What makes this year's violation particularly troublesome is that the 1997 standard has been replaced with a more protective one that's 10 ppb lower. So for the next DFW air plan to succeed, it will have to reduce smog to levels no DFW monitors have ever recorded.
That new plan has its official kick-off event next Tuesday, November 5th, beginning at 9am in Arlington at the Council of Governments Headquarters.
It's the first briefing from the state on the computer model it will be using to base the plan on. Everything about one of these plans is based on such a computer model,
a model only the state can run. For now. The plan must be submitted to EPA by June of 2015.Downwinders will have representatives at this meeting, as well as every other one that takes place between now and June 2015
. Director Jim Schermbeck is one of three representatives from environmental groups that sits on the North Texas Clean Air Advisory Committee that gets briefed by state staff on a plan's progress. It's the only opportunity citizens groups have to cross-examine the state's staff about its assumptions.
Even though extremely high ozone numbers were rarer this year, there were enough bad air days to cause the running averages of 10 out of 17 monitors, called "design values" to rise
- not the kind of trend you want when you're next task is complying with a tougher standard.
One of those increases is worrisome because it marks the third year in a row the central city monitor in Dallas near the corner of Mockingbird and I-35 (Hinton Street) has increased its annual average.
This is a monitor that had a "design value" of 67 parts per billion in 2010 -
that is, it was in compliance with the new 75 ppb standard just three years ago. But now this monitor is up to 84 ppb and almost out of compliance with the 1997 standard.
That's quite a swing in three years - again in the wrong direction.Every monitor inside the DFW metro area and even most "rural" monitors had a design value above the new standard of 75 ppb.
Only Kaufman and Greenville made it under the wire, barely, with readings of 74 ppb. As usual, the worst ozone levels were found in the northwest quadrant of the DFW area.
This is a well-known historical pattern caused by the predominant southeast to northwest winds that blow pollution from the coast up through the coal and gas patches of East and Central Texas, over the Midlothian Industrial Complex and North Texas central urban cores into Northwest Tarrant Wise and Denton counties.
This pattern has been the target of the last three state clean air plans, but somehow it never gets fixed the way Austin predicts it will.
If you look at the readings of DFW's air monitors since 1997, (as you can with our downloadable pdf)
, you'll see that the last clean air plan to make a dent was the 2006 effort that looked like it was going to succeed for a year or two. Since 2008 however, air quality that was supposed to be getting better has gotten worse, or stagnated.
While cars have gotten cleaner during this time, and pollution from cement and coal plants has been reduced, there's one "source category" of pollution that's increased significantly since 2008: the gas industry.
In submitting the last DFW air plan to EPA in 2011, the Texas Commission on Environmental Quality estimated there were more tons of smog-forming Volatile Organic Compounds being released by the gas industry in the official DFW "non-attainment area" than by all the cars and trucks on the road combined.
That wasn't true in 2008.
Moreover, this is new air pollution in a smog non-attainment area that doesn't have to be off-set by reductions in pollution elsewhere in DFW. Unlike every other large industry, the gas industry is exempt from this offset requirement of the Clean Air Act.
You always hear about what kind of DFW smog problems all those nasty cars cause. You never hear about the smog problem caused by the gas industry.
Could DFW's continuing inability to comply with the old 1997 ozone standard be due to this new under-regulated source of air pollution?
Denton's Airport monitor's 4th highest reading of 85 ppb
this summer, the one that officially counts toward its running average, was the highest such reading in the entire state, including Houston.
There's no doubt Denton is in the middle of the local gas patch,
as are the Keller and Grapevine monitors that had the highest design values this year. Given the decreases in pollution from other categories, are gas patch emissions keeping these numbers from coming down they way they were supposed to? Austin keeps saying no, but the evidence is compelling.
Just last year there was a study out of Houston
showing how a single flare or compressor station could significantly impact local ozone levels by as much as 5 or 10 ppbs.
TCEQ itself just produced a study this last summer showing how Eagle Ford Shale gas pollution is increasing ozone levels in San Antonio.
Other studies show how gas patches are producing record levels of ozone in Colorado, Wyoming, and Utah where there were no such problems prior to the industry's arrival on the scene.
Local Barnett Shale gas pollution might explain these Tarrant and Denton county monitors' problems, but they don't explain the rise in numbers of the Dallas monitors, since the wind during ozone season comes in from the south to southeast.
What new pollution is coming from that direction? Gas industry pollution from numerous compressor stations and processing plants stations in Freestone, Anderson, Limestone and other counties just about 90 to 100 miles south-southeast of Dallas.If one adds up all the emissions these facilities are allowed under their "standard permits." it exceeds the pollution from coal plants like Big Brown.
That's a huge hit from sources that weren't there 10 years ago.
In effect, DFW is getting squeezed
between gas pollution being produced in the middle of its urban areas, and gas pollution blowing in from the south. We're in the middle of a big, gas-produced ozone sandwich. Officials with Rick Perry's TCEQ would rather drink lye than admit gas pollution is causing smog problems for DFW.
But such an admission might be the only way you ever start to bring DFW into compliance with the Clean Air Act. This is why local DFW municipal and county governments serious about air quality must divorce themselves from Austin's politicized science and begin to seek their own solutions.
Austin really isn't interested in solving DFWs chronic smog problems. Heck, the Commissioners who run TCEQ don't even believe smog IS a health problem
. Forecasters are saying drought conditions are the new normal for North Texas.
If that's true, this last summer seems like an exception to the rule. And if we couldn't catch a break when it's cooler and wetter than it should be, it's hard to imagine making much progress when we're facing more summers like 2011.
Downwinders will have a summary of next week's modeling meeting in its "Fighting for Air" blog. Stay tuned.