In a sparsely attended public hearing this week, Sierra Club’s Brandt Mannchen told the TCEQ that their proposed Emissions Inventory for the eight-hour ozone State Implementation Plan was grossly inadequate — particularly on “area” sources like oil and gas drilling and dry cleaners and emissions from the ports — and that it was impossible for the public to recreate the numbers. The TCEQ is required to submit a 2011 Emissions Inventory as part of the State Implementation Plan for the Eight-Hour Ozone standard of 75 parts per million. Both the Houston-Galveston-Brazoria area and the Dallas-Fort Worth area are considered “non-attainment” for ozone because they consistently violate those standards. Other cities like Austin, San Antonio, Corpus Christi and Tyler-Longview-Marshall have also violated the standard on occasion though not enough to be considered non-attainment.
The 2011 EI is important because it establishes the baseline by which TCEQ must show how it will reduce emissions of the pollutants — nitrogen oxides and volatile organic compounds – that create ground-level ozone pollution. In addition to the EI itself, the state must list regulations which will help limit emissions and if necessary develop additional regulatory and voluntary controls to show the state will meet the health-based standards. Getting the EI right – as Brandt mentioned in his comments – is essential. The Lone Star Chapter is working with our local Houston Regional Group and Dallas and Fort Worth regional groups to submit comments on the EI by the January 27th deadline.
Despite the stakes, Mannchen was only joined only by two other Sierra Club members and a smattering of others — none of whom spoke. Among other issues raised by Mannchen was the failure of the EI to even consider the impact of emissions from outside the non-attainment areas — including large coal-fired power plants and the thousands of oil and gas facilities in the Eagle Ford, and Haynes areas which can impact ozone formation; the use of old 2009 data to generate numbers for a 2011 Emissions Inventory; and poor calculation of emissions from maritime vessels in the Houston Port.
Tomorrow, those in the Dallas-Fort Worth area get their chance to speak, January 16th.
Meeting is in Arlington on Thursday, January 16th at 2 PM at the Arlington City Hall Building in the Council Chambers (101 w. Abrams Street). For information about the proposed EI and related documents, check out this TCEQ Hot Topics page.
Even as TCEQ develops this EI and the SIP, the EPA is actively considering lowering the ozone standard to between 65 and 74 from the current 75 parts per billion. This could have a profound effect in Texas, forcing communities from Laredo to San Antonio to Tyler to develop more robust controls.