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
Dallas Plan Commission Hearing Scheduled
for Thursday January 17th, 1:30 pm
Dallas City Hall Rm 5ES
Speak Out Against
Systematic Environmental Racism
1) CLICK HERE TO SEND AN EMAIL TO
THE PLAN COMMISSION RIGHT NOW
Urge them to deny these permits…and consider a moratorium on ALL new industrial permits south
of the Trinity River “until the City can provide
a way to insure the same neighborhoods
are not always chosen to host them.”
2) SHOW-UP AT THE HEARING ON THE 17th
and speak against the zoning change
that Estrada Concrete is seeking.
Thanks in part to your emails, the Plan Commission delayed routine approval of the Bird Lane batch plant at its December 13th meeting and scheduled an individual hearing for Thursday, January 17th that could start as early as 1:30 pm at Dallas City Hall.
If you didn’t get a chance to send an email opposing the batch plant to the Plan Commission in December and want to do so you have that chance through our revised Featured Citizen Action “clickNsend” messaging. If you did send one in, send another.
This time, you can not only tell the Commission you oppose this specific permit…but ALL new industrial permits south of the Trinity River until the City of Dallas quits dumping all new polluters there.
We know the Bird Lane Batch Plant will be on the January Commission agenda but residents may be facing a twofer by then. The same company pursuing the Bird Lane site is also looking to put another new Batch Plant on Zonie Road right around the corner. After initially rejecting that effort because the paperwork wasn’t correct, it seems to be back on track up for Commission action as well – we just don’t know when yet.
All of this is just down the street from Blue Star Asphalt “Recycling” mess, aka Asphalt Mountain, current industry in Joppa, and close to the new Lane Plating Superfund site.
It seems certain that at the very least, the Plan Commission will decide on a Special Use Permit, or SUP, that Estrada Concrete needs to operate a concrete batch plant on the Bird Lane property for a minimum of three years..
Opposition is based both on the specific problems the batch plants would cause for neighbors, and the fact that this part of South Dallas already has a disproportional amount of polluting industries.
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
Not quite two weeks ago, on Thursday October 19th, something happened to throw local air quality conditions into the red zone for most of the day.
There was a inexplicable smokey haze extending along the limestone escarpment from Midlothian to Dallas and then north to Denton, sending Particulate Matter pollution soaring to Beijing levels and ozone readings so high the whole regional average went up a part per billion. Countless downwind residents complained to officials, FaceBooked, and Tweeted about “the smell of burning plastic” enveloping their neighborhoods with the smoke, which was so thick many thought the problem was just down the street.
The 24-hour standard for Particulate Matter Pollution is 150 ug/m3. The annual standard is 12.
70 ppb is the new ozone standard.
The events took the Texas Commission on Environmental Quality completely by surprise. Commission computer forecasting had not predicted an Ozone Alert Day or warned of heavy PM pollution. Officials were playing catch-up for the rest of the day.
Now almost two weeks later nobody official knows what caused this Really Bad Air Day. Not the EPA. Not the Texas Commission on Environmental Quality. Not the DFW area citizens who breathed in the dirtiest air their lungs have seen all year.
Despite the sophisticated technology available to us in 2017, a single unexpected incident upwind of DFW can throw the entire North Texas air shed into the danger zone with no warning and no clue as to what initiated it.
Readings from state monitors were of no help until damage had already been done. As usual they were two hours or more behind in reporting. The numbers they were displaying at 12 noon were actually taken at 10 am. You had no idea what was going on in real time so that you might better protect yourself or family.
There are only three or four Particulate Matter pollution monitors in all of DFW. Even if you’d wanted to use the state’s current monitoring system to track this mystery plume, you couldn’t have done so. It doesn’t have that capability.
As inquiring reporters called, the TCEQ staff found a variety of things to blame. TCEQ suggested the smoke was from a Bastrop forest fire near Austin. But readings from monitors between Bastrop/Austin and Dallas show there was no problem south of Midlothian that day, while there was a huge problem north of there at the same time. Eyewitnesses who saw the plume on Thursday reported a thick narrow ribbon of a plume you’d see coming off a near-by source, not the sort of diffused cloud you’d expect to witness after traveling more than a hundred miles downwind. And then there’s that “burned-plastic smell.”
Then it was maybe one or more “controlled burns” in the Midlothian-Mansfield area. As it turns out, neither fire department found evidence of any permitted controlled burns in their own jurisdictions that could have cause so much pollution. Midlothian’s single permitted fire for the day was “the size of a coffee table” according to a department employee.
According to the Mansfield Fire Department “a fire” was reported to be located at Kimball Road and Hwy 287 just north of the Midlothian city limits. This is what’s at that intersection:
Please note the caution against open flames. Could a fracking site have produced the kind of particulate matter pollution and haze we saw on October 19th without methane or other kinds of pollution being released en masse as well? It doesn’t seem like it could. But what if the fracking site had been turned into a temporary waste incineration site for the day?
That’s not all. A satellite pic of the intersection and what’s around it reveals Kimball and Hwy 287 to be a kind of rogue’s gallery of potential suspects:
Besides the fracking sites you can be see in mid-drilling on this Google street level tour, the road leads to a Trinity River Authority Wastewater Treatment plant and the back door of the giant Ash Grove cement plant.
TRA is a shadowy, 60-year old regional bureaucracy that owns millions of acres of land, reservoirs, landfills, and wastewater-treatment facilities. It’s been in environmental hot water before. Wastewater treatment accumulates a lot of solids, and the TRA handles a lot of trash. It’s not inconceivable that it had something to do with the October 19th incident by thinking it could get away with an open burn on its own property.
Ditto for Ash Grove. Like the other two cement plants in Midlothian, Ash Grove’s kiln is allowed to burn industrial waste, including used oil, tires and plastics – remember the oft-cited “smell of burning plastic” citizens reported on the 19th? Waste-burning cement plants have had their wastes combust and cause huge fires before and each plant has its own emergency response crew which might be able to put out a fire without calling Midlothian.
There’s no proof Ash Grove, TRA or the fracking sites were the cause of the October 19th public health disaster. But there’s also no proof yet they didn’t cause the problem.
The truth is: there’s no official explanation for what made the air so dangerous to breathe on October 19th .
More truth: As of Friday, October 27th the TECQ had not even opened an official investigation into this matter – which again, sent Particulate Matter pollution to levels not seen outside SE Asia and single-handedly raised the regional ozone level.
This is why Downwinders at Risk filed the first of what we’re sure will be a series of Texas Open Record Act requests last Friday seeking:
“Any and all printed or electronic documents and electronic media containing information concerning or related to ozone, particulate matter and/or haze air pollution readings and levels in the Dallas-Forth Worth non-attainment area on Thursday, October 19th 2017, including official ozone action warnings issued, complaints filed about air quality in the Dallas-Fort Worth area that day, photographs, satellite images, computer modeling, as well as all material related to any questions, inquiries, or investigations about air quality in DFW on October 19th anyone in the TCEQ, or contracted by TCEQ has been tasked to perform since October 19th or is still performing currently, and e-mails, letters, reports, telephone logs and notes, memos and all other material about October 19th air quality from 6 am Tuesday October 19th to Wednesday October 25th, 2017.”
TCEQ has until November 10th to respond. We’ll keep you posted.
In the meantime, this episode becomes Exhibit A in why DFW needs to catch-up with other metro areas and build its own network of high tech air quality sensors.
If such a grid had been in place, there would have been a real time warning of the PM and ozone pollution being generated shortly after the it started. There would have been a way to locate the source of the pollution right away and do something about it before it got worse, and there would have been a way to predict the plume’s course and warn those in its path before it got there – not two hours after it arrived.
In this sense a modern sensor grid is actually a pollution prevention device, an investigative tool, and an early warning system all rolled into one.
In a metropolitan area that’s been out of compliance with the Clean air Act for 27 years and counting over 14 million lungs are being held hostage by a state air quality monitoring system left over from the 1990’s. It’s being maintained by a state agency that’s run by polluters, officially thinks smog isn’t bad for you, and is cutting its air monitoring budget.
There’s no desire in Austin to update this obsolete system and no money to do so. If DFW officials want to utilize 21st Century technology to help them clean their air, they’re going to have to build their own network of air monitors – exactly the proposal the DFW Air Research Consortium was trying to get funded with a National Science Foundation grant. Close, but no cigar.
Without the NSF grant, local officials are going to need to get creative. Are there private businesses who might want to sponsor an app that could tell give you useful air quality info in exchange for naming rights: “Brought to you by the Nissan Leaf DFW Clean Air Network.” Are there local foundations that would contribute? What about local high-tech billionaire Mark Cuban? For less than a million bucks, DFW could have 500 Particulate Matter sensors that would be capable of of pinpointing a problem down to the street address.
Baltimore, Chicago, Chattanooga, Louisville, L.A. , Oakland, and Lafayette, Louisiana are all way ahead of DFW in building out their own local dense grid of air sensors. They’ve done it with a combination of private, government and academic know-how and financing.
We have as much, or more technical expertise and money than any of those locales and we should have more incentive given our chronic air pollution problem. There’s no reason we can’t build our own modern, more protective, more useful way of monitoring air pollution – even if the state isn’t interested. Not only can we do it, but in light of the events of October 19th, it should be considered a necessary act of public health self-defense.
Dow, Hefty and Keep America Clean’s proposal to burn plastics via bright orange “energy bags” in cement kilns is new but the idea of using kilns as industrial kitchen dispose-alls is not.
DFW has been identified as a national waste disposal destination because of its cement plants since at least the mid 1980’s. And as long as they continue to operate, the area will continue to be seen as a desirable dumping ground.
All these buildings, and roads, and “developments” have to be made out of something. They’re mostly made out of cement. In an area that’s grown by a Tyler or Richardson a year since 1970, cement is as ubiquitous as the air in your lungs. You just take it for granted. But it comes from somewhere and it gets made someplace.
In our case, that place is here – right over there, in Midlothian, just a couple of miles across the Dallas and Tarrant County lines to the south. You know, the direction the wind blows from most of the time.
And its a big place. There’s a Chamber of Commerce sign in downtown Midlothian proclaiming the town the “Cement Capitol of Texas.” There are three large cement plants – TXI, Ash Grove and Holcim – that quarry the limestone rock they need from the escarpment that runs north-south along I-35 for most of the length of the state. But the sign is too modest. Befitting one of the fastest growing areas in the country, it’s the largest concentration of cement manufacturing in the nation.
These aren’t batch plants. Think coal plants. Smokestacks hundreds of feet high. Furnaces, or kilns, as long as football fields. In 2015, the three plants released 475 tons of Particulate Matter pollution, 2040 tons of Sulfur Dioxide, and 510 tons of Volatile Organic Compounds – more pollution than the totals from entire North Texas counties.
That pollution goes somewhere. Depending on where you live, some of it lands in your lungs.
All three cement plants are in Midlothian to mine the limestone rock just like coal plants would strip-mine coal. Midlothian has a lot of cement kilns because that’s where the raw material for cement is, not because of any other reason.
But unlike coal, the limestone isn’t flammable and for there to be cement, the kilns must reach and maintain a flame of at least 1700 degrees F to bake the limestone with other ingredients. This is the way cement has been made since Rome perfected the process two millennia ago. You bake rock…just so.
And that flame is your number one operating expense as a cement plant owner. It accounts for up to 40% the costs of doing business. Anything you can do to reduce the costs of that flame saves you money. And that equation is the basis of constant mischief in the industry.
When the first Midlothian cement plant opened in 1960, and when the second one opened in 1965, the rock was baked with fire fueled by Texas natural gas. By the time the third cement plant opened in the mid-1980’s , the first couple of “energy crisis” had hit and they all three begun to burn cheaper coal.
But another trend started in the 1980’s. Two of the three cement plants took advantage of a loophole in a new federal law and began burning hazardous wastes to bake their limestone rock.
Unlike gas and coal, the cement plants were paid by hazardous waste generators and middlemen to burn these wastes, so the plants not only saved the cost of buying fuel, they actually profited from becoming incinerators, and labeling waste as “fuel.” Hazardous waste burning at U.S. cement plants peaked in the 1990’s.
Even after many cement plants have stopped burning hazardous wastes, they continue to burn “industrial wastes” like used oil, tires and shredded car interiors. When burned in kilns, these waste often produce exactly the same toxic air pollution as hazardous wastes. That’s what’s happening in Midlothian now. Although decades of citizen action have modernized the equipment and stopped the burning of official hazardous waste, the three cement plants continue to burn a wide variety of materials, and the pollution continues to blow wherever the wind takes it.
As long as there’s limestone to be mined, the cement plants will remain open in Midlothian. As long as they stay open in Midlothian, they’re going to try to burn all kinds of wastes. When they do, they release a lot of toxic air pollution. And as long as the wind patterns stay the same that means that seven million DFW residents will be exposed to that toxic air pollution.
And that’s the reason why DFW is always just one multinational decision away from being downwind of a huge hazardous waste incinerator again, or a municipal waste incinerator, or a medical waste incinerator: Because we’re already downwind of the three hungry cement plants that need to burn any and everything they can get their hands on, the cheaper the better. And if they can get paid to throw things in the fire, well that’s a business formula they can get behind. As long as they need to feed their flames, they’re out combing the streets for things to burn – including “hard to burn plastics” for an industry that needs its own greenwashing cover story.
Until the manufacturing of cement no longer demands a sun-hot flame, or they run out of limestone rock, the Midlothian cement plants pose pose a huge on-going air pollution threat. The Dow project to burn plastics is just the latest, but not last, chapter. That’s why as long as there’s cement being made here, there also needs to be vigilant downwinders.
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.
Economics and Physics has the Nobel. Journalism has the Pulitzer. Environmentalists have the Goldman.
The Goldman Prize is the world’s largest award honoring grassroots environmental activists. It’s awarded to six activists every year – one on each continent. Winners are selected by an international jury who receive confidential nominations submitted by a worldwide network of environmental organizations and individuals. Since the it was established in 1989, a total of $15.9 million has been awarded to 157 honorees from more than 79 countries.
Last month the 2017 Goldman Prize winners were announced and two of the recipients echo local fights of our own, briefly turning the spotlight on Downwinders’ beginnings as a group fighting the burning of hazardous waste in the local Midlothian cement kilns.
Uroš Macerl, an organic farmer from Slovenia, successfully stopped a 130-year old LaFarge cement kiln from co-incinerating pet coke with hazardous industrial waste by rallying legal support from fellow Eko Krog activists and leveraging his status as the only citizen allowed to challenge the plant’s permits.
As part of the celebration of his winning, global anti-incineration group GAIA is hosting a page featuring other cement kiln warriors and of course no such page would be complete without a mention of Downwinders. Answering the question posed by GAIA of “Why We fought?” the memorial features the Downwidners float in the 1995 Duncanville Fourth of July Parade with the statement the “We fought the largest hazardous waste permit in US history against TXI cement because we didn’t believe official assurances that it was safe to burn modern toxics in obsolete cement kilns. We were right.”
The North American Goldman winner was Mark Lopez who was recognized for his role in closing down, and then getting a clean-up of the Exide lead smelter on Los Angeles’ East Side. That would be the same Exide corporation that operated an outlaw lead smelter in Frisco until Downwinders and its affiliate Frisco Unleaded teamed up to close it down in only nine months back in 2012.
Downwinders salutes all the Goldman Prize winners but wonders if anyone on either coast will take note of what this “little group that could” has done here in the belly of the beast over the last two decades? If you agree we’re at least worth the consideration, won’t you please throw some money into the hat. We’ve still got Giants to slay.
Holcim is the first cement plant in the nation to voluntarily install an industrial catalytic converter called SCR on its smokestack, significantly cutting smog-forming air pollution in DFW.
But despite operating only 26 miles from EPA headquarters, the Agency and State of Texas still claim the technology isn't "feasible"
Downwinders is proud to announce Midlothian's Holcim cement plant is the first in the nation to voluntarily install pollution control equipment significantly cutting smog-forming air pollution, along with other dangerous emissions.
"Not many people may notice, but Friday is a big day for air breathers in DFW, as well as for everyone in the country who lives downwind of a cement plant," said Tamera Bounds, Chair of Downwinders at Risk, the clean air group that's been relentless in its pursuit of the technology for North Texas since 2001.
Friday marks the official deadline for Holcim's Midlothian cement plant to have its Selective Catalytic Reduction, or SCR system, up and running on one of its two giant kilns in order to be compliant with EPA emissions limits.
Although almost a dozen cement plants in Europe have installed the technology over the last twenty years and it's widespread in the American coal industry, Holcim is so far the only cement plant in the U.S. to install SCR on one of its kilns without a government mandate.
A pilot test using SCR at Midwest cement plant was required by a Department of Justice enforcement action in 2010. Results show smog-forming pollution was cut by at least 80% – roughly twice as much as pollution controls now in use in the US, including Midlothian. In Europe, SCR has a track record of removing 80-90% or more of the smog-forming pollution that has kept DFW in violation of the Clean Air Act since 1991. It also cuts the emissions of air toxics, particulate matter, and dioxins by double-digits.
With three cement plants and four kilns, Midlothian hosts the largest concentration of cement manufacturing in the US, and the largest "stationary" sources of air pollution in DFW. Since the late 1980's, the city has become a national battleground over cement plant pollution. First, over the use of hazardous waste as "fuel" for the local kilns, then over the closing of dirtier, obsolete "wet" kilns contributing to smog and climate change, and now over how fast new kilns can be updated to reflect 21st technology. ￼
Bounds and others say the installation of SCR on all four kilns in Midlothian would mean a huge benefit to public health for residents in Tarrant County, where the predominant winds push the plumes from the kilns. A 2009 Cook Children's Hospital study showed childhood asthma levels highest directly downwind of the cement kilns.
The demand for the technology is a central part of the group's push to replace the current State-sponsored anti-smog plan with a more effective, and protective, one from EPA. So far, Dallas County, the City of Dallas, two Congressional Representatives and a State Legislator agree with them. But incredibly, the Agency maintains the SCR technology Holcim has freely invested in to reduce pollution and is already operating less than 30 miles from its regional headquarters is not "technically feasible."
Downwinders and other groups in the DFW Clean Air Network regional alliance are challenging EPA's refusal to recognize a game-changing pollution control technology that could help DFW finally put its smog problems behind it a well as offering similar help to other parts of the country downwind of cement plants.
"It's rare these days to find the EPA embracing Texas' approach to ignoring advances in environmental science, but that's exactly what happening," said Bounds. "Both State and EPA officials are acting like 3rd Graders – closing their eyes and humming loudly, pretending this time-tested technology isn't operating right in front of them. But it does, and it's here to stay."
Bounds wants the EPA to take note of the cuts in pollution triggered by Holcim's operation of its SCR system and then hold ALL the Midlothian plants to the same modern standard. "You have a piece of equipment that is setting a higher bar for pollution control. Every cement kiln in DFW should have to meet that higher bar now. No other anti-pollution strategy makes sense."
It's been a long and circuitous route to getting SCR installed in a Midlothian cement kiln. Along the way, the region's clean air activists moved the entire nation closer to widespread use of this control technology.
North Texans first heard about the use of SCR in the cement industry through a citizens group fighting a proposed new cement plant in New York state in 2001.They'd commissioned a study from a NYC engineering firm identifying European cement plants that had already successfully installed the technology.
Downwinders tried and failed to include SCR in the anti-smog plan in 2003. It then used a 2005 settlement agreement with the State over the failure of that plan to get the then Rick Perry-controlled Texas Commission on Environmental Quality to perform an independent assessment of the technology. That landmark study produced results that are still reverberating today. In it, five independent experts chosen by Downwinders, the cement industry, and the State declared SCR to be ready for prime time.
"SCR is a commercially available technology. It offers the possibility of significant NOx reduction at the plants in Ellis County. As an 'add on' technology, which can achieve 90% or greater NOx reduction, with demonstrated performance at hundreds of coal fired power plants, SCR is a viable technology that is available for both dry and wet kilns."
That conclusion, from cement industry experts, in a TCEQ study, is now a decade old.
At the same time they were working to bring SCR to Midlothian, Downwinders also led the fight for new EPA emission limits on cement kilns that burn hazardous waste. A 2009 national hearing at DFW Airport attracted over 200 people. Those emission limits clamped down on air toxics. Holcim couldn't meet them without adding controls. They choose an SCR unit on one kiln and a thermal oxidizer (re: flame) on the other to try and stay in compliance. Even though Holcim installed SCR to address air toxics, or Volatile Organic Compounds and not smog pollution, the effect on emissions will be the same.
Meanwhile, the 2006 TCEQ study and subsequent push by Downwinders for SCR in Midlothian helped persuade the EPA to require the pilot test in 2010. That test, as well as Holcim's experience in Europe, set the stage for SCR's official debut on the Texas prairie on Friday.
"It's been a long fight, but change is hard," said Bounds, "and it doesn't happen in a straight line."
Help Us Celebrate This Victory That Was 15 Years in the Making
Please consider contributing $25 or more on "GIVING DAY" NEXT THURSDAY to keep us on the front lines of change another 15 years.
Giving Day is an all day online giving event sponsored by the Communities Foundation of Texas.
Downwinders will have our own online Giving Day page where you can click and give from 6 am through 12 Midnight next Thursday.
Every contribution of $25 or more is matched or extended by the Foundation.
This year, we need your support to keep our full-time staff in the field, as well as fund our 2nd annual Root and Branch Revue for activists, and assemble our North Texas Clean Air Forceof air-monitoring drones.
Oh yeah, we're also opening a school for organizers in January.
We're based in DFW. All our board members are from DFW. Our priority is DFW air. Your contribution stays in North Texas to fund the fight for clean air in North Texas.
We know you're being assaulted by Giving Day appeals from all the local non-profits, and there are lots and lots of good causes. We only request that you ask yourself how many other local groups can repeatedly pull off meaningful victories with so few resources?
We were able to bring SCR to Midlothian with your help. We need your help again next Thursday. We think we've earned it.
State Representative Chris Turner, whose District 101 spans west Grand Prairie and east Arlington between Dallas and Fort Worth became the first state elected official to urge EPA to reject the current state anti-smog plan for DFW and substitute one of its own.
In a letter to EPA Chief Gina McCarthy, Turner used language echoing the sentiments of US Congresswoman Eddie Bernice Johnson and Congressman Marc Veasey.
"While I hope that the TCEQ will take the public comments it received by EPA, the Texas Medical Association, and others into consideration and require additional emissions controls in the final SIP revision it submits to EPA, I ask you to consider rejecting the state's plan use of a Federal Implementation Plan if your agency decides that the final SIP revision is insufficient and the state will not negotiate in good faith."
The entire letter can be read here.
Besides Johnson and Veasey's letters, Dallas County and the City of Dallas have voted in favor of resolutions condemning the currently proposed plan has being inadequate. More cities and counties are expected to pass similar resolutions as elected bodies come back from summer breaks.
Members of the DFW Clean Air Network (DFW CAN) – Downwinders at Risk, the Sierra Club, Beyond Coal, the Texas Campaign for the Environment, Mansfield Gas Well Awareness and Livable Arlington – are also out and about obtaining letters like Turner's from other state and federal elected officials.
Turner's district is directly downwind of the Midlothian cement plants and includes numerous natural gas wells and facilities. Gas sources are now the fourth largest contributor to DFW smog.
According to EPA, the state plan arrived at the EPA's doorstep August 8th, but it's already DOA.
Although ozone season is far from over and it's been a relatively mild "season" so far, we know in its second full year out of the three years allotted for success, the state air plan will, at best, have brought down ozone levels by 1 ppb from 2015 levels, to 80 ppb. We're supposed to be at 75.
The parrot is dead. We're just waiting for the state to admit it – or the EPA to shut the farce down.
Meanwhile, the more political support on the ground in DFW for an EPA alternative that might actually reduce emissions from major sources in North Texas like gas, cement kilns, and coal plants, the more likely it is for the Agency to accept the challenge, and endure all the pushback from Austin it'll get if it decides to take over the job.
If you're interested in trying to get your city, county, or state or federal elected officials to join the band wagon and reject the state plan, write or call us and we'll work with you in getting something accomplished that can add to the momentum.