The EPA is proposing to reduce the amount of pollution from coal fire power plants. On paper this is a good idea, especially for San Antonio, which only has ozone issues due to transported pollution from the NE. My only concern is how much will this cost the electricity rate payers. Fortunately, San Antonio's electric company, CPS has already taken measures to clean up their coal fire power plants.

Bloomberg

EPA Proposes Reducing Pollution From Power Plants

July 06, 2010, 3:45 PM EDT

As high pressure builds above us in the next 24 hrs, rain chances will diminish and pollution will be on the increase. Our winds have switched to the East and NE, which during the summer months, brings in transported pollution (both man-made and natural) from the eastern parts of the United States. This added pollution, which normally does not exist in our area, may cause our ozone levels to rise to over 70 ppb. by Friday and Saturday. This is a perfect example of why our current system of penalizing cities like San Antonio for high ozone is wrong. Without the additional pollution, San Antonio never reaches high ozone levels. Last summer, despite our searing heat and cloudless days, we did not go above the EPA mandated 8hr. Ozone Average Maximum of 75 ppb.. And now, the EPA may act to lower the maximum 8hr. standard even lower, forcing almost ever small, medium and large cities into non-attainment.

Below are two links to follow the potential high ozone event. On the first link, look at the sulfates in the upper right hand corner. Sulfates signify where the pollution "blob" is in the country. On the second link, just go to the ozone forecast and check out forecast where high ozone will occur. Notice that high levels will be occurring out in the Gulf of Mexico, where there are no cars. Speaking of no cars, check out the past 10 days of ozone for Joshua Tree National Park, a desolate area in south central California. They have already had several high ozone events in the past 10 days.

Navy Aerosol Forecast

NOAA Ozone Forecast

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 www.ozoneinformation.com

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. http://www.ozoneinformation.com/homepage.html

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

www.ozoneinformation.com

210-229-9950

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.

Why?

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?

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.

Winds carry Asian smog component to western U.S., study finds

WOAI Text of My Interview

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

New Ozone Standards Seen Damaging SA, Texas Economy

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.

Perry Says State May Sue Over Ozone Regs