Cage MatchJOIN OUR TAG TEAM EFFORT TO TAKE DOWN THE STATE OF TEXAS
BUT WATCH OUT – THEY PLAY DIRTY

NEXT THURSDAY EVENING
JANUARY 21st
6:30 PM

616 Six Flags Road
First Floor HQ of the
North Central Texas Council of Governments

There's an important bureaucratic cage match between EPA and the State over how clean your air should be.

The state says just by hitching a ride on already-in-progress federal gasoline mix for cars and trucks, DFW ozone, or smog, will drop to levels "close enough" to the current federal smog standard of 75 parts per billion (approximately 78 ppb) . No new cuts in pollution required.

The EPA says not so fast – "close enough" may not be good enough this time around and you're not following the Clean Air Act in laying back and requiring no new cuts in pollution.

EPA has told Austin a failure to follow Clean Air Act rules will force it to take responsibility for the plan away from the State.

Is this something you want? If so, you should show up and  next Thursday evening to give the EPA the political support it needs to pull the rug out from under the State.


 

WHAT HAS THE EPA ALREADY SAID ABOUT THE STATE'S PLAN?
 
Along with comments from DFW residents, environmental groups, doctors, industry and elected officials, EPA itself will weigh-in with written comments on the TCEQ plan by the deadline of January 29th.
 
But we don't have to wait that long to find out what EPA really thinks about what the State is proposing. Last year, EPA provided 11 pages of comments on exactly the same plan.  

1) This plan won't work without more cuts in pollution

What EPA Said:
"Based on the monitoring data and lack of additional large reductions in NOx within areas of Texas that impact DFW, it is difficult to see how the area would reach attainment in 2018 based solely on federal measures reductions from mobile and non-road….The recent court decision that indicates the attainment year will likely be 2017 for moderate classification areas such as DFW, makes it less clear that the area will attain the standard by 2017 without additional reductions."
 
What EPA Meant:
It wasn't looking good when the deadline for reaching the 75 ppb standard was 2018 and the State didn't require any new cuts in air pollution, but now that the deadline is 2017, your do-nothing "close enough" plan is even less likely to work.  


2) Your case for doing nothing isn't very good

What EPA Said:

"While the State has provided a large chapter on Weight of Evidence, the principal evidence is the recent monitor data. The monitor data does not show the large drops in local ozone levels and therefore raises a fundamental question whether the photochemical modeling is working as an accurate tool for assessing attainment in 2018 for DFW." 

What EPA Meant:
Actual measurements of smog in DFW seem to undercut your claim that the air is getting cleaner faster. Maybe your computer model that's driving the entire plan isn't all that great. (And this was before smog levels went UP after the summer of 2015 – something not predicted by the State's model….)


3) Review pollution limits for the Midlothian cement kilns, or we'll reject your plan

What EPA Said:
"Because of significant changes in the type and number of cement kilns in Ellis County,…TCEQ's rules need to be reevaluated to insure these reductions are maintained, and the emission limits reflect a Reasonably Available Control Technology (RACT) level of control as required by the Clean Air Act…Failure to conduct a thorough RACT analysis for cement kilns which would include appropriate emission limits would prevent us from approving the RACT portion of the attainment plan submittal."

What EPA Meant:  
Update your kiln pollution limits, or this part of the plan is toast. (Texas chose not to perform this update, in essence, giving EPA the bureaucratic finger.)
 
 
4) Oil and Gas pollution seems to be keeping the region's smog levels higher than they should be

What EPA Said:
"Recent NOx trends (Figure 5-10 in TCEQ's Proposal) indicate a fairly flat NOx trend for several NO monitors in the western area of the DFW area (Eagle Mtn. Lake, Denton, and Parker County monitors). These monitors are in areas more impacted by the growth in NOx sources for Oil and Gas Development that seem to be countering the normal reduction in NOx levels seen at other monitors due to fleet turnover reductions (on-road and Nonroad). These higher NOx levels in the modeling domain that seem to be fairly flat with no change since 2009
raise concern that the area is not seeing the NOx reductions needed to bring the ozone levels down at these monitors."
 
What EPA Meant:
Since the historically worst-performing air pollution monitors in DFW are located in exactly the same area as a lot of gas and oil activity, and these monitors haven't been seeing the expected decrease in smog you predict, maybe you ought to think about cutting pollution from those oil and gas sources. Like we said, this plan needs more cuts in pollution.


5) Your own evidence supports cuts in pollution from the East Texas Coal Plants
   
What EPA Said:
"The TCEQ provided an evaluation of emissions from all of the utility electric generators in east and central Texas. However, the discussion in Appendix D on the formation, background levels, and transport of ozone strongly supports the implementation of controls on NOx sources located to the east and southeast of the DFW nonattainment area. How would a reduction in NOx emissions from utility electric generators in just the counties closest to the eastern and southern boundaries of the DFW area impact the DFW area?"

What EPA Meant:
Despite your protests, the State's own analysis shows cuts in pollution from the East Texas Coal Plants have a big impact on DFW smog levels and supports the argument for putting new controls on them. Did you actually run your fancy-dancy computer model to see what would happen if you did that? (No, the State did not. But UNT and Downwinders did.)

WHY WOULD AN EPA PLAN FOR DFW AIR  MAKE ANY DIFFERENCE?

No Biggie – maybe new controls on every large industrial polluter in the region…that's all
 
The EPA has already said DFW needs more cuts in air pollution to make any clean air  plan work. It's opened the door to cuts in pollution from  from the Midlothian cement kilns, oil and gas sources, and the East Texas coal plants.
 

If the EPA rejects the State's plan, the clock begins ticking: the State is warned it has to write a new plan and, meanwhile, EPA begins to write its own. If the State doesn't turn in a plan the EPA finds acceptable in 24 months,  the EPA plan is implemented instead.

An EPA plan brings everyone back to the bargaining table who's interested in cleaner air and all potential cuts – kilns, coal plants, and oil and gas –  are carefully considered.

The State has no interest  in any new cuts of pollution from any sources. It thinks it's plan is  already "close enough."

If the EPA is writing the plan, citizens can use the new UNT study to show the Agency which cuts get the largest drops in smog – using the State's own air model.

We can use Dr.Haley's study to show the approximate economic and public health benefits of those cuts.

More change happens if EPA is writing the plan.Enough to finally get DFW safe and legal air? We don't know until we try. The alternative is doing nothing.

Two very different futures for your lungs are being decided right now.
 
Your voice is needed to help the better one win out.

traffic jam_EQA large new European study released this week found that as much as 14% of chronic children's asthma in the Continent's urban areas could be due to traffic pollution. That would put it on par with the effects of second-hand smoke, linked to anywhere from 4 to 18% of all childhood asthma. 

"Air pollution has previously been seen to trigger symptoms but this is the first time we have estimated the percentage of cases that might not have occurred if Europeans had not been exposed to road traffic pollution," lead author Dr. Laura Perez, at the Swiss Tropical and Public Health Institute, said in a press release. "In light of all the existing epidemiological studies showing that road-traffic contributes to the onset of the disease in children, we must consider these results to improve policy making and urban planning."

Although the idea of getting cars off the road as a benefit of mass transit isn't new, this study and others that have been published recently flesh out a new public health concern about the immediate impacts of such reductions in the neighborhoods adjacent to highways. Often these neighborhoods are already low and moderate income, and/or minority-majority with higher-than-average asthma rates already institutionalized because of lack to access to care, poverty or other factors. Highway plannning has yet to take this kind of localized impact into account, especially in Texas and DFW, where regional highway builders are still salivating to build the Trinity Toll Road straight through the middle of Dallas or criss-cross Ft. Worth neighborhoods with the new "Chisholm Freeway."

Asthma affects one in 12 people, or 8 percent of the U.S. population, according to 2009 data from the Centers for Disease Control and Prevention. The number has increased since 2001, when one in 14 people were affected.

BPA and BabyChildren exposed to routine levels of the chemical bisphenol A (BPA) in the first seven years of life are more likely to have asthma, according to a new Columbia University Medical Center study.

The children studied had roughly the same concentrations of BPA as the average for U.S. kids. “We saw increased risk of asthma at fairly routine, low doses of BPA,” said Dr. Kathleen Donohue, an instructor in clinical medicine at Columbia University Medical Center and lead author of the study.

The study, which tested 568 children and their mothers in New York City, is the first to link early childhood exposure to BPA with asthma. Studies with lab mice, however, have found a similar link.

Children with higher levels of BPA at ages 3, 5 and 7 had increased odds of developing the respiratory disease when they were between 5 and 12.

BPA is used to make polycarbonate plastics and is found in many canned foods and beverages, on paper receipts, and in dental sealants. As a result, more than 90 percent of Americans have traces of BPA in their bodies.

Medical experts for decades have been trying to figure out what has caused asthma rates to skyrocket in children throughout much of the world, beginning in the 1980s. Many suspect that it might have something to do with early-life exposures and changes in immune systems causing inflammation.

If one then adds this injury to increased levels of smog, VOCs, or particulate matter that can set such inflammation off, it's not hard to imagine a conspiracy of chemicals causing a new rise in an old ailment.

One out of every 10 U.S. children has been diagnosed with asthma, and the rate is one out of every six for black children, according to 2011 data from the Centers For Disease Control and Prevention.

Because it’s the first study of its kind, it’s too early to blame BPA for asthma, Harley said. But the chemical is increasingly linked to more and more children’s health problems.

“This is another study showing an association between health outcomes and early life exposure with BPA,” she said. “Several studies look at children’s behavior, development, thyroid hormones, now an association with asthma. There’s really starting to be accumulation of evidence.”

One out of every 10 U.S. children has been diagnosed with asthma, and the rate is even higher for black children – one out of every six, according to 2011 data from the Centers For Disease Control and Prevention. – See more at: http://www.environmentalhealthnews.org/ehs/news/2013/asthma-and-bpa#sthash.zFBBJBLc.dpuf

The study, which tested 568 children and their mothers in New York City, is the first to link early childhood exposure to bisphenol A (BPA) with asthma. Studies with lab mice, however, have found a similar link.

JasonUnbound/flickr
One out of every ten U.S. children has been diagnosed with asthma.

A Columbia University research team reported that children with higher levels of BPA at ages 3, 5 and 7 had increased odds of developing the respiratory disease when they were between 5 and 12.

– See more at: http://www.environmentalhealthnews.org/ehs/news/2013/asthma-and-bpa#sthash.zFBBJBLc.dpuf

The children studied had roughly the same concentrations of BPA as the average for U.S. kids. “We saw increased risk of asthma at fairly routine, low doses of BPA,” said Dr. Kathleen Donohue, an instructor in clinical medicine at Columbia University Medical Center and lead author of the study. – See more at: http://www.environmentalhealthnews.org/ehs/news/2013/asthma-and-bpa#sthash.zFBBJBLc.dpuf
The children studied had roughly the same concentrations of BPA as the average for U.S. kids. “We saw increased risk of asthma at fairly routine, low doses of BPA,” said Dr. Kathleen Donohue, an instructor in clinical medicine at Columbia University Medical Center and lead author of the study. – See more at: http://www.environmentalhealthnews.org/ehs/news/2013/asthma-and-bpa#sthash.zFBBJBLc.dpuf

A new analysis of the historic 2009 Cook Children's Hospital survey of regional childhood health confirms that higher levels of Tarrant County childhood asthma track closely with the downwind pollution plume coming from the three Midlothian cement plants in adjacent Ellis County.

According to researchers Patricia Newcomb and Alaina Cyr from the UTA College of Nursing "…the bulk of Tarrant County asthma cases lie directly in the path of southeasterly winds that have historically carried high levels of particulate matter from working cement kilns in a neighboring county. Asthma prevalence increases in a linear configuration within the path of the 'cement plume' as residential location comes closer to the cement kiln area."

Exposure to Particulate Matter pollution, or soot, is a well-known known cause for asthma. It can also make a child's asthma worse.

"This latest study is one more piece of empirical evidence that we need to decrease pollution from the Midlothian cement plants to secure the right of our children to breathe without getting sick, " said Jim Schermbeck, Director of Downwinders at Risk, a local group originally founded in 1994 to oppose the burning of hazardous waste in the Midlothian cement plants.

Proximity to the pollution from the three Midlothian cement plants was the only environmental factor geographically associated with higher concentrations of childhood asthma, ruling out poverty and indoor air pollution. There also wasn't a strong correlation to urban gas drilling, although the authors concede that "urban drilling may play a part as well" in the region's higher than normal child asthma rates, and there was no direct comparison between the geography of drilling activity and area asthma levels.

In 2009, Cook Children's Hospital released its Community-wide Children's Health Assessment and Planning Survey (CCHAPS), the largest examination of childhood health in North Texas ever undertaken. It found that Tarrant County and the western side of the North Texas region suffer childhood asthma rates significantly higher than state and national averages.  

In "Conditions Associated with Childhood Asthma in North Texas," published in the October edition of ISRN Allergy, Newcomb and Cyr revisit the Cook study and delve more deeply into its data. "The purpose of this study was to identify significant associations between asthma diagnosis, comorbid conditions, and social problems in children." The complete article can be accessed on the Cook Hospital CCHAPS website page devoted to asthma, under "Special Reports."

Midlothian is the home of the largest concentration of cement plant manufacturing capacity in the United States. It hosts three large cement plants – TXI , Holcim and Ash Grove –  with a total of six kilns. They are the largest stationary sources of pollution in North Texas. Reports submitted by the plants themselves show they poured over a million pounds of Particulate Matter pollution into the North Texas air in 2009.

EPA recently announced that it was considering once again delaying the implementation of new federal emission rules, including stricter particulate matter pollution standards, from 2013 to 2015 that have been in the works for two decades. The delay would also water down proposed PM pollution standards. Schermbeck said Newcomb and Cyr's analysis shows the real world costs of such a rollback.

"It's a scientific fact, endorsed by EPA, that inhaling tiny bits of particulate matter can make people sick and even kill them. What this study makes clear is that the agency is senselessly condemning more Tarrant County kids to illness and suffering by delaying rules that were supposed to have been in place in the 1990's. It's time to start saving lives by reducing this kind of pollution."

Last week it was fish oil that protected your lungs against the harm from breathing-in particulate matter, or soot, pollution. This week, it's Vitamin C that "may lessen the harmful effects of air pollution for people suffering from chronic lung diseases."

"Researchers looked at London hospital patients with asthma or chronic obstructive pulmonary disease (COPD), and found that those with low levels of vitamin C had an increased risk of breathing problems on days when outdoor air pollution levels were high.

"This study adds to a small but growing body of evidence that the effects of air pollution might be modified by antioxidants," said Michael Brauer, an environmental health scientist at the University of British Columbia in Canada."