This plan won't work.
That's the simple message from the three pages of new comments Region 6 EPA staff submitted to the Texas Commission on Environmental Quality last month concerning its anti-smog plan for DFW.
That message begins with the cover letter, written by Mary Stanton, Chief of the State Implementation Plan Section for Region 6. "… additional local and regional ozone precursor emission reductions will be necessary to reach attainment by 2017."
How much in reductions? EPA estimates an additional 100-200 tons per day more in cuts of smog-forming pollution will be necessary to achieve compliance with the current 75 parts per billion ozone standard. "Without emission reductions on this scale, it is unlikely that the area will attain by the attainment date.”
To give you some idea of how large a number that is, TCEQ calculates that all gas and oil air pollution in DFW equals 78 tons per day, the Midlothian cement plants belch out over 18 tons per day, and all the power plants in the immediate DFW area, 21 tons per day. Totaled, those three sources add up to 117 tons of pollution a year.
All the cars and trucks on DFW roads are said to add up to 180 tons per day of pollution.
So the decrease in pollution EPA is saying is necessary to get down to the current ozone standard is huge.
But take a look at those obsolete East Texas coal plants outside the boundaries the DFW nonattainment area. TCEQ says they account for a total of 146 tons per day. Add Selective Catalytic Reduction (SCR) which can get you up to 90% reductions in coal plant emissions, or close them down completely, add decreases from new controls on the cement kilns and oil and gas sources, and you're well on your way to amassing 200 tons a day of cuts in pollution.
Which do you think is more attractive to most DFW residents: permanently parking their cars, or putting new controls on the coal plants? Even though the coal plants harm the whole DFW airshed more than any other major source, they're not held accountable to the same regulatory requirements as sources closer to the center of the urban core, but which have less impact. Our cars must have special gasoline formulas in summer, we have to have HOV lanes, and we still go through Ozone Action Days, but the coal plants party like it's 1979. TCEQ is taking a hands-off approach to the plants and as a result the DFW region will continue to be in violation of the smog standard or huge cuts from other sources will be necessary.
TCEQ could have added new controls to the coal plants to the plan, but it chose not to. In fact, there are no new controls in the state's plan on any major sources of air pollution affecting DFW. EPA's new comments go to the heart of that choice. "Without additional emission reduction measures, we don’t see how the area will meet the standard of 75 ppb by the end of the 2017 ozone season," writes EPA staff.
EPA goes on to say TCEQ's computer modeling supporting it's do-nothing plan is "unrealistic," severely underestimating future smog levels, and delivering projections of decreases "that seem unlikely to be reached."
With this stance, EPA seems poised to reject this "attainment demonstration" part of the air plan as being insufficient. But it must wait to see how TCEQ responds to EPA comments about its modeling shortcomings and need for new cuts when the state officially submits its plan this July. Then, and ony then can the Agency approve or disapprove. We're going out on a limb here and predicting TCEQ won't change a thing, thus inviting EPA disapproval.
That's the pattern TCEQ has already established with its "screw you" response to the EPA's comments about the part of the plan dealing with "Reasonably Available Control Technology," or RACT, last February. This second part decides what new controls should be required of major sources of air pollution within the 10-County DFW "non-attainment" area – like the Midlothian cement plants and the thousands of oil and gas facilities checkerboarding the western half of the Metromess.
TCEQ says nothing new is required. EPA disagrees. EPA told TCEQ last year it had to do a new RACT review and lower the kiln's emission limits to account for a new generation of technology or it would have to reject the state's plan. TCEQ ignored the request, daring the EPA to disapprove. EPA seems more than willing to take them up on the offer.
And so while you're waiting for the state's computer modeling and suspect math to be rejected by EPA in July, you can probably expect to see EPA officially rejecting the RACT part of the state's plan sooner – maybe as soon as the next 60-90 days.
Despite the TCEQ going out of its way to submit an unacceptable plan to EPA, if the Agency pulls the trigger and begins a federal takeover of the DFW air plan, the Commission and the whole of Texas State Government will cry bloody murder about the usurpation of the state's authority and once again proclaim how "out of control" the EPA is on their way to filing suit.
This is why the rowdy eruption of public sentiment for an EPA plan at the hearing in Arlington two weeks ago was so critical (Thank you again). It's also why we now have to be about the business of getting DFW local governments, hospitals and school districts to pass resolutions in favor of an EPA takeover. The Agency will need this kind of public support to counter all the criticism it will take from the Usual Suspects in Austin and DC. If you're interested in helping us pass one of these resolutions in your county, city, school or hospital district, please let us know at: email@example.com
And as always, it's why you, and people you know should: