A little after 5 pm Monday February 3rd, the Office of Environmental Quality and Sustainability (OEQS) at Dallas City Hall released its draft recommendations for the city’s climate “action” plan. There are 93 “action items” including transportation, buildings, green spaces, water management, solid waste, and urban agriculture. Most are without imagination or timelines, meaning that even the most milk toast-like recommendations being made will have to be fought for tooth and nail to be done in a timely manner.
Like the department that generated them, the list of recommendations is effusive about stormwater management and tree-planting and silent on more challenging issues such as inequitable pollution burdens and the City’s own reliance on natural gas. It once again puts the spotlight on the lack of any environmental health expertise at Dallas City Hall in the decision-making process. When Dallas OEQS staff talk about the environment, what they really mean is “conservation” – a definition that’s been obsolete since at least the 1970’s.
There’s no better example of how this tunnel vision affects policy than OEQS staff invoking DFW’s chronically poor air quality (i.e. an environmental health problem) to sell the need for its Climate Plan…only to see the actual Plan ignore poor air quality as a serious health issue that could use some innovative thinking.
For over a year now, anytime you saw a Climate Plan presentation by Dallas OEQS staff, it always cited DFW’s smog problem as something that would only get worse as the climate crisis played out. “Everyone here is probably aware of DFW’s longtime air quality problems” or some approximate was the standard riff. And of course, everybody was. Heads nodded. Audience members were sometimes asked if they knew anyone with asthma and hands immediately shot up. That was the point. The selling point.
Because, until recently at least, the abstract nature of “the climate crisis” made it difficult to get people excited about the idea of a plan. Staff/Consultants needed a hook. And that hook was something everyone could relate to and probably already knew about: DFW’s three decades of violating the Clean Air Act. If you look at the results of the Ctiy’s online survey asking about frequency or intensity of climate change effects, “Poor Air Quality” was the second most cited concern. Among the City’s own handpicked crew of “stakeholders” advisors, it tied for first, along with buildings/energy use, getting more votes than parks, “nature-based approaches,” and renewable energy.
And yet, in those same City Staff presentations that highlighted poor air quality as a reason to have a Climate Plan, air quality itself was completely absent in the staff’s list of anticipated recommendations. It wasn’t that they just didn’t have much to say. They had nothing to say. There wasn’t even a category for air quality.
So Downwinders complained. Loudly. Staff and consultants sprang into action and came up with a category of recommendations officially called…“Other,” the theme of which was “air quality standards” and “public education.” Opportunities cited included “location-specific initiatives (e.g. downtown)” and “Programs targeted outdoor workers (e.g. Landscapers, construction workers).”
So sure, we have a chronic air pollution problem that warrants a $500,000 consultancy fee to construct a plan, but in that plan we’re only going to continue to inform people of that problem and maybe do some kind of vague thing relating to the poor souls who work outside (limit hours, hand-out free oxygen, help find new employment, or maybe free health check-ups? Doesn’t give a hint). By the way, only the public education part of that slide made it to last Monday. Construction workers and landscapers are still up a creek.
Along with those snippets of text on the “Other” slide were large color pictures of the “Breathe Easy” 5K run sponsored by The Jerome Alston Memorial Foundation in May…during Ozone Season. We’ll give the City staff credit. In terms of public education, there might not be a better way to personalize the seriousness of DFW’s air pollution problem than having North Texas smog cause an emergency asthma attack while you’re running in it. But liability could be an issue.
As late as the final round of public meetings last Fall, staff still didn’t have an “Air Quality” category but said they would have “something” when the plan was published.
Turns out “something” looks a lot like nothing.
Among the 93 “actions” listed in the Plan’s draft, the category of Solid Waste gets nine recommendations. Water Resources 15. Urban Ag 14. The brand new category of “Air Quality” has four – the fewest of any category in the plan. It’s practically stamping “Last-Minute Desperation” on the whole subject.
And tell us if any of these recommendations sound like anything you might have already heard about…
Let’s take them from the top.
The very first thing out of the gate, the lead-off, sexiest, out-of-the-box recommendation for improving air quality is…. somehow talk the State into adding more obsolete, state-run air monitors at some unspecified time in the future.
If you can, forget that the State environmental agency – the Texas Commission on Environmental Quality (TCEQ) – is a model for the Trump Administration. Forget that its official position is that smog is waaaaay overrated as a health threat. In other words, forget that this is akin to hiring Charlie Sheen to babysit your only child.
It’s not the baked-in, in-your-face cynicism of City staff knowing the state has every reason not to do this that’s so offensive. It’s the same cynicism applied to knowing full well what will happen even if the state says yes to the request: no real improvement in local information about air quality. Those state monitors are big, slow, and sparse. They run two hours or more behind real time. They’re hard to find online. They’re needlessly expensive and take up lots of real estate that has to be purchased. Their placement is decided by TCEQ and city staff, not the communities most in need of them. There is no stated OEQS goal for the number of monitors to acquire, or suggestions about where new monitors should be. No language in the recommendation about wanting real time monitoring or more modern equipment. It’s just an expansion of an already-obsolete system the state only runs because federal law requires them to (for now).
So let’s say the City talks the state into doubling the number of state PM 2.5 monitors in Dallas. Victory! The discussion will then be where to place the second slow, hard-to-find PM monitor for all of Dallas County’s 2.5 million residents.
Left unsaid in this recommendation is something we already know. For a year now Staff has tried to move that single Dallas County PM monitor located on Hinton Street north of Downtown to somewhere in Southern Dallas. Apparently the state has made that hard-to-impossible and so for the purposes of having something, anything, to recommend for this climate plan, staff recommends more monitors – knowing there’s a snowball chance in Hell of getting them. It’s the perfect bureaucratic out.
Most importantly the City remains a spectator to the reporting to its residents of how bad their air is. Its staff doesn’t have to make any environmental health judgments as they’re busy promoting tree planting. They leave that up to the people who couldn’t care less about how much pollution you’re breathing.
In the wake of recent Gulf Coast chemical plant accidents, the TCEQ is under heavy criticism for its lack of current air monitoring technology. The system it operates in DFW hasn’t changed in over 20 years. TCEQ won’t even put an air monitor in the only DFW “non-attainment” county that doesn’t have one – Wise – where smog levels have been predicted to be even higher than in DFW proper.
Recommending a modest expansion of circa-1999 technology is the opposite of a “best practices” answer for our gap in local air quality knowledge. The most alarming thing about this recommendation is that it got made at all.
The one-liner stapled at the end about offering free health screenings “with Dallas County” (who’s already in the business) in “areas with poor air quality” is incredibly condescending. Here’s the ultimate “settlement house” approach to a social ill – addressing the symptoms but not the cause. “Well, we can’t do much to enforce code or keep those batch plants out of your backyard, but by God we’ll be around every 6 months to keep track of your asthma until you die from it.”
How does OEQS staff know where those “areas with poor air quality” are now unless they’re out monitoring them? Which they clearly do not want to do. Given there’s only one official PM monitor for all of Dallas County, how are they defining “areas with bad air?” If they’re making educated guesses where those “areas” are based on other factors besides monitoring, why not name those factors and the “areas?” OEQS goes out of its way to avoid using the words “environmental justice” even as it makes recommendations based on the concept.
Recommendation #2 – let’s build our own “non-regulatory” air monitoring network sometime in the unspecified future with unspecified non-profits and community partner volunteers and put an unspecified number of monitors in unspecified places, for which we unspecified criteria. And these monitors “could be used to “to track progress for air quality improvements based on strategic initiatives deployed in CECAP, and the comprehensive plan.”
This is actually a great idea. It’s such a great idea that a specified alliance of local governments, non-profits, and community partners are already doing it in specified locations with specified monitors. Their effort is about to deploy over 100 locally-built air monitors that will increase PM 2.5 monitoring in Dallas County by 4000%. It’s called the SharedAirDFW Community Air Quality Monitoring Network and the City of Dallas officially walked out of it last year over a public participation requirement and a desire to refrain from being the source of bad news about bad air.
Dallas city staff is consistent in believing that telling you about air pollution is absolutely, positively necessary – they just want someone else to do it.
Having walked away from the SharedAirDFW network, OEQS set out to make one up of its own using the City Hall-friendly Nature Conservancy as its non-profit partner. The “Breath Easy” plan was to put 9-12 PM and smog monitors on the same number of DISD campuses, grow trees and implement anti-idling zones at those schools and see if asthma attacks/rates dropped in 24 months (2 growing cycles). Everyone seemed to agree how important a project this was and the city raised $500,000 or more to buy 12 very nice Aeroqual (Recommended by Downwinders since 2017!) air monitors. Everyone but the Dallas independent School District, who nixed the idea last summer. This detail somehow escaped the presentation staff gave to the City Council’s Quality of Life Committee on the Breath Easy project in September 2018.
So far the City of Dallas is 0 for 2 in making their own recommendation a reality when it had the chance. But wait! Remember those 12 monitors the City bought for the defunct Breathe Easy project? They’re just sitting somewhere. They’re already paid for but aren’t being used. OEQS could implement this recommendation of theirs on its own tomorrow if it wanted to by placing these 12 monitors in locations based on where the most industrial facilities are and where the most air pollution complaints come from. Overnight it could have its own fleet of “non-regulatory” monitors in the field, with all the benefits cited by staff.
But there’s no mention of those 12 monitors, or of the City Hall’s ability to accomplish this goal on its own, right now, without waiting. Because it doesn’t want to. It wants someone else to do it.
Recommendation #3 . It’s that forlorn public awareness recommendation showing up in the form of continued support for an ozone season air quality campaign run by a group that did its part to make smog an issue for years. There’s no harm to this but there’s also no help. This campaign will go on for as long as DFW is in violation of the Clean Air Act and doesn’t mention climate change.
Finally, there’s recommendation #4. Perhaps (but perhaps not) heavy industry that pollutes a lot shouldn’t be close to homes. This is coming straight-faced from a OEQS that’s approved the last four batch plants seeking permits to set-up shop in Joppa and the South Central Corridor…next to homes. Do as we recommend, not as we actually, you know, do.
When it says the City will review zoning, that’s not a special environmental health screening of sites. It’s just part of upcoming land use planning processes that will already be used to re-examine all zoning on a neighborhood-by-neighborhood level. They’re riding coat tails. The OEQS doesn’t make recommendations about suggested buffer zones, where those zones should be, or what criteria the city should use in pursuing buffer zones. And it doesn’t even say the City’s neighborhoods need any buffer zones between homes and industries at all, just that it may want to consider them at an unspecified time by an unspecified body for unspecified neighborhoods. Have we mentioned the staff at City Hall really really doesn’t like to deal with environmental health issues?
We get it. They had to have something or you’d be reading our criticism about the absence of ANY specific air quality recommendations, no matter how lame. And there are other items in other categories that will inevitably produce decreases in air pollution of all kinds – bus and vehicle fleet electrification being among the lowest-hanging fruit.
But City Hall’s cynical use of DFW’s air pollution problem to win support for a plan that ends up doing nothing about it directly makes these “Air Quality” recommendations particularly contemptuous.
What would more sincere “air quality” recommendations look like?
1. Acknowledging an historic imbalance in the air pollution burdens borne by Dallas neighborhoods and a commitment with a deadline to inventory the City’s air pollution threats by council district and zip code. You can’t fix what you don’t measure. Right now there’s no map of where concentrations of air pollution are in Dallas.
2. Acknowledging there’s no safe level of PM air pollution, i.e., no amount of exposure that isn’t capable of doing harm. Acknowledging People of Color are exposed to more, and higher levels of PM pollution than their white peers. These conclusions, supported by a multitude of good studies, including ones from EPA, are basic in prioritizing where to reduce air pollution in Dallas.
3. Recommendation to write an Environmental Equity Provision into City Code to discourage and prohibit siting new polluters in those zip codes hosting more permitted polluters than the citywide average, beginning in 2021.
4. Recommendation to quit siting polluters in any floodplain beginning in 2021.
5. Recommend a 2025 deadline for the electrification of all railroad switch yard operations in Dallas.
6. Recommend 1500 foot buffer zones on either side of new major highways where homes, day care centers, and schools would be prohibited from locating. Applied to existing highways as uses within 1000 feet come up for new permits and zoning.
7. Recommend the immediate amortization and relocation of the GAF asphalt shingle factory in West Dallas and the TAMKO shingle factory in Joppa. These factories are among the City’s largest industrial polluters in Dallas, accounting for over 420 tons of air pollution in 2017 alone. They operate in the middle of dense urban residential areas populated primarily by People of Color. They need to be relocated elsewhere. Building new facilities will automatically trigger modern pollution controls requirements. They’ll be cleaner and doing business in a less harmful location.
8. Recommendation to rewrite city codes giving incentives for cleaner industries and more requirements for dirty ones.
9. Join UTD’s SharedAirDFW Community Air Monitoring Network – plug OEQS’ 12 unused monitors into the Network and begin to take responsibility for telling Dallas residents what their air quality actually is.
10. Acknowledge the conflict of interest the City has in producing and selling gas from its landfill recovery operation and commit to electrification of all city-owned vehicles by 2025. Dallas’ own city-run McCommas Bluff methane gas recovery facility is the fourth largest air polluter in Dallas, releasing over 160 tons of air pollution in 2017 alone. Recommend contracting only with electric vehicle fleets for additional services. Los Angeles recently committed to an all electric garbage truck fleet in five years, and Dallas could do the same – but it still wants to use its own landfill gas to power combustion vehicles.
11. Implement stronger enforcement of the city air quality and nuisance ordinances, including hiring new staff and publicizing how to request an investigation.
12. Beginning in 2025 begin collecting municipal clean air mitigation fees of $50 a pound on permitted air pollution from major sources to incentivize pollution controls and pay for new staff. In 2017 such a fee would have collected over $1 million.
13. Implement no idling zones in all Dallas warehouse districts.
14. Recommend Low-Emission Zones in Downtown Dallas where combustion vehicles are banned or restricted, permanently or on a schedule. Consider expanding to other parts of Dallas such as Deep Ellum and Bishop Arts where congestion is already a problem.
15. Recommend PM pollution protection be designed into new bus shelters.
16. Recommend establishment of an Electric Bus Procurement Pool with DISD, DART, Trinity Metro, other area schools districts, and transit companies for cheaper purchases of electric buses.
17. Restoration of the Dallas Environmental Health Commission.
18. Hiring a City of Dallas Environmental Health Scientist.
DFW does have a chronic bad air problem. The Climate Crisis will make it worse. It is a legitimate area of policy planning in any thoughtful, modern Climate Plan.
Just not this one.
A small army of University of Texas at Dallas graduate students are assembling over 100 solar-powered wireless air monitoring units to be dispersed throughout the metro area. A third of those have been purchased by Downwinders for placement in Joppa, West Dallas, and Midlothian. 40 or more or going to Plano. Three Dallas County Community College campuses are receiving one, along with the Fort Worth and Richardson school districts.
And now news has come that Paul Quinn College has received an EPA grant to purchase 11 of these monitors for placement around its Southern Dallas campus. Downwinders is working to coordinate the location of its Joppa area monitors with Paul Quinn to provide Southern Dallas with its own mini-network of monitors.
Meanwhile another group of UTD students are working on the mapping software and app residents will be able to use to access the data in real time. They’re being led in this effort by Robert “The Map” Mundinger, who Downwinders hired for the job. All in all, Downwinders has now invested almost $50,000 in this network, which we hope will become a model for the rest of Texas and the nation.
2019’s “ozone season” came in like a lamb but is headed out as big, wheezy lion.
A three-day stretch from Thursday September 5th to Saturday the 7th that combined triple digit temperatures with lots of air pollution was enough to push Dallas-Fort Worth smog numbers for the year over 2018’s annual average. It was the first year-to-year increase in ozone levels since 2015, and more than enough to insure DFW will be in violation of the Clean Air Act for the 28th year in a row.
Because the formula for arriving at these averages is so convoluted, discounts the highest three numbers, and is stretched out over 8-hour periods, it takes a lot ozone to make them go up even incrementally. Raising the annual average by even one part per billion (ppb), from 76 to 77, as occurred by Saturday evening, hides a lot of Really Bad Air. Smog levels were in the 90’s and even close to 100 parts per billion at monitoring sites in the northern part of the Metromess. EPA’s national standard for 8-hour exposure to ozone is a 70 ppb average.
Three sites saw their 2019 highs set during this 72 hour period. Frisco had an eight hour average of 88ppb on Saturday, Keller 84 ppb and North Dallas 83ppb. There were four hours on the afternoon of the 6th when smog was over 90 ppb in Frisco.
That’s reminiscent of the bad ‘ol days from the Turn of the Century when levels in the upper 90’s and even topping 100 ppb were routine. Since 2000, there’s been a more or less steady fall in smog in DFW thanks to better controls on combustion-powered vehicles, and the citizen-induced decreases in pollution from Midlothian cement plants and the retiring of East Texas coal-fired power plants. In 2000 DFW’s annual ozone average was 102 ppb. It’s taken 20 years to lower that number to the high-to-mid 70’s. For the last three years we’ve seen decreases of 3, 1 and 3 ppb. 2019 halts that downward trend.
Beside the human health toll these numbers represent – an increase in asthma attacks, ER visits, strokes and heart attacks. – they also represent a challenge to government. This increase comes as the usual planning process to reduce dirty air in DFW sits in tatters. In fact, there really is no process anymore.
In the past, the North Central Texas Council of Governments (NTCOG) would bring the Chambers of Commerce, elected officials and some environmentalists together to cobble out a list of proposed strategies to reduce smog, then submit it to the Texas Commission on Environmental Quality in Austin where it would get watered down by corporate lobbying. Nevertheless, those past plans did have an influence on tightening emissions for ancient cement kilns and other industrial sources and they can take some credit for the two-decade decrease in smog.
But that process hasn’t taken place since even before the current administration took office. The last plan submitted by the region to the state was in 2013. Because Austin kept ignoring most of the region’s recommendations, NTCOG just gave up trying after that. It’s Clean Air Steering Committee was disbanded and hasn’t met for six years now. Despite approaching our fourth decade of illegally bad air there’s no official body in DFW working on a regional clean air plan. Everything is being run by Greg Abbott’s state agency – one that doesn’t believe there’s a climate crisis, wants to increase permissible exposure for dangerous pollutants, and whose former Toxicologist in now leading the Trump administration’s efforts to roll back federal pollution standards.
It’s doubtful a single part per billion rise in the regional average will prompt reconsideration of this laissez-faire approach. But it should.
Before the 2016 election, Downwinders was trying to pave a path for the federal government to take away the power of Austin to determine DFW’s clean air progress. We had hoped to have EPA delegated as the “final cut” author of a new clean air plan. Trump’s election made that impossible. But should this administration be gone by 2021, that strategy is still one local residents would be wise to pursue. As long as the State’s environmental agency is in the hands of anti-science flunkies and fanatics, there will be no concern about DFW smog in Austin.
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
Thursday, December 6th
Catch the bus at 6:30 or 7:00 pm
at the Green Door in the Farmers Market District
600 South Harwood Dallas 75201
Plug In. Get Lit. Stay Current.
How did we get from cement plants burning hazardous waste in Midlothian to transit or and school buses making runs in inner city Dallas?
The answer is PM, Particulate Matter. The two-decade fight against the cement plants was one long primer on PM pollution. They were, and remain the largest industrial sources of the pollution in North Texas. We learned firsthand about the toxicity, reach, and insidious health effects of PM pollution. Not just strokes and asthma, but IQ loss, Autism, Dementia, Diabetes, low-weight births. PM is the new lead.
Every boiler, furnace, fire, flame and combustion engine produce PM. Diesel engines emit an exceptionally toxic form of PM called Black Carbon.
Because they’re on the road so much, are diesel or natural gas-powered, and make people wait by the side of traffic-heavy roads to ride, bus systems turn out to be a major source of PM pollution. And climate change gases. And smog. A rough estimate shows DART’s bus fleet would be the 10th largest PM source in Dallas County if it were all parked in one spot. But of course its the dispersed nature of a bus fleet’s pollution that often makes it more of a widespread threat to public health than a stationary “point source” a.k.a. an industrial facility.
What’s missing is a constituency for electrification of school district bus fleets and transit agencies like DART and Trinity Metro. Because of the potential impacts and benefits, this could be a wide-ranging and powerful alliance – PTAs, transit riders, physicians, environmentalists, environmental justice advocates, and even the utilities that could buy the power from bus batteries. But until we get the ball, er wheel rolling, its all just that – potential.
One of the reasons we’re sponsoring the December 6th “Electric Glide bus pub crawl” as part of this year’s Root and Branch is that we wanted to start that rolling. And real, wheels-on-the-bus-go-round-and-round rolling discussions and presentations on the advantages of electric buses are part of the evening, but so is just showing your support for the goal of electrification as something local officials could accomplish right now, especially if they combine their collective purchasing power.
The more people that show-up on the 6th, the more DART and local school boards – whose memberships we’re inviting as well – will get the impression someone gives a damn and the more we’re a force to be reckoned with. We need a people’s lobby for 21st Century electric buses in DFW.
In exchange for coming out and forking over $25, we give you three custom drinks, Graham Dodds’ food, a presentation by Dale Hill, the co-founder of the Proterra electric bus manufacturer, and maybe, just maybe some food for thought about what we all can do right now to advance a bunch of causes in one campaign that’s winnable at the local level in the Trump era.
Thursday, December 6th
Catch the bus at 6:30 or 7:00 pm
at the Green Door in the Farmers Market District
600 South Harwood Dallas 75201
Plug In. Get Lit. Stay Current.
Only in the nonsensical world of EPA air quality regulation could the official regional average for DFW smog actually decrease despite the worst levels of DFW Ozone pollution in five years.
In 2018 a quarter of all North Texas official monitor sites recorded smog levels in the 90-95 ppb range for more than an hour. 2018 was the first time in two years that any DFW monitors have had 8-hour averages of 80 ppb or above, and the first time since 2013 since there been at least six. In fact, this year’s total number of 80-or-above monitors is almost equal to the total number from the last five years combined.
Nevertheless, the regional average for smog pollution that determines government action actually went down from 81 to 76 parts per billion.
How does that happen? Not without a lot of numerical manipulation. EPA’s formula for smog pollution classification is a two part affair. First EPA only counts the highest 4th highest annual reading from each monitor in DFW. That means every monitor gets three “Mulligans” or “do-overs” before the results are eligible for regulatory use. Then EPA combines the last three year’s worth of those highest 4th highest readings to produce a rolling average. So that 2018 average is actually the results of the highest 4th highest reading from 2016, 2017, and 2018.
High readings from the summer of 2015 are rolling out of that three-year rolling average, while lower readings in ’16 and ’17 remain. While this year’s smog levels were higher, but not so extraordinarily high as to be able to counter the lower numbers making up the rest of the average.
But our smog was bad enough last year and this to once again make sure DFW is in “non-attainment” of the clean Air Act for the pollutant. For the umpteenth time in a row, we missed a deadline for meeting a Clean Air Act smog standard – this time it’s the 2008 75 ppb standard. If EPA follows its own protocol, that means DFW will be go from being “moderately” out of compliance to being in “Serious” non-compliance.
And please remember all of these numbers are based on only 20 smog monitors, half of which are located well-outside the DFW urban core, and none of which are located in Wise County, where Downwinders is doing the job of monitoring ozone pollution that the State and EPA refuse to do.
What are the consequences of this continuing violation of the Clean Air Act that imperils public health? Nada probably. At least while the Trump Administration holds office. In the past such classifications would have triggered a process leading up to some kind of official plan of action that, at least rhetorically, is aimed at correcting the 30-year old problem. But no one expects the State of Texas, or now the EPA, to take that responsibility seriously.
What you can expect is some official TCEQ spin about how it’s been successful in bringing down smog pollution levels. In fact, it was the wettest September on record that brought an abrupt end to what was shaping up to be an even worse smog year than it already was at the end of August. Historically, September is when DFW sees some of its worst bad air days. But not this year.
Accompanying the rise in smog pollution in 2018 was also a dramatic rise in the regional numbers for Particulate Matter (PM) pollution – the highest North Texas has seen since 2003.
After a long spell of annual peaks of between 24 and 28 migrograms per cubic meter of air, the 2018 average for highest daily readings among all sites has risen dramatically as of this month – to almost 40 µg/m3
Before this year, they’d only been four daily peaks above 40 µg/m3 over the last 15 years. In 2018 four out of 6 PM monitoring sties had registered daily readings averaging between 41 an 43 ppb as of October.
The EPA annual standard for PM pollution is 12 µg/m3. The 24 hour standard is 35 µg/m3.
As with smog, these readings are coming from a very small pool of monitors – in this case just six PM monitors scattered over an area only slightly smaller than Rhode Island.
Some of this might be blamed on the drought we we experiencing during the summer and increased dust circulation, but comparing it to 2011 when similar if not worse conditions were in play shows no similar bump then. Fewer coal plants blowing their plumes into DFW this year might lead you to think we were even due for a drop. Instead it’s as if someone turned the key on a couple more. There’s no obvious reason why PM levels would have jumped so much in a single year.
What’s clear is that local governments are the last refuge for effective and new air pollution control measures. Until political leadership changes in Austin and/or Washington, there’s no expectation of any relief. In fact, every day sees new proposals from the State or EPA that will actually increase smog and PM pollution in DFW. This is why local city and county elections are just as important as state and national ones.
We’ll have to wait until the end of 2019 to see if this rise in pollution averages is a trend or blip, but there’s no question that smog and PM are taking their toll on public health in DFW. Study after study shows harms at levels of exposure well below these annual and daily averages that determine EPA regulations. In the real world, your lungs, heart, brain and immune system don’t seem to be able to distinguish between “safe” and “unsafe” levels of poison as defined by the government.
With months of “ozone season” still to come, 2018 is already one of the worst years of DFW smog pollution this decade.
As of August 9th, six out of the 20 North Texas ozone pollution monitors have registered at least four days when the average concentrations of smog were 80 parts per billion or higher over any eight-hour period. The current EPA ozone standard is 70 ppb over eight hours. Most scientists who study ozone pollution recommend between 60 and 65 ppb.
Unfortunately our lungs don’t breathe averages. Regulatory accounting smooths out the highs and lows. This summer has seen at least five sites record smog in the 90-95 ppb range for more than an hour. That’s very hazardous breathing.
There’s no question there were public health consequences to those extreme air pollution levels. Asthma attacks were triggered, COPD patients were gasping, but also strokes and heart attacks. We just don’t know how many…until after the fact.
It’s the first time in two years that any DFW monitors have had 8-hour averages of 80 ppb or above, and the first time since 2013 since there been at least six. In fact, this year’s total number of 80-or-above monitors is almost equal to the total number from the last five years combined.
Besides the number of high smog readings, the location of the monitors recording them should be of concern. Five out of the six registering the highest numbers this year have long histories of being among those registering the highest numbers in past years – Grapevine, Eagle Mountain Lake, Dallas Hinton, Dallas North and Frisco. Only Cleburne might be considered an outlier. The fact the same sites keep popping up over and over again means the strategies for reducing smog pollution aren’t working when put to the test like this July’s heat wave.
But of course that assumes there are any strategies for reducing smog in DFW. And technically there are. But they aren’t being vetted for their effectiveness, and they aren’t being enforced, and some are even being rolled back. After 27 years of continually violating the Clean Air Act for smog pollution, there’s nobody in any level of government working on a cogent plan to get DFW into compliance. Law and order rhetoric from Austin and Washington not withstanding.
What made July smog worse than usual was the heat. Climate scientists are telling us we’re going to be having more summers like 2018, not fewer. So this year’s levels are probably a precursor, not an aberration. But that’s a hard sell to elected officials whose campaign accounts depend on denying the science.
The punch line to this year’s sudden and dramatic spike in higher smog levels? It might still result in officials taking the Orwellian stand that the air in DFW is getting better. How is such a thing possible? Through the wonders of regulatory math.
EPA’s classification of how bad or good air quality is in any region is done by taking the 4th highest annual reading from each monitor and then keeping a rolling average of three years’ of those annual 4th highest numbers for each monitor. For this year, only the 4th highest numbers for 2016, 2017 and 2018 are included in the rolling average. Denton did see high numbers in 2015, but those are all now rolling off and not being counted.
Up to now those 2015 numbers have kept the regional smog average in Denton at 81 ppb despite relatively light ozone seasons in 2016 and 2017. Now that that 2015 high number is rolling off, it would take the Denton site having 4 separate days of 90+ ppb smog in the next 90 days to make the average rise back up to 81 ppb. If that doesn’t occur, then the Denton average could drop to somewhere in the mid-to-upper 70 ppb range.
Should that happen, expect to see lots of regional back-slapping among officialdom for bringing down that Denton number and “continuing to make air quality progress.” Even as more monitor sites see higher smog numbers, officials will declare their anti-pollution measures are working splendidly. But that will not be the case, and you should not be misled.
While there might be a bit of specific progress made at the Denton monitor site, the increase in the number of other sites registering higher levels of smog they haven’t seen in years negates it. If all it takes is a heat wave to send two years of lower numbers down the drain, and the future is full of heat waves, then that’s not really progress, is it? We’re forced to put our fate in the hands of the weather instead of our own planning. Not very proactive, but that’s the state of air pollution control in DFW in 2018: “Please Dear God, keep it cool this summer.”
Even before the Trump Administration came into office the EPA wasn’t enforcing provisions of the Clean Air Act that DFW blew by ages ago – not correctly classifying its non-compliance, not requiring controls on major polluters, providing one extension after another. Now of course, there’s total abdication of even the pretense of striving toward cleaner air for its own sake.
Which is why if any progress is going to be made over the next 2-3 years, it must be made at the local level. No one else gives a damn. Officially.
Over a decade ago $500,000 was collected from North Texas local governments to protect Texas air.
It’s been sitting in a bank account ever since. Until recently, not too many people even knew it existed.
Now, citizens want to use a part of it to build a world-class 21st-Century air monitoring network for DFW.
In 2006, then-Dallas Mayor Laura Miller teamed up with Houston Mayor Bill White and organized a coalition of Texas local governments to oppose the “fast-track” permitting of a dozen new coal plants Governor Rick Perry was pushing.
15 North Texas cities, Houston, and McLennan County (Waco) established the “Texas Clean Air Cities Coalition” to fund a legal team and the technical expertise needed to take on not only the big utility companies, but Perry and the State of Texas as well.
But before the battles could begin, a settlement was reached that cancelled all but one of the coal plants. The approximately $500,000 raised by the Coalition to wage clean air war was not needed now. Instead of reimbursing the separate contributors, it was kept in total by the Coalition, possibly because it had already been budgeted to “protect Texas air.”
And there it’s sat ever since. With each new election cycle, the number of local elected officials who knew about the fund got smaller and smaller, until there was hardly any institutional memory of the Coalition or its half-million dollar fund left at all.
Downwinders only recently found about the money in the course of discussing funding of the new regional air quality monitoring network we’re working to establish with local policymakers.
While visiting with Dallas Council Member Scott Griggs about Dallas establishing such a network in partnership with Plano and Dallas County, CM Griggs mentioned the Texas Clean Air Cities Coalition and the $500,000 it had accrued, and asked us how our Network idea was different than the TCACC mission. We consider ourselves the premiere clean air watchdog group in DFW but we had no idea the Coalition or its fund was still around.
And, as it turns out, Griggs is the “Principal Officer” of the fund.
Needless to say, we were gobsmacked.
After reviewing some paperwork on the Coalition in Griggs’ office, we answered his question by suggesting that while the original goal of TCACC was to actively oppose those “fast-tracked” coal plant permits, the mission of the monitor network was to gather air quality information for public health purposes.
But on closer examination, we did notice similarities. Many of the municipalities that contributed to the Coalition fund are the same ones that are now interested in participating in the new monitor network, which like the Coalition, is a regional effort. The Mission of the Coalition is “to protect Texas air” primarily, but not exclusively through permit opposition. The spirit, if not the mechanics of the Coalition and Network are originating out of the same concern for public health.
That being said, extracting the money from the fund for modern use could be a convoluted affair. Despite the broad executive powers given to the Principal Officer in the Coalition’s by-laws, including the authority to commence litigation and intervene in permit proceedings, they don’t address air quality monitoring directly per se. It would appear to take a vote of the remaining Coalition members to ratify a new expenditure for the regional monitoring network, but it’s not clear who they are.
Of the five Coalition officer positions listed in the paperwork Downwinders received from Griggs, three would appear to be vacant, with no one representing Houston, Waco, or Irving due to retirements or elections. Only Griggs and Arlington City Council member Kathryn Wilemon, who both term out in May 2019, remain in elected office.
The discovery of the Coalition fund in 2018 raises all sorts of questions about why it didn’t get used over the last decade of air quality problems. Although there hasn’t been another tsunami of coal plants proposed, there’s still cement plant plants burning industrial waste, still oil and gas facilities still releasing way too much methane, still battles over batch plants in places like West Dallas and Joppa that the money could have gone to…but didn’t. Advocates like Downwinders didn’t even know about it to be able to make the case for its use. It’s a large policy failure on all fronts, that perhaps can be partially redeemed now by spending some of the the collected monies on another regional clean air initiative.
After learning of the Coalition fund, Downwinders asked Dr. David Lary of the University of Texas at Dallas Engineering Department to outline what kind of North Texas air monitoring network could be built with approximately HALF of the fund’s $530,000.
Dr. Lary is the author of the National Science Foundation grant that originally proposed the idea of grid air monitoring in DFW. He’s an expert in the field of high-tech low cost sensors and just got a large US Army contract for testing sensor equipment for the nation’s armed forces.
What he suggested was a 200 + sensor network, operating mostly on solar power and using wifi to bring real time air quality information to the regions seven million residents..for a low, low price of $280,000. This is his itemization:
All previous plans had any regional monitoring network growing slowly by charging affordable fees for purchase and installation of sensors. If there’s a large clean air fund that could pay for the immediate build-out, it would propel DFW into the front ranks of “smart cities” and provide public health benefits much sooner.
Now that a City Council Quality of Life Committee hearing has been set for Dallas to decide whether to join the monitor network, the opportunities the fund could provide deserve overdue attention. The question of what role the fund can or should play in paying for a new regional clean air network will be important. Having squandered the ability to provide the kind of assistance it was created for over a decade ago, let’s hope current officials don’t make the same mistake and ignore public health…again.
After a few technological hiccups, the state’s first permanent smog monitor built and operated by a citizens’ group is up and running in rural Southeast Wise County. And by the looks of this summer’s ozone season, just in the nick of time.
Conceived, designed, and supervised entirely by environmental scientist and UNT doctoral candidate Kari Northeim on behalf of Downwinders, the Atlas Monitoring Station is a first-of-its-kind adaptation of smaller, less expensive technology to perform the job of monitors many times its size and cost. It instantly becomes a huge milestone in our efforts to build a better system of air quality monitoring in North Texas.
The Atlas Station is a product of Downwinders’ Wise County Ozone Project, financed by a grant from Patagonia and an EarthTank prize won by Downwinders at EarthDay Texas in 2016. It’s objective is to collect continuous readings of Ozone, otherwise known as smog, in Wise County – until this week the only one of ten DFW “non-attainment” counties with no ozone monitors.
Besides being downwind of much of DFW’s smog, Wise County is the birthplace of modern “fracking” and blistered with gas patch facilities that produce significant amounts of smog-causing air pollution. However, the nearest official smog monitors are approximately 30 miles to the east in Denton County and 20 miles south in Tarrant County. Despite past state and private computer modeling predicting smog to be worse in Wise County than the rest of North Texas when “ozone season” winds are out of the south-southeast, there’s been no monitor there to test that hypothesis. Until now.
Accurate regional ozone readings are important to DFW because they determine how much in or out of compliance with the Clean Air Act we are. If smog levels being recorded by EPA monitors in their current locations aren’t reflective of higher smog levels actually being breathed in North Texas, then we need to know that and add more protective air pollution measures.
Last spring Downwinders bought two portable smog monitors the size of cable boxes from Colorado’s 2B Technologies at $5000 each. That’s a huge drop in price and size. Traditional EPA monitors doing the same job can cost hundreds of thousands of dollars and take up a quarter acre.
2B factory-calibrates the monitors and they’re already certified by EPA, but from from June 2017 to March 2018, they were subject to additional testing by Kari at the University of North Texas (UNT) Engineering Lab.
Although small, these are incredibly reliable machines with an accuracy of greater than 1.5 parts per billion by volume, or 2% of the total reading. They measure ozone every ten seconds and can automatically average over a minute, 10 minute, or hour interval (like the state monitors do so we can compare apples to apples).
Small, portable, cheaper, but the monitors still need electricity. In order to have more siting options in a mostly rural county, the Atlas uses a 100 W solar panel to connect the monitors to the juice they need to take readings. Batteries provide back-up. This makes is a completely stand alone, self-sufficient monitoring station that we can put anywhere with a good south view.
Air is collected through a funnel and shuttled down a pipe that brings it into a weather-protected box where the monitor itself sits.
During the Wise County Ozone Project, one monitor at a time will be deployed for a period of 3-6 months. Unfortunately, there’s not a way yet to get real time access to the monitor via the internet, so instead data will be downloaded by Kari every month and compared to readings at those Denton and Tarrant County monitors. Not perfect, but better than no monitor at all.
According to Northeim, who expects to be able to mine several scientific papers with the data she collects, “This research is critically important to develop an understanding of the true ozone exposure in Wise County. It’s very exciting.”
Putting a Smog Monitor
Where No Smog Monitor Has Gone Before
EPA has 20 ozone, or smog, monitors in North Texas. Approximately half of those are considered “background” monitors on the edge of the denser urban areas. Originally the DFW “non-attainment area” for smog was only Dallas and Tarrant Counties. As the area’s populations grew, so did its air pollution problem and Denton, and Collin Counties were added, then Johnson, Parker, Rockwall, and Kaufman. Citizens petitioned and sued to bring Ellis And Wise Counties into the fold. All of these counties except Wise have an EPA smog monitor, despite Wise County being included in the non-attainment area since 2012, and despite state and private computer air modeling showing the County could have some of the region’s worst smog.
The early start to 100° + days in DFW this spring has meant an early start to high smog levels as well.
Although it’s not even summer yet, five official EPA ozone monitoring sites in North Texas have already recorded “4th highest” 8-hour ozone averages that put DFW above the 70 parts per billion federal standard for 2018: Grapevine 73 ppb, Keller 72 ppb, Dallas North (by I-635) 73 ppb, Dallas Hinton (Stemmons Freeway and Mockingbird) 72 ppb, and Denton Airport 72 ppb.
No matter what happens the rest of this 2018 “Ozone Season,” these numbers insure DFW will still be violating the Clean Air Act for a 27th year in a row.
Grapevine and Eagle Mountain Lake monitors have recorded the single highest 8-hour ozone levels in the state so far, at 89 and 92 ppb respectively.
Breathers will have to wait longer to find out how this year’s dosage will affect the all-important regional average, driven recently by the results from the Denton Airport monitor. The regional average is the highest 8-hour average number from any one monitor after averaging the 4th-highest ozone readings from each of the last three years. Extremely high years can be off-set by better years, or visa versa.
Slowly, the DFW regional ozone average has come down from the really bad old days of the 1990’s and early-Oughts. But for the last seven or so years, it’s plateaued in the 80-85 ppb range. As of 2017, Denton had a three-year, regional-leading average of 81 ppb.
Many observers believe the recent stagnation in the decrease of DFW smog is due to increased emissions generated by the Barnett Shale gas play taking up the slack from decreases from other large sources like kilns or cars.
A 2015 UNT study using the State’s own air modeling demonstrated the disproportional impact gas industry sources like compressors had on the area’s historically worst performing monitors in Northwest Tarrant County and Denton, accounting for up to 3 ppb of smog.
Closure or mothballing of three large East Texas coal plants will help keep the numbers down this summer from what they could have been, but it may not be enough to outweigh the impact of continued growth and reluctance by authorities to crack down on other large sources like the gas industry or the Midlothian cement plants.
And this summer’s early smog crisis is yet another reminder about why a 21st Century locally-controlled monitoring system is needed. During this last stretch of 100° + heat, when ozone levels were often climbing by 10 ppb or more per hour, the official EPA/State monitors were up to 2 and a half hours late. At 1 pm, a resident was still looking at 10 am data that was obsolete.
If the federal and state governments won’t do anything but make it more difficult to solve our chronic smog problem, it’s self-defense for local governments to at least be able to warn residents about how bad the air is in real time and at a location near them instead of the other side of town.