San Antonio Clean Technology Forum

Observations, impressions

and ideas after attending

“The San Antonio Clean Technology Forum”

On July 11th, I had the privilege of attending the 2013 San Antonio Technology Forum, held at Rackspace headquarters. Thanks to my oldest daughter, who works at Rackspace, I was able to sit with some of her co-workers and listen to a panel of speakers discuss San Antonio's air quality and how we stand in our air attainment with the EPA.

The panel included Moderator, Robert Rivard, Speaker, Judge Nelson Wolff, Doyle Beneby from CPS, Dr. Thomas Schlenker from the SA Metropolitan Health District, Elena Craft from the Environmental Defense Fund and Peter Bella from AACOG (Alamo Area Council of Governments).

Their task was to discuss our current air quality in San Antonio and things being done to lower our emissions in and around Bexar County. In a nutshell, here’s how I summarize their discussion on the subject; "We have to do more", "Our air is getting worse", "Suburbs are bad", "Cars are really bad", and "Asthmatics are dying".

For a more detailed summary of the event, check out Iris Dimmick’s blog in the Rivard Report . The Express-News also reported on the event, but you'll need to have a subscription to their paper to read the story.
There was about 30 minutes allotted for people in the audience to ask questions and I was fortunate enough to mention the fact that last week's high ozone event had impacted not only San Antonio, but Big Bend National Park, where their ozone levels reached 65 ppb., despite Big Bend being located in one of the most remote spots on the planet. Background ozone will throw an estimated 97% of communities into non-attainment if the EPA lowers the eight hour average ozone standard to 65 ppb. Based on local monitoring, cities as small as Seguin (pop 25,000) will not be able to stay in attainment.

Here are a few of my observations from the panel discussion:

 

1. The Eagle Ford Emission Inventories presentation, which I viewed on July 8th at the AACOG Air Advisory Committee meeting, is based on three inventory analysis and the model data shown is a "worst case" scenario during a high ozone event when winds would be out of the southeast. Most of the impact (4-7 ppb.) in the worst case scenario will be on the south side of Bexar County, where high ozone is more rare than on the NW side of San Antonio, where the two monitors that have recorded ozone values over 75 ppb. are located. Ozone impact on the NW monitors may be an estimated 1-3 ppb. and even this is only during a high ozone event.

2. According to the Express-News, Peter Bella said, “the air quality of the region has gotten steadily worse since 2007."  Based on materials distributed by AACOG and data from TCEQ, this is not the case. Every year, NOx levels in San Antonio are decreasing as people purchase cleaner burning vehicles and CPS cleans up their power generation. NOx emissions in 2008 were 231 tons per day as compared with 184 tons per day in 2013. 4th highest ozone values since 2007 are as follows: 2007 (77 ppb.) 2008 (78 ppb.) 2009 (75 ppb.) 2010 (78 ppb.) 2011 (79 ppb.) 2012 (87 ppb.) 2013 (79 ppb.). High ozone days are random and associated with weather events, as I mentioned in my question to the panel on July 11th. In 2002, the 4th highest ozone reading was 104 ppb., and then the following year it was 86 ppb. It's all about the weather. Dirty high pressure moves into our area when our winds shift to the NE and East during summer months.

3. Nelson Wolff's quote is curious, according to the San Antonio Express-News, “We have got to start living closer to each other,” Wolff said. “We have got to quit spreading out. We have to stop building highways.”  Based on Bexar Appraisal District records, Judge Wolff resides near Wurzbach Road and Military Drive, about 13 miles NW from downtown San Antonio. I’m cool with that, but it does seem a little hypocritical, in my opinion, to ask people to live closer to central San Antonio when you live in the suburbs. His comment on not building highways is also hard to grasp. Keeping vehicles moving lowers NOx emissions as compared those same cars idling in traffic jams along smaller roads.  

4. There was discussion on asthma deaths and high ozone but no one on the panel mentioned that there is very little link between high ozone areas and asthma rates. According to the CDC, Texas has some of the lowest asthma rates in the country.

Here are some links to a couple of asthma studies in Texas. 
http://geography.unt.edu/~pdong/courses/4550/reports/Hedrich_Mara_2006.pdf     
And from my website:  
http://www.ozoneinformation.com/uploads/ozone_presentation_2011.pdf

5. Dr. Thomas Schlenker's quote (SA Express-News) of “Suburban sprawl is just killing us,” struck me as being just a little over the top from my perspective. I question how he wants to stop San Antonio from growing, given our strong economy and an increase of families flocking to our great city? Not everyone wants to live in apartments and not everyone works downtown. There are large employers, such as Valero Energy and USAA that are located in the suburbs of San Antonio. If employees purchase homes nearby, they aren’t driving any greater distance than someone living near downtown. With shops, grocery stores and other services available in the suburbs, those of us who choose to live there, often don’t drive more than a mile or two to access them.

As a life-long asthmatic and concerned citizen, I agree that cities should continue to reduce their emissions and we should all work harder to pollute less.  San Antonio is demonstrating that we are doing so, thanks to CPS Energy, cleaner burning vehicles and other industries in our area that are making yearly reductions in NOx and VOCs. Even so, if the EPA continues to “lower the bar” for eight hour ozone thresholds, there is no way we can guarantee that we will not have a few high ozone days per year. Even if the city of San Antonio shuts off our electricity, forces people not to drive their vehicles and closes all businesses on high ozone events, we will not be able to stay in attainment due to transported, background ozone.

I would like to see the EPA consider changing their "non-attainment" rules as stated below:

It is a scientific fact that ground level ozone can form in the presence of NOx and sunlight (UV). It is also a known fact that volatile organic compounds (VOCs) can elevate and extend that chemical process.

While cities and regions across the country can lower their anthropogenic NOx and VOC emissions, the amount of sunlight and weather related factors that can cause ground level ozone are beyond our control. These factors are "Acts of God" and can change a city's ozone levels from acceptable to exceeding the 8 hour standard, even though that city's emissions remain constant. It is also a fact that cities located in southern latitudes are more likely to have high ozone events due to their longer summer season. Furthermore, foreign transport of pollution has been documented and continues to contribute to background ozone levels. 

When a city has been determined as exceeding the three year, 4th highest, 8 hour average of acceptable ozone levels, if they can demonstrate that they are making reductions in NOx and VOC emissions every calendar year forward, then they can stay in attainment status. Since ground level ozone can only form in the presence of NOx, this will insure that eventually ozone levels will continue to fall throughout the country. Under this new method of evaluating attainment, when meteorological conditions that cause high ozone events do occur, cities and industry will not be penalized for conditions beyond their control.

Mark Langford

 

 

 

 

Poking Holes in the American Lung Association’s “State of the Air” Report

For the past 14 years the American Lung Association has released their annual “State of the Air” report and for the past 14 years San Antonio has received an “F” for our air quality. This report is supposed to be used as a guideline for people to get a sense of the air quality in their region, but after further review, it could be argued that the “State of the Air” is more akin to a “State of Fear”, to borrow a title from best-selling author Michael Crichton.

 

First of all, let’s look at the American Lung Association’s “methodology” for giving out their grades. I’m going to focus on ground level ozone, since it is the leading pollutant in the country and impacts the most cities in the country. As you can see in the chart from their website, using eight hour “weighted averages” for high ozone days, any city with an average of 3.3 or higher gets an “F”.  Anything less than 3.3 gives you an “A” with zero, up to a “D” with 3.2. At first glance, this may seem like a logical system of grading until you look more closely.  Using their methodology, San Antonio, with a rating of 5.7, gets the same grade of “F” as Houston, with 27.3 and Los Angeles with 81.8!  A person simply looking at the ALA grades would think that San Antonio’s air is just as polluted with ozone as Los Angeles, even though LA has a weighted average of almost twenty times that of San Antonio. Brewster County, which includes Big Bend Nation Park, got a “D” from the ALA. Brewster County only has a population of just over nine thousand and no major manufacturing.

Now let’s look at how many counties in Texas were included in this report. Because only 35 counties have ozone monitors, 219 out of Texas’ 254 counties were not included. Moral of the story, make sure your county does not have an ozone monitor if you don’t want an “F”!

Next, let’s compare asthma rates between some of the “dirtiest air” cities and the cleanest air cities in Texas. I’ve also included a couple from California just to show that cities from outside of Texas compare pretty equally. I used adult and pediatric asthmatics, taken from the report for each city that I examined. San Antonio, which as you know by now, garnered an “F” on the report, has an asthmatic percentage of 7.5%.  Houston and Dallas also have around 7.5% asthmatics and both cities also got an “F” rating. One of the “A” cities, Brownsville has an asthma rate of 7.6% as well as Webb County which also came in at 7.6%. “F” rated Los Angeles hit 8%, but so did “A” rated Lake Tahoe. These rates are consistent with ones I’ve researched in the past. There appears to be no correlation between asthma rates and high ozone.

It really concerns me that the American Lung Association releases this report every year and scares citizens in almost every city in the country, thinking that where they live could be harming their health. True, pollution is not a good thing, but the air in our cities is cleaner than at any time in the past 50 years due to cleaner burning vehicles and reductions in electrical generation emissions. Furthermore, if a person were genuinely attempting to make a decision on where they should move or start a business based on this report, they would be left thinking that a city like San Antonio was just as polluted as Los Angeles or even more outlandish, a county in far west Texas with less than 10,000 residents.

We can't change the weather, but....

Since I spoke to the AACOG Air Executive Committee in July, San Antonio has exceeded the Eight Hour Ozone Standard by averaging 80 ppb. at CAMS C58 and 77 ppb. at CAMS C23. Unfortunately, these high ozone events were beyond our control due to the weather. Early season cool fronts switched our winds into the NE, ushering in anthropologic and biogenic pollutants into our area. These pollutants reacted with our high temperatures and sunshine to give us several high ozone events in August and September.

As we all know, we haven't had much luck controlling the weather, but it is possible for all of us to control our leadership in Washington so that there might be a chance that either our current 8 hour ozone standard remains the same or goes back to the 85 ppb. standard prior to 2008.

The Obama administration has made it "not so secret" that they favor a standard that is between 60-65 ppb. Last year they halted the EPA from potentially lowering that standard and asked that the decision be "shelved" until 2013...after the election. Obama Halts Controversial EPA Regulation

If the EPA lowers the standard down to 60-65 ppb., according to an article in US News and World Report, "The proposal could render up to 96 percent of U.S. counties noncompliant, and by some estimates would impose economic damages exceeding $1 trillion."

Even more frustrating is the science, or lack of, behind the move to reduce ozone standards. I have two compelling studies posted on the main page of my website conducted by TCEQ, showing no link between high ozone events and hospitalizations.

 

Citizens To Be Heard-7-25-12  AACOG Air Tech Meeting

Good morning. My name is Mark Langford and I am the editor of OzoneInformation.Com, a citizen of Bexar County and a lifelong asthmatic.

If I told you that there was a law on the books that could penalize people for having gray hair before the age of 55, you’d think that was completely “ridiculous”. Men and women can’t control the genetics that determines when their hair will turn gray.

But if I told you that the Clean Air Act penalizes areas for having high ozone events when it’s beyond their control, you would not question the EPA or Congress on their science. It’s time to question the science and the Clean Air Act. Depending on this year’s presidential election, the current administration has made it known that they are in favor of lowering the high ozone threshold to even lower parts per billion, sending most of the country into “non-attainment”.

Join me while we look at a Power Point Presentation that illustrates why the current 8hr, three year ozone average is “ridiculous”.

1. Looking at my second slide, you can see our first high ozone event of 2012 that has put San Antonio very close to being in violation of the Clean Air Act. Notice how the high ozone days are clustered around two days at the end of June and that July there are now high ozone days, despite it being very hot and the same emissions going on as June. Now look at slide 3 and notice that the high ozone event in June also occurred in Austin and Corpus. Houston and Dallas also had high ozone readings during those times.
2. It’s all about the weather! Winds during those high ozone days were out of the NE-East. As we have seen time and time again, winds from the NE-East usher in pollution (biogenic and anthropogenic sources) into the San Antonio area, spiking our ozone readings to levels that do not occur without outside influences.
3. As an example, let’s look at slide 5. This graphic shows the ozone that was recorded at Joshua Tree National Park from May 3^rd-May 12^th of this year. As you can see, their 8hr average exceeded the Clean Air Act on the 10^th-12^th of May.  Looking at slide 6, you can see that Joshua Tree is located in a very remote location in the desert of southern California. Los Angeles is to the west and San Diego is to the SW. Slide 7 shows an image of what it looks like at the entrance to Joshua Tree National Park.  As you can clearly see, this is a desolate region, devoid of cars, trucks, power plants and manufacturing. But, as you saw in slide 5, they also have high ozone events. Since they obviously are not emitting pollutants of their own, then it must be assumed that their high ozone is the result of transported pollution from Los Angeles and other sources in the region. Same logic can be used for San Antonio. Even though we are a city of over a million people, our pollution is not enough to exceed the EPA 8hr standard without outside factors.
4. Now let’s look at the next graphic…slide 8. This information is from a report found on the American Lung Association using Asthma Rates from the Centers for Disease Control. States with some of the highest ozone problems have asthma rates below the national average, including Texas. This information has not been hidden, yet it is never mentioned in any EPA reports that discuss a link between asthma and high ozone events. As an asthmatic, I have never had an attack during a high ozone event.
5. Lastly, let’s look at slides 9 and 10. Part of the problem when we have high ozone events is due to natural causes. Besides the obvious natural cause, the weather, there are other natural causes as well. For ozone to form, it needs several chemical reactions to occur. First, there must be NOx (nitrogen oxides), then it needs sunlight (in abundance in south Texas) and lastly it needs volatile organic compounds. According to the EPA, biogenic (natural) emissions were estimated to contribute 74 percent to VOC emissions from all sources during 2005. One of my theories on why our ozone spikes when winds are out of the NE-East, is that high levels of biogenic VOCs flow into our area from the vast forested regions of the Eastern United States. We still have to have man-made NOx to  start the process, but the normally low levels of ozone that are recorded when the winds are not out of the NE-East are quickly elevated when those winds occur.

Thank you for your time.

Mark Langford

My Response to Express-News Article 8-23-12

To the Express-News

I just read your front page article, "San Antonio appears on EPA's radar" and there are a couple of key points I would like to address:

1. Winds were blowing from the NE and East, due to the passage of an early season cool front. That same front ushered in high levels of smoke from forest fires, sulfates (containing NOx) and volatile organic compounds from biogenic and anthropogenic sources to our north and northeast. You can see this on the NAAPS model from yesterday.

2. Background levels of ozone were so high that even Seguin (74 ppb. on the 20th) and San Marcos (81ppb. on the 20th) had high levels of ozone at their reporting sites. When you factor in the high background levels, San Antonio only added 10-15 ppb. of recorded ozone. Austin avoided the high ozone levels due to a constant cloud deck that only parted yesterday afternoon. When it did, their levels also spiked for a few hours. Here is a link to this data: Daily 8hr Ozone Averages

3. The Eagle Ford Shale drilling area is located to the SE of San Antonio and did not play a role in our high ozone on Monday and Tuesday, nor did smoke from Mexico.  Our winds were consistently from the NE and East on Monday and Tuesday. This was a dirty "Continental Air" event.

4. These events are rare and can be blamed on the weather, not local pollution. San Antonio has some of the lowest emissions in the country for a city our size and never exceeds the EPA standard unless transported pollution invades our region.

Please check out my website for more information on ozone. I have been studying ozone for over 10 years now.

Thanks.

Mark Langford

www.ozoneinformation.com

San Antonio Exceeds the EPA's 3 year 8 hour Ozone Average

San Antonio is now out of compliance with the EPA's National Ambient Air Quality Standard (three year-8hr ozone average) as of today. An early season cool front is to blame for ushering in transported biogenic and anthropogenic pollutants into our area.

The next step for San Antonio will be "negotiating" with the EPA to try and stay out of "Non-Attainment" status. As usual, high ozone events only occur when winds are of the the NE and East in San Antonio during the summer, late spring and fall. As you can see in the graphic below, the two monitors with the highest ozone readings (CAMS 58 and 505) are located on the north side of San Antonio. With winds blowing from the East and NE, that means that local contribution was minimal. Notice that San Marcos and Seguin also had higher than normal ozone readings. Austin lucked out with cloud cover this afternoon and stayed lower than San Antonio's high ozone day.

Latest NonAttainment vs Asthma Rates

2012 Non Attainment Counties

The latest EPA Non Attainment results are in, based on the lowering of the 8 hour ozone average to 75 ppb in 2008.
San Antonio came close to non attainment with a 3 year average of 73 ppb. while the Dallas and Houston areas exceeded 75 ppb. If the 3 year average had dropped to 65 ppb. as proposed by the EPA, almost every city in Texas would be in non attainment. Check it out for yourself.

Over the next few weeks, I will be examining the non attainment regions and comparing their high ozone rates with current prevalence percentage asthma rates. Since high ozone is suppose to trigger and exasperate asthma, then there should be direct correlation between the non attainment regions and asthma rates.

Since I live in Texas, let's start with Region 6 as our first area for examination. Our data will come from the American Lung Association's latest report "Trends in Asthma Morbidity and Mortality" from 2011. This is the same group that has given almost every large city in the country an "F" for air quality in their yearly "State of the Air" report. San Antonio, which is currently in attainment, consistently gets an "F" on our air quality...but that's another story!

According to the American Lung Association, 8.4% of the USA has been told that they have asthma. So, let's use that number as the average for asthma in this country and compare it with cities that are in non attainment, according to the EPA. Below is a list of cities in Region 6 that are in non attainment and their asthma rates.

1. Memphis, TN area:  7.0% Current Asthma Prevalence

2. Baton Rouge, LA:  7.3% Current Asthma Prevalence


3. Dallas-Ft. Worth, TX:  7.2% Current Asthma Prevalence


4. Houston-Galveston-Brazoria, TX:  6.2% Current Asthma Prevalence


So, as you can clearly see, the highest ozone regions in Region 6 have asthma prevalence rates that are below the nation average. The city with the highest asthma prevalence rate in this region is Lubbock, TX, with a 13.1% rate. Lubbock's air is so "ozone free" that the EPA doesn't even bother to monitor it.