The U.S. Environmental Protection Agency began public hearings this week in North Carolina to consider whether to lower the national health standard on ground-level ozone. Formed on hot sunny days by emissions of volatile organic compounds and nitrogen oxide emissions– primarily resulting from the burning of fossil fuels in power plants, cars and industry – ground-level ozone directly impacts lung function and can lead to asthma, bronchitis, early death and a host of other health-related illnesses. Particularly at risk are the very young, the very old and those with preexisting health conditions.
Not surprisingly, filed public comments showed strong support among environmental and health advocates like Sierra Club and the American Lung Association for lowering the standard, while utilities, coal companies, the Texas Public Policy Foundation – an industry-funded conservative think tank – and even the Texas Commission on Environmental Quality said the science does not support lowering the ozone standard. A full copy of the Lone Star Chapter’s comments can be found here.
At issue is whether or not the EPA should lower the level of pollution in the ambient air at which an area would be considered to be in violation of the national air quality standard. The current standard of 75 parts per billion – measured as an average over eight hours — was developed in 2008 under former President Bush, while the new proposed standard would range between 60 and 70 parts per billion and has been under discussion in the public, in the White House, in Congress and in court ever since.
The Sierra Club filed extensive comments supporting lowering the standard to 60 PPB based on hundreds of peer-reviewed health studies showing children and others do exhibit reduced lung function and real health effects at a level of 60.
If a standard of 60 were adopted, it is likely that all major urban areas in Texas – based on the last three years of ozone data – would fail to meet the standard, including Houston and Dallas – which are currently out of compliance with the standard – along with Austin, San Antonio, Laredo, Corpus Christi, Tyler-Longview, Waco, Beaumont-Port Arthur and El Paso. Even cities in the Lower Rio Grande Valley – generally far removed from large industrial sources – might violate such a standard.
Though a new, lower standard would be challenging for most of the state to meet, no Texas citizen should have to breath outdoor air that is unsafe. Fortunately, there are solutions. Within our cities, generally the largest amount of pollution that leads to high levels of ground-level ozone comes from vehicles. Texas can and should continue to clean up our cars and trucks by not only making sure we meet the federal standards for new vehicles but also by fully allocating the money from the Texas Emissions Reduction Plan, which provides grants to clean up older mobile vehicles. There will be nearly $1 billion of TERP funds that could be allocated to clean up our mobile sources of pollution when the Legislature meets again in 2015.
We also must take strong action against major point sources of pollution. According to the TCEQ’s 2012 Point Source Emissions Inventory, about one-third of all nitrogen oxide emissions from industrial sources in Texas come from coal-fired power plants. Nonetheless, out of the 32 boilers in Texas that burn coal that are not scheduled for retirement, 24 lack basic control technology known as Selective catalytic reduction (SCR), a type of scrubber which removes much of the nitrogen oxide pollution. These coal plants without modern pollution control belched more than 78,000 tons of nitrogen oxide into our airways, leading to higher ozone levels throughout Texas. We would note that a special case are the coal plants owned by Luminant, which are large and located primarily in areas that influence ozone formation in Dallas and Waco. In 2007, they were purchased by a holding company known as EFH, which made a commitment to add SCR on many of their units, including Martin Lake, but have thus far failed to do so. Collectively, the Martin Lake units contributed more than 11,500 tons of nitrogen oxide in 2012, the highest single source in the state. Requiring that all such units install modern pollution control on their stacks – or retire – could significantly reduce these emissions.
We must also implement new regulations to clean up emissions from oil and gas fracking activities. The Railroad Commission of Texas is permitting some 20,000 oil and gas wells every year, the majority of which are being fracked. The well completions, flaring and venting of gas, plus their operation, processing, transportation and storage of the oil and gas and related materials is literally leaking thousands of tons of nitrogen oxide and volatile organic compounds into the atmosphere, leading to the creation of more ozone over our city centers. This problem is particularly pronounced in San Antonio and Dallas-Fort Worth due to the fracking boom. Yet our air quality regulations are outdated to deal with this new source of pollution. Finally, while many of our cement plants have updated their control equipment, about half have not, and they are major contributors to ozone formation throughout Central Texas, contributing about 16,000 tons of NOx per year.
Other solutions include making future buildings more efficient, growing renewable energy and energy efficient appliances and retrofitting existing buildings. These solutions have not been fully explored in Texas.
Yes meeting a new ozone standard would be challenging, but if our leaders at the White House, in Congress, at the Pink Dome and at our own agency – the TCEQ – will actually work on solutions rather than delay implementing a lower standard– we can reduce ozone levels, improve health, save lives and create jobs.