.

ruptured appendixAccording to CBS News

"A new study published July 10 in The Lancet showed that even breathing low levels of air pollution for a prolonged period of time could raise risk for the often-deadly lung disease. Another study released on the same date showed that short-term exposure to most major air pollutants could increase the risks of hospitalization and death from heart failure."

Lung cancer risks went up 18% with each increase of 5 migrograms of PM 2.5. Researchers noted that they did not find a level of pollution for where there was no risk, and the results indicated "the more the worse, the less the better" when it came to pollution.

"At this stage, we might have to add air pollution, even at current concentrations, to the list of causes of lung cancer and recognize that air pollution has large effects on public health," Takashi Yorifuji from the Okayama University Graduate School of Environmental and Life Science and Saori Kashima from Hiroshima University in Japan…."

A second study shows the risk of dying or going to the hospital because of heart failure increased by 3.52 percent for every 1 part per million increase of carbon monoxide levels; 2.36 percent for every increase of 10 parts per billion of sulfur dioxide; 1.7 percent for ever 10 parts per billion increase in nitrogen dioxide; and about 2 percent for every 10 micrograms per cubic meter increase of particulate matter. Surprisingly, increases in ozone were not linked to heart failure. Unsurprisingly, you're breahting in all of these kinds of air pollution if you live in DFW.

All of that is kind of old news – put stuff in air, see stuff harm your lungs and heart. But here's a new "adverse health effect" being linked to air pollution – appendicitis. While not as lethal as lung cancers and heart attacks, anyone who's had their appendix rupture can tell you it's not a pleasant experience.

And while ozone may not have been linked to heart problems in that previous study, the New York Times reports a Canadian one links it to a slight increase in your chances of having appendicitis.

High ozone levels were associated with an increased number of hospitalizations for appendicitis and were even more strongly associated with cases of burst appendix. For each 16 parts per billion increase in ozone concentration the scientists found an 11 to 22 percent increase in ruptured appendix cases. The study was published in Environmental Health Perspectives. The associations persisted after controlling for age, sex, season of the year and the presence of other air pollutants, like nitrogen dioxide and particulate matter. The reason for the association is unclear, but studies in mice have shown that air pollution can alter the animals’ abdominal bacteria.

Who knew?