Wednesday, January 27, 2010

My Speech to AACOG in San Antonio 1-27-10

AACOG Ozone Speech 1-27-10

Good Morning

My name is Mark Langford, citizen of San Antonio, owner of a small business for 26 years, editor of OzoneInformation.Com and MyWeatherPage.Com, but most importantly today, a person who has suffered from asthma for over 50 years.

I want to first of all apologize to this group and our audience. According to the EPA, I will be filling this room with copious quantities of CO2 as I deliver this speech for the next several minutes. As most of you may know, the EPA has now declared that CO2 is a pollutant and will now be regulating that gas in the future.

Speaking of regulation, if the EPA is successful in lowering the 8 hour ozone average down to 60-70 ppb. they will also be regulating almost every small, medium and large cities throughout the country. If this new standard is adopted, AACOG might as well shut down this division of operations, because all of this work will be futile and a total waste of taxpayer dollars.


As Peter Bella and Steven Smeltzer can show you, there is absolutely nothing San Antonio can do to achieve this new standard when our winds blow from the East or NE and transported pollution from natural and unnatural sources stream into our area. Ask Peter to show you the high ozone days that have occurred on Sundays through the past 15 years. On Sundays, there are 57% less vehicles on the road and most manufacturing and non retail businesses are closed. This demonstrates that even if we got our 57 percent of our residents to not drive to work, we would still not be able to stay within the new ozone averages.

Ask Peter Bella to show you the ozone recordings for Seguin. Seguin has a population of around 25,000 and is almost an hour east of San Antonio, yet they will not be able to stay within attainment if this new standard is adopted. And of course, neither will any suburban areas near San Antonio, including New Braunfels, Fair Oaks, San Marcos…the list goes on.

And San Antonio is not alone. If this committee will go to “Google Alerts” and create an alert for ground level ozone, you will be stunned on the volume of stories being published throughout our country right now on cities that are questioning how they will keep from going into non-attainment.

So. why is the EPA considering this new standard? Good question. As usual, they maintain they are doing this to “Save the Children and asthmatics” like me. Unfortunately, I believe the Federal Government has come up with a novel way to control and regulate almost the entire country without having to pass any “cap and trade” legislation.

And “Saving the Children and Asthmatics’? According to a 2002 report from the CDC, the highest asthma rates in Texas are found in Midland-Odessa with a 28% rate, yet as far as I know, they have no ozone problems in that area. In fact, I don’t even think they have an ozone monitor. On the other hand, one of the lowest asthma rates in Texas is Houston, the ozone capital of Texas, with a less than 10% rate of asthma. As you look at the national numbers, you will see no correlation between asthma rates and ozone. There are just as many small towns with high rates of asthma as there are large cities with high ozone.

As Forrest Mims has asked the Air Executive committee on numerous occasions, we need a local study done on respiratory hospitalizations during high ozone events, as compared with any other summer day. We need to also look at respiratory hospitalizations compared with winter. I am not alone with experiencing my worst asthma during pollen filled dry, cold air days during the winter and spring months. In fact, unfortunately I have been using my Albutural way too often over the past several weeks, during the worst of this cedar season and the very cold weather we have experienced.

So, what are we to do about this? Will we simply sit idly by and let the Federal Government regulate our future growth or will we do as the environmental groups have so successfully done in the past and sue the EPA to make changes. The only way for change is to quickly join a class action lawsuit with hundreds of cities and states and fight this unfair takeover by the Federal Government. There are many holes in the research, including studies done on asthmatics without considering pollen counts, using ozone counts of 250 ppb. on test subjects, not including the CDC report on asthma rates, unfair treatment of cities located in the south, who climatically have more 90 degree plus days than northern cities and a total lack of consideration for biogenic sources of volatile organic compounds, such as trees and kudzu plants. Most importantly, it will be a standard that cannot be achieved. That alone should be proven unconstitutional. Since when can any government create a law that cannot be obeyed?

Thursday, January 21, 2010

Asian Pollution Transport

This is one of my biggest problems with measuring ozone...cities being penalized for high ozone when it's the transported pollution that causes the rise in recorded ozone, not local sources.

Friday, January 8, 2010

WOAI Text of My Interview

Thanks to WOAI for doing a very fair interview with me yesterday on the newly proposed EPA ozone standards.

Thursday, January 7, 2010

Perry May Sue Over New Ozone Rules

I'm not a big fan of Governor Perry, but this is what will need to happen to keep the EPA from lowering the ozone standard.

Joel Schwartz shoots many holes in the science behind lowering the ozone standard even more.

This is a great article from 2007 from Joel Schwartz. It is full of great arguments against lowering the ozone standard

Here we go!

Well, as expected, the EPA wants to lower the 8hr average standard to between 60-70 ppb. They might as well drop it on down to 40 ppb so that even Alaska will be out of attainment!

This is beyond comment...but I will.

Here is my response to the last reduction in 2008...basically you can take the same comments and adjust them to address the even more ridiculous reductions being proposed now!


An Ozone Update
In an incredible move that defies both logic and understanding of our nation's ozone problem,
the EPA announced today that it is reducing the national 8hr ozone average to 75 ppb., effectively
adding hundreds of small and large cities to their "non attainment list". Despite costs that could total
in the billions of dollars and harm an already stressed manufacturing economy and positive health
results that are very difficult to prove, the EPA agreed to lower the 8hr average standard.
Below are questions that should be asked by everyone to the EPA:
1. How are small, rural areas supposed to lower their 8hr average ozone readings when they are not
contributing any pollution or only trace amounts? How many hundreds of new cities will now fall into
"non attainment"?
2. Why is their no allowance or handicap for urban areas located in the southern parts of our country?
A city like Houston, Texas, which averages over 96 days above 90 degrees, is more likely to have more
high ozone days than Seattle, Washington which averages only 3 days. Also, southern states have
higher UV values. Since UV is part of the formation of ozone, higher levels of UV give southern areas a
better chance of having high ozone days.
3. Exactly how many lives will be saved at what price? Can this be proven? Where is the increase in
hospitalizations data? In Texas, we have not seen data that supports this claim. TCEQ's chairwoman,
Kathleen Hartnett White, also understands the problem with the EPA wanting to lower the standard. In a
letter to the EPA, she argues that such a move would prove too costly and unlikely to improve health in Texas.
She mentions that studies found "no increase in hospital admissions in elderly patients and health effects in
children, respectively, due to ozone."
4. How much of high ozone readings can be attributed to natural causes beyond our control? There is much
documented evidence showing that many variety of trees, including oaks, produce isoprenes, which cause ozone.
In the southeast, there is an imported plant called the kudzu, which is taking over many areas, and releases
high levels of volatile organic compounds, which lead to high ozone.
5. What percentage of our ozone forming pollution comes from industrial plants in China or agricultural burns in
Mexico and what exactly does the EPA expect us to do about it? New data suggests that an ever increasing
percentage of our ozone readings are being impacted from transported pollution from China.
6. How do larger cities, like San Antonio, that produce very little pollution, lower our average to the new standard,
when we generally contribute less than 15% to high ozone days? How do we keep the outside pollution from
reaching us?
7. How does the EPA expect the Gulf of Mexico to lower its ozone levels, when those levels are often
higher than populated areas inland during the summer. No one has explained how that can be accomplished.
8. How does the EPA expect national parks like Joshua Tree National Park, to lower their levels, when only a
handful of people live their?
9. Who will pay for this?
10. Why do none of the health studies (that I have seen), mention pollen counts during the outdoor investigations?
The studies do mention that ozone can increase symptoms to allergens, but do not include pollen counts on any
of the outdoor studies of asthmatics.
11. How many people actually exercise in hot areas of our country when the ozone levels are high? Your are much
more likely to die from heat exhaustion than ozone exposure during the time of day when ozone levels are highest.
12. Where is the link to high ozone and asthma? According to CDC data, there is a higher percentage of asthmatics
in Midland, Texas, where there is very low ozone, compared with Houston.
13. Will the EPA reveal that "vehicle emissions testing" only reduces ozone levels by less than .05 ppb. in cities
as large as San Antonio, TX, with populations of over a million? Will they continue to force people to pay for these
costly annual tests, even though they are essentially non effective, since ozone is not measured in .05 ppb.?
Locally, reducing the standard will throw not only Austin and San Antonio into "non attainment", but Seguin,
La Grange, Fair Oaks, Garden Ridge, New Braunfels, Calaveras Lake, Bulverde, Temple, Round Rock, Corpus Christi,
Victoria and Hallettsville could also go into "non attainment", depending on whether the EPA accepts their ozone
monitoring data.
Here are some sites for ozone information:

Mark Langford

Still waiting for the EPA....

As of 9am, still nothing from the EPA

Wednesday, January 6, 2010

Still waiting for the EPA....

The EPA was supposed to announce their decision on whether or not to lower the 8hr ozone average again this afternoon. So far, no decision as of yet. The fact that they are even considering lowering it even more is insane!

Sunday, January 3, 2010

Joshua Tree National Park High Ozone


It had to be Houston, Los Angeles, Phoenix or Dallas. With metro populations in the millions and motorists commuting to work on traffic clogged roads in their ozone producing vehicles, the first area to have four days above 75ppb. for an 8 hour ozone average just had to be one of these cities. Instead, it turned out to be barren, sparsely humanly populated, Joshua Tree National Park.

As of yesterday, April 22nd, Joshua Tree National Park recorded its fourth day of over 75 ppb. for an 8 hour ozone average. As recorded on their monitored ozone site, the park exceeded the new standard on April 18th, 20th, 21st and 22nd. Looking at their remote CAM site, you can see how the region looks as though it would be a great training area for NASA astronauts.

According to the park's website, Joshua Tree National Park encompasses almost 800,000 acres of land and is located at the crossroads of two deserts, the Colorado and the Mojave. Named for the Joshua trees that are found in the region, the park was originally named a national monument in 1936 and became a National Park in 1994. Home to thousands of animals and plants, the park is also the home of high ozone during the summer months, due in part, to being located about 150 miles east of Los Angeles, where pollution is often transported into the area.

The following paragraph from their website describes the problem:

"Although the Environmental Protection Agency (EPA) has mandated that the skies above our national parks be subject to the most stringent level of protection, Joshua Tree National Park consistently exceeds the 120 ppb. ozone concentration levels set by the EPA for human health at it's monitoring station located in the northwestern part of the park. An additional monitoring station was recently installed at Cottonwood Spring to determine if the southern part of the park is also out of compliance with air-quality standards."

Joshua Tree National Park is a perfect example of why the new EPA ozone standard of 75 ppb. is not only unfair, but borders on the ridiculous. Will the EPA be meeting with park officials to draft an "emissions reduction" program? Will an emissions testing station be built to test the few vehicles owned by the park? Will the park lose federal funds because they can't clean up their air? If our national parks, with very few human footprints can't stay within the new standard, then how do we expect cities throughout our nation, who are trying to reduce their emissions, to stay within the new standard?

Ozone Update from 7-09

Just in case some of you read the Express-News front page article on Sunday, July 12th, here is my response:

1. The facts were well presented, but as usual, there were no additional perspectives on the subject matter, just one primary source...the Alamo Area Council of Governments.

2. Nowhere in the article did it talk about the fact that in the past 6 years, Seguin, with a population of 25,000, would have exceeded the new 75 ppb. eight hour standard 3 out of 6 years.

3. Nowhere in the article did it mention that Austin, which has vehicle emissions testing, has already exceeded the 4th highest ozone standard for 2009.

4. The Express-News article also did not question why the highest asthma rates in Texas are found in Midland-Odessa and some of the lowest rates are found in Houston, where ozone levels are often the highest in the country.

5. The article did not address the fact that 2 of our highest ozone days in San Antonio have been on weekends, when vehicular traffic is 40-60% lower than on weekends.

6. The reporter never asked AACOG why our ozone levels can be 33 ppb. on some days when our air temperature is over 100 degrees and there are almost no clouds in the sky, and fairly light winds and 90 ppb. on other days? Could NE winds make a difference?

7. The article also never mentioned that 64% of our locally measured VOC's are biogenic...produced my nature.

8. Lastly, I would have liked the reporter to have asked our local government officials why they are going to sit back and allow San Antonio to go into non attainment without a legal battle? Our city stands to lose millions in potential government funding and could lose future business opportunities because of the "non attainment" status that will occur sooner, rather than later. The EPA has lowered the ozone standard to a level that is completely unobtainable and should be pursued legally, just like the environmental groups did to reduce the ozone standard to this level. There are several directions that can be challenged on the new standard...the most important one is asking where the evidence is that slightly elevated levels are harming San Antonio citizens? Surely it is not in any CDC findings. How much would it cost to do a thorough investigation into the matter? Surely, it would be less than sitting back and embracing a "non attainment" status!

Ozone Update from 11-09

An Ozone Update from www.OzoneInformation.Com 11-02-09


I've been hearing a lot of "buzz" on the radio today on why San Antonio "dodged" high ozone this summer.

First of all, I'm happy we did.

I've heard and read that the "Air Quality Health Alerts" were behind our success. While they might have helped, there is no record of them keeping us from going over 75 ppb. in the past and it is very hard to measure their impact. More often than not, they are issued when conditions either don't pan out or are not issued when ozone is already elevated.

While they might have helped, I have not heard anything mentioned about the fact that we had no low pressures (tropical storms or hurricanes) in the Gulf this summer, very few NE wind days, a slumping national economy and one of the coolest summers ever recorded in the northern parts of the country. These are more than likely the more important reasons that we stayed under 75 ppb. this year. While you did mention to the SA Business Journal that our local economy might have lead more people to driving less, there was no mention of distant coal fire plants and manufacturing plants in the NE polluting less, due to the economy. There was also less pollution from China this summer.

Even more interesting, is that this summer was the warmest and one of the driest ever recorded for San Antonio. Our electrical usage set many records and clear skies allowed an abundance of UV radiation (important in ozone formation) to rain down on us. Despite this, we stayed under 75 ppb. because our winds rarely blew from the East and NE. When we finally did get some early cool fronts, they came with clouds and moisture, protecting us from a high ozone event.

I really wish AACOG would do a better job in communicating these events with the media. While I realize it's human nature to want to give yourselves credit for positive ozone news, you still need to discuss other possibilities, in my opinion.

Mark Langford

Story from SA Biz Journal:

Welcome to Ozone Information Blog

Welcome to my Ozone Information Blog.

We may be learning on January 6th, whether the EPA will lower the 8-hour Ozone Average to 70 ppb. By doing so, almost every small, medium and large city in the southern part of our country will fall into non-attainment. This will subject most of the country to being controlled by the EPA whenever any city wants to build new roads or add new industries.

Meanwhile, there will be little a city can do to lower their ozone averages, since background ozone levels are often higher than 70 ppb. due to transportation of pollution and natural sources, such as trees and plant emissions of volatile organic compounds.

Please visit my website for more information: