Friday, March 19, 2010

What I wrote to the EPA today

The EPA is taking comments on the potential revision to the 8hr Ozone Average Standard until Monday, the 22nd of March. You can share your comments. Below are my comments:

To whom it may concern:

My name is Mark Langford and I am a 52 year old lifelong asthmatic, living in San Antonio, TX

I am also the editor of

We all want cleaner air to save the lives of children, elderly and asthmatics (like myself), but this reduction is beyond what we, or most cities that will now fall into non-attainment can control through emissions reductions. The EPA is essentially asking cities to control something that is beyond our control, due to "background or transported" pollution. How can the government ask a city or a citizen to do something that can't be accomplishing?

Here are a few points on why the current 8hr Ozone Average should not be reduced to even lower levels:

1. As revealed by an internal study done by San Antonio's Alamo Area Council of Governments (AACOG) in 2003, emissions testing will only lower our ozone average by no more than 1/2 of 1 part per billion of ozone. This small amount cannot even be measured by our current monitors. According to the EPA, our current fleet of vehicles is polluting 1/50th of what they were back in the 70s. Placing the blame on vehicles is "Old School" thinking. That's why cities like Houston and Dallas that have tried to correct their ozone problems by going after vehicles, have not been able to solve their ozone situation. The only thing they have accomplished is burdening their taxpayers with additional fees and fines.

2. San Antonio studies show that on most high ozone days, the four county San Antonio area usually contributes less than 10 ppb. during high ozone events and rarely contributes over 15 ppb.. On high ozone days with 8 hr. averages above 90 ppb., even if our entire 4 county area were to completely shut down, we would not be able to keep our ozone levels under the new 75 ppb. standard. This is evident in looking at monitors in our rural counties, like Seguin, TX. Under the new standard, Seguin will also go into non-attainment during most years, even though only 25,000 people live there.

3. As far as I know, there have not been any detailed studies on how big of an impact natural ozone sources play in "background" ozone levels. Depending on how wooded cities are, oak trees and other vegetation like kudzu, may be a much higher percentage of biological sources than we realize. A good way to prove this theory is to examine ozone monitors in National Parks. Joshua National Park, in the deserts of California, is a great example of an isolated area having high ozone during the summer. What if even half of the ozone we record is from natural sources? Without studies, we may never know if high ozone levels can even be dropped at all.

4. Cities in the lower latitudes are unfairly penalized with this new standard. Since ozone production is impacted by heat, clear skies and UV, cities that are in the southern half of the country are naturally going to have more days during a typical year that could be high ozone days. Cities like Houston average 96 days a year over 90 degrees and Seattle only averages 3 days...yet both are under the same standard.

5. The EPA claims that more people are dying and being hospitalized during high ozone events. Where is the evidence in San Antonio? The EPA needs to pay for a local study and see if this is actually occurring in our area. As an asthmatic, I suffer my worst symptoms during high pollen, cold air days...not on high ozone days. In fact, I have never had an asthma attack during a high ozone event. None of the outdoor studies, conducted on asthmatics, I have read on the EPA site, took into account pollen counts during those studies. Allergens are the #1 trigger for asthma and high ozone days in northern parts of the country often occur during high pollen days in late Spring.

6. If ozone is such a problem for asthmatics, then why do cities like Houston, TX have some of the lowest asthma rates in the country? Looking at CDC asthma rates, there is no correlation between asthma rates and cities with high ozone. See the front page of my website for a link to that study.

7. There are hundreds of cities like San Antonio, that have only a handful of high ozone events when weather patterns bring imported pollution into our areas. Only when our winds shift into the NE or East, does San Antonio ever experience high ozone. New studies are now showing that an ever increasing percentage of our ozone may also be transported from pollution from Asia. Why is it fair to economically penalize cities for pollution that is not even their's?

Feel free to explore my website for more information.

Mark Langford