TexasVox: The Voice of Public Citizen in Texas

African Dust Storms, Air Pollution, and Exceptional Events

July 5, 2018 by Adrian Shelley

As if the relentless heat wasn’t enough this summer, Austin is experiencing hazy skies due to an African dust cloud originating in the Saharan desert. The dust was most noticeable on Sunday, July 1. The technical term for this dust is “fine particulate matter,” particles that are so small they can travel from our lungs into our blood stream, causing health problems. An individual particle is 1/20th the width of a human hair.

The Clean Air Act establishes standards for fine particulate matter (also known as “PM2.5” because it is 2.5 microns in diameter) in the air we breathe. PM2.5 is measured in micrograms per meter cubed, a measurement of how much material is found in a given volume of air. The Environmental Protection Agency has established limits of PM2.5 at 35 μg/m³ in a 24 hour period and 12 μg/m³ in an annual average. If an air monitor exceeds that level of PM2.5, then the region it monitors risks being designated in “nonattainment” of the federal standard. There are currently no areas in Texas in nonattainment of the PM2.5 standard, though there are several areas in nonattainment of the ozone pollution standard.

Unfortunately, the Austin area got very close to violating the PM2.5 standard on Sunday. The table below lists hourly monitor values at the Zavala air monitor in Austin (you can see a map of all the air monitors in Texas here). As you can see, the 24-hour average of monitor values at Zavala on July 1 was 32.5 μg/m³, very close to the EPA’s standard of 35 μg/m³.

Data available from TCEQ.

This does not mean, though, that Austin risks falling out of attainment of the fine particulate matter standard. There are a few reasons for this. First, measuring compliance with the standard is a complex calculation that involves averaging three years of air monitoring data. Second–and more importantly for air quality this week–African dust is considered an “exceptional event” that would be excluded from the data anyway.

An exceptional event is an air pollution event that is excluded from the data because it meets certain criteria. The EPA establishes the criteria for an air pollution event to be considered exceptional. These criteria include that “the event is associated with a measured concentration in excess of normal historical fluctuations, including background.” 40 CFR § 50.14(c)(3)(iv) (emphasis added).

African dust has been reaching Texas since time immemorial, and the impact of these events on air quality in Texas is absolutely part of the normal historical fluctuations of weather and air quality. In fact, the phenomenon was first identified by a noted historical figure, Charles Darwin, during his famous trip aboard the H.M.S. Beagle in 1833.

You might think that the considerable historical record on African dust events would cause EPA to reject their exclusion from the data on the basis that they are, after all, well within “normal historical fluctuations.” You would be wrong. The truth is that Texas has a long history of claiming exceptional events that include African dust storms. Other typical exceptional events in Texas include agricultural fires in Mexico (as old as agriculture) and ozone pollution blowing in from other countries (also Mexico, also old).

Why does this matter? Most importantly, air pollution is linked to public health. Children, the elderly, and people with respiratory ailments such as asthma and COPD are particularly vulnerable to air pollution. We have to keep our air clean to keep ourselves healthy. But nonattainment designations have consequences for a region that can last for decades and cost billions of dollars. Houston and Dallas, for example, have been trying to get into attainment of the ozone standard for decade. It’s why we have emissions tests for our cars, and why we can’t build a new factory without reducing pollution from an existing one. The consequences are so great precisely because the impact on human health is so serious. Asthma is the number one cause of school absences. Globally 7 million people die each year from air pollution.

So the purpose of a nonattainment designation is to make our air healthier and protect ourselves and our children. Unfortunately, in Texas, the focus is on avoiding nonattainment designations and their consequences to big business. Several times in the last few years, Texas has used the exceptional events rule to keep areas artificially in attainment of air pollution standards. In 2013, the Texas Commission on Environmental Quality plainly stated that it was excluding enough exceptional events from Houston’s data to keep the area from being desingated under the fine particulate matter standard. Several air quality advocates (including myself) objected to this move. We even pointed to Charles Darwin’s observations as evidence that Texas could not exclude African dust events from its data.

Our objections were ignored by Texas and EPA. The result today is that thousands of people are breathing air that does not meet federal pollution standards. Their health will suffer as a result. Some people will even die. There are quantifiable consequences to these decisions, and they are measured in human lives.

Since the 2013 move to avoid designating Houston as not meeting the PM2.5 standard, several other exception event exclusions have kept areas of Texas artificially in attainment of pollution standards. El Paso doesn’t meet the ozone standard, but exceptional events blamed on Mexico in 2015 have helped the area to avoid a nonattainment designation. More recently, the failure to designate San Antonio as not meeting the ozone pollution standard was blamed on ozone transport from other regions.

In some cases, Texas is using the law correctly to exclude exceptional events. (Houston’s lack of a PM2.5 designation is not one of these cases. We still maintain that it was done improperly and in violation of the exceptional events rule and the spirit of the Clean Air Act.) But even if the state is legally correct in its maneuvers, it’s doing so at the cost of human health. When the Texas Commission on Environmental Quality relies on tricks of data manipulation to avoid federal scrutiny, it is prioritizing business interests over people. A nonattainment designation has consequences for business and industry: old plants have to clean up, new plants have to invest in clean tech. These consequences do reach into the billions of dollars. The total cost of compliance with the Clean Air Act in 2020 is estimated to be $65 billion. But the health benefits of cleaner air in 2020 is estimated at $2 trillion. That’s a return on investment of more than 30 to 1.

Notably, more and more of our air pollution is coming from vehicles. When you register your vehicle, you pay a fee that is used in part to reduce vehicle pollution. When you get your car inspected and make any improvements needed to meet emissions standards, you are investing in clean air. Texas makes sure that you pay your fair share of the cost of reducing air pollution, and you should be happy to do so. After all, it is an investment in your health and your children’s future.

So why does Texas keeping fighting against Clean Air Act regulation? It’s a question of priorities. Much of the cost of compliance is born by industry, especially the oil and gas industry. That’s a powerful lobby in Texas, far more powerful than children who can’t go to school because of chronic asthma attacks. Texas is willing to skirt some regulations in order to save money for industry. It isn’t willing to invest in environmental improvements that pay huge dividends to its people in the long term.

Industry profits today, or public health tomorrow. Texas has made its choice. What’s yours?

Posted in Air Quality, Health, Houston, Pollution | Tagged air pollution, EPA, ozone, particulate matter, PM2.5, TCEQ, Texas |

Solar Success at Universities

July 3, 2018 by Adrian Shelley

This is a guest post by Public Citizen Intern, Celine Cottenoir who is also a Student Government Association – Senator at St. Edwards University, Austin, Texas.

Students and faculty at universities across the United States have been at the forefront of implementing solar energy at their schools. And for good reason, with increasing attendance at colleges and universities, it is a growing concern to many that these institutions be environmentally conscious.

So what makes solar energy remarkable?

Solar energy has seen increased popularity among institutions due to its ability to “pay back” to an institution over time. Once initial installation costs have been paid, an institution which chooses to adopt solar energy can then save money by not having to buy energy from an electric company. With solar panels warrantied at 25-years, the institution can reap the reward of solar energy payback for several years. Not only do solar panels make for a smart investment over time, they have low maintenance and repair costs.

Although there are several advantages with the use of solar energy, there can also be administrative and fiscal challenges in the push for renewable energy in the form of solar power. For many of those pushing to implement renewable energy at their own universities, and even wider community, it can be asked: “How did they do it?”

The following universities have excelled in the realm of implementing solar energy:

Stanford University, Stanford CA:

In 2009, Stanford began their renewable initiative by launching their “Energy and Climate Action” which planned to transition away from using 100% fossil fuels. Since 2009, Stanford has transitioned to using 65% of its total electric use to renewable sources. Of the renewable energy used by Stanford, 50% of it comes from solar energy. Stanford has been able to provide 200 kWh of solar electricity to its campus by use of both onsite roof top solar along with offsite solar power procurement:

The onsite rooftop solar can be found on 16 various locations on campus, and accounts for 2% of solar energy produced.
One of Stanford’s on-site installations
The offsite solar power procurement is where Stanford is able to get 48% of its solar electricity. The project is a part of a partnership with SunPower, a solar panel manufacturer and contractor. The offsite solar array is a 67 megawatt plant and is comprised of 155,000 panels, located in the Mojave Desert. This array is considered an “individual model”, meaning it provides electricity to Stanford University exclusively.
Stanford’s off-site solar panel array

Stanford leases the panels from SunPower, and initial costs required by the initiative were allocated from the university’s annual facilities budget.

George Washington University & American University, Washington DC:

In June of 2014, George Washington University and American University created a partnership called the “Capital Partners Solar Project”. This partnership would make the large-scale implementation of solar energy fiscally possible. As a result, 52 megawatts of energy are provided by Duke Energy Renewables to both AU and GWU. The energy is produced off-site in North Carolina electric grid. The universities get the financial benefits from the energy produced.

George Washington University and American University Presidents announce plans for a joint solar energy initiative between universities.

American University:

American University is the first university in the United States to become “Carbon Neutral”. Meaning, AU has achieved net zero greenhouse emissions. Electricity used at AU comes from 100% renewable sources, 50% of which comes from the Capital Partners Solar Project solar energy deal.

George Washington University:

Along with American University, George Washington University also receives 50% of its electricity from the solar energy deal. The solar panels aren’t present on campus due to lack of space required for energy demands. The desire by students for solar power, along with administrative support, paved the way for the partnership for solar energy with American University. The partnership gave the perfect opportunity to increase renewable energy consumption and do so more affordably.

Even for schools without large endowments, solar energy can still be made financially feasible:

Huston-Tillotson University, TX:

Funding can be a huge obstacle in the push for solar, as initial installation costs can be huge. In Texas, many schools have used a number of local renewable energy incentives to afford the initial costs of solar.

Huston-Tillotson University, a small private university in Austin, Texas has installed a 240 kWh array, which has 736 panels. The university has a student body population of just under 1,000 students. With a small student body, the university wanted to incorporate green energy while also being cost effective.

Huston-Tillotson University leases it’s solar panels through Freedom Solar, a local Austin manufacturer.

Huston-Tillotson was able to finance their solar array will no upfront costs. The university was able to make installing solar panels a possibility by earning PBIs (performance based incentive credits) offered by the City of Austin, along with the commercial VoS (Value of Solar), which is rate Austin Energy uses to compensate customers for the value of the energy the panels produce. These two revenue streams from Austin Energy (the city-owned utility) equal at least what HT pays for the lease on the solar installation.

Karen Magid, director of STEM and Sustainability at Huston-Tillotson, stated a to two-prong approach was used when giving the pitch for solar energy. The first, that green energy would pay back to the university over time and allow them to discontinue purchasing electricity from the grid. Second, the use of green energy is a major selling point to environmentally conscious prospective students. HT is able to boast more solar panel energy per student than fellow Austin area universities: The University of Texas, St. Edward’s, and Concordia.

Posted in solar | Tagged American University, George Washington University, Huston-Tillotson University, solar colleges, solar schools, solar universities, Stanford University, Texas, university sustainability |

Energy storage–the third leg of the stool

June 28, 2018 by Adrian Shelley

25 years ago, Texas electricity prices were skyrocketing because overbudget and unneeded nuclear plants were being brought online. It was generally believed that competition among electric generators would lower costs and pollution. That thesis has come true. Natural gas producers claimed building a lot of new natural gas plants would reduce electricity costs. Advocates for renewable energy and energy efficiency believed that an open market would create new market opportunities in which they have thrived.

Therefore, the Texas electric market was deregulated and split into three parts. The generators and retailers would compete based on costs but the distribution and transmission system, which provides the poles and wires on which our energy is transmitted, would remain regulated. In order to avoid conflicts of interest the rules governing deregulation clearly divided the market into those that generated electricity and those who distributed it. The rules clearly said that generators produced the energy- and that transmission and distribution companies could not.

This made sense about 25 years ago, but time has shown us that the system is out of balance, and the only time the generators really make money is when it is really hot or cold. On a daily basis the amount of energy we use swings wildly from late at night when the winds blow hard to hot afternoons when every generator is needed. As result we have a lot of wasted power produced to balance these swings. This systemic imbalance results in a lot of unneeded costs to consumers including pollution and overbuilding of poles and lines to deliver energy at times of peak demand.

Storing excess energy in big electric batteries can provide a third leg to the stool and balances out the swings while reducing costs and pollution. This isn’t new technology. We’ve been storing energy in car batteries for more than 100 years. But battery technology has changed dramatically over the last decade. The proof is in your pocket. Think about the phone you carried ten years ago. Today’s phone batteries are a fraction of the size and weight and store far more energy for longer than those of 10 years ago. Today’s storage batteries can store renewable energy at a fraction of the cost of upgrading or building transmission or distribution infrastructure. It can also store that excess energy produced by renewables until we need it on hot afternoons, cutting costs for consumers and reducing pollution. Add to that the expected explosion in energy storage provide when millions of electric cars plug into the grid and allow tier batteries to be used to meet short term peaks on a hot summer day.

The rules adopted 25 years ago didn’t envision the dramatic technological changes that have occurred. What we need to do is modify the rules that deregulated the electric industry by allowing batteries to provide energy to reduce costs while making money. That means clearing up the question of who can own storage and how to pay for it.

The Public Utility Commission (PUC) is beginning to hold hearings to resolve this question. There are many solutions being discussed. The basic message is clear. We support storage which will lower costs and pollution and can enable new technologies to thrive.

Public Citizen believes that consumers deserve energy that is reliable, resilient, responsive, modern, clean, and affordable. Energy storage technology is the next big step in reducing pollution and costs from power generation. If correctly deployed, it will help us avoid expensive and unnecessary buildouts of transmission infrastructure, thus lowering costs for consumers. Storage will also help us to realize the full potential of our renewable energy sources, particularly wind which blows strongest at night and solar which produces energy during the middle of the day and storing it until we need it most in the late afternoon and evening. We support PUC adopting policies that will reward utilities for investing in energy storage that is cost effective in providing clean, reliable, affordable energy to Texans.

This guest post was written by Tom “Smitty” Smith, who served as the Texas state director of Public Citizen for 31 years from 1985 until his retirement in early 2017. For more than four decades, Smitty organized citizens to stand up for their rights in a wide variety of forums. He has worked on energy, environment, ethics and campaign finance reforms. His passion has been reducing global warming by promoting renewable energy, energy efficiency and cleaner transportation. Many of the programs he promoted have become national and international models.

Posted in Energy | Tagged Texas |

Reimagining the Lawn

June 26, 2018 by Briauna Barrera

June 26, 2018
By Briauna Barrera

Imagine: You’re walking through your neighborhood one warm summer evening. The sun is sinking into the horizon, and the cicadas are starting their nightly chorus. Bats are swooping in the sky. The scent of a nearby grill lingers in the air. Automated sprinklers and homeowners alike water vibrant green lawns, excess water swirling lazily onto sidewalks and down sewer drains. This is familiar, this is home.

Lawns appeared in England and France in the 1800s as a showcase wealth and nobility. The idea reached the United States through literature and art from England in the late 18th century and was similarly used by landowners to convey their status. In the 1830s and 1840s, as cities in the US become more congested and polluted due to the Industrial Revolution, wealthy families began to move outside the city in order to escape the issues of urbanization. In these new suburban landscapes, the upper class adopted the stylings of the elite in England and France. Then at the beginning of the 20th century, the United States Department of Agriculture, the United States Golf Association, and Garden Club Of America encouraged the proliferation of lawns due to its potential as a profitable industry. During this same time, the United States shifted from a producer society to consumer society and much of the individually owned land, especially in cities and suburbs, was no longer needed to produce food for domestic animals or vegetables for the family. Advertising encouraged people to have lawns and buy lawn-care products and by the 1930s, lawns were viewed as a normal and expected feature of middle-class suburban landscapes.

Sketches and Hints on Landscape Gardening, Humphry Repton, 1795

With the economic boom following World War II and the passage of the GI Bill, which allowed returning soldiers to afford college educations and ownership of detached single-family homes, there was a dramatic increase in suburban development. Automobile-centric policy and corporate practices, in large part through lobbying from car manufacturers, also supported the rapid increase in suburban development, as the increase in mass production of cars made them more affordable for private ownership and the drastic expansion of the U.S. highways systems under the Federal-Aid Highway Act of 1956, gave residents an avenue out of deteriorating urban areas into the surrounding suburbs. While white residents fled in droves from cities, known as White Flight, people of color were often prohibited from moving into the suburbs through racists practices such as red-lining. Thus, the sharp rise of suburbia resulted in an increasingly stark urban landscape defined by race and allowed white families to join the middle class and start building generational wealth that that was harder for families of color to obtain. The American lawn became a staple for the well-to-do middle class and continued its legacy of showcasing wealth, status, and consumption.

The Green Revolution, a period of rapid technological advances in agricultural technology and federally-supported agriculture research increased people’s ability to maintain grass lawns in any climate. Now that grass lawns were within reach for families across the nation, the United States Golf Association (USGA) and the National Gardening Association (NGA) sought to expand their power and influence through the new patch of empty land surrounding each middle class American home. The NGA did so by hosting garden workshops that educated people on the proper way to grow and maintain lawns, hosting gardening contests, and volunteering within local communities. While gardening groups and clubs shifted their focus to growing ‘victory gardens’ consisting of vegetables to support the wartime effort during World War I, after the war, focus shifted back to growing flowers instead of vegetables and beautification efforts rather than using gardens, lawns, and community spaces for practical measures. Advertisements also ramped up, with ads and articles about gardens starting to appear in magazines like Better Homes and Gardens. Beautification gardening and golf, leisurely and status-laden activities, became available to the middle class who were increasing in numbers in the suburbs and creating a lifestyle in which grass became paramount.

Wizard Power Mower & Lawn Conditioner advertisement, 1953

The commitment of American consumption and advertising resulted in the creation of a financial and laborious expenditure for home-owning Americans who were expected to spend vast amounts of time and money in the upkeep of something that produced nothing. Currently, the average homeowner spends about 70 hours a year maintaining their lawn and Americans households spent around $29.5 billion on lawn care and gardening services in 2015. However, people are not instinctively compelled to care for lawns, at least not when lawns were first introduced, but many people learned “to keep their front yards in presentable condition as dictated by community cleanup campaigns and school programs, as well by advertising. Advertising, as a result of a country driven more and more by consumption and production, manufactured a false need for lawns that came at the consumer’s and the environment’s expense.

Lawns have a distinct impact on the appearance of the American landscape through the introduction of non-native and invasive plants across the United States. Many of the common grasses used for lawns, such as Kentucky bluegrass or Bermuda grass, are not native to the North American continent and were brought over to familiarize the landscapes for colonists, to graze animals that were accustomed to European flora, and by accident, as when grass seeds were present in the hay of livestock on ships. Eventually these non-native grasses became the grasses people used for their lawns. As lawns spread across the United States, so too did invasive and non-native grass species spread. These grass species drove out other, native species of grass, decreasing biodiversity and disrupting the local food webs as a result.

Lawns are an intensive use of resources, especially water. According to the EPA, nationwide use of landscape irrigation makes up approximately one-third of all residential water use, totaling more than seven billion gallons per day, and up to 50 percent of water used for irrigation is wasted due to evaporation, wind, or runoff caused by overwatering. Lawns not only waste resources, but they are also an inefficient use of land. As lawns became more commonplace, it became increasingly taboo for lawns to serve a purpose other than aesthetics. When lawns were first introduced, they served various functions, such as grazing for livestock, but by the 20th century, functionalist lawn us had all but died out. However, lawns take up an estimated 40 million acres of land in the continental United States or almost two percent of surface in the contiguous U.S. If grass were counted as a crop, it would take up three times as much space as irrigated corn.

Lawns maintenance uses an inordinate amount of fertilizers, pesticides, herbicides, and insecticides. Lawns use about 30,000 tons of pesticides yearly in the United States. However, the effects of these toxic chemicals do not stop at the land; excess phosphorus and nitrogen runoff from lawn fertilizer enters waterways, and the increased amounts of dissolved nutrients cause algae blooms that siphon oxygen out the affected waterways, asphyxiating fish and causing the larger ecological systems to fail and ultimately eutrophying these waterways. Not only does this destroy the habitat for flora and fauna, disrupt the ecosystems, and lower biodiversity, it also causes “dead-zones” that prevent fishing from taking place and negatively affects water quality, which in turn causes human health issues.

Furthermore the toxicity of these fertilizers can affect other animals indirectly, for example, birds that eat fish or insects that have come into contact with fertilizers are at the risk of contracting pesticide poisoning and dying as a result. Additionally, studies have shown a link between the use of pesticides and colony collapse disorder (CCD), a phenomenon in which bee colonies are abandoned for seemingly no reason. This is problematic because one-third of the food we eat depends on insect pollination, mostly by honeybees at that, and over the last six years, American beekeepers, on average, have lost 30 percent of their hives each winter. With the spread of lawns and the use of pesticides, the health of ecosystems, animals, and humans are all at risk.

A suburb in Bay City, Texas.

By enforcing a particular landscape aesthetic, it becomes evident that the American lawn forced a cultural homogeneity across different climate zones and different demographics. This particular home landscape aesthetic enforces a hegemonic idea of what American homes can and should look like by catering to the Northeast ideal and climate of landscaping, all the while pushing people who cannot afford that ideal or do not wish to conform to it to the periphery. This becomes yet another barrier to becoming homeowners, an integral feature to accruing generational wealth.

As the commonality of lawns increased and more and more homes in the suburbs were bought, an increase in private property occurred as undeveloped land was acquired, bought, divided, and sold to families and individuals. Thus, the propagation of lawns also contributed to an increase of privatization. This increase of privatization is problematic because privatization sterilizes culture by taking public space, whether it be physical commons like public parks or digital commons such as TV and radio, and sells them to the highest bidder. As privatization increases, through processes like the acquisition of undeveloped (and unowned) land or of public land and the subsequent development of that land for private purposes, such as creating suburban developments, culture loses to commercial values. The institution of the grassy lawn, driven by those same commercial values, forced out cultural and geographically-specific landscaping methods because it suited the land developers who had vested interest in the lawn maintenance industry.

Lawns are ecologically unsustainable and contribute to the pervasive isolation of people who live in an economic system based on consumption and individualism. Lawns may cause many problems and issues, but they are not the root cause of them. They are microcosms of systematic problems. We need to rethink the way we construct and live in cities, including housing, transportation, and density.

Imagine: You’re walking through your neighborhood one warm summer evening. Native trees cast shade over the wide sidewalks with ample bus-stops on one side and protected bike lanes on the other. You pass one of the many neighborhood parks and see children playing, couples walking hand-in-hand, and families enjoying dinner together. Where lawns were once sprawled out, now stands additional multi-family housing, along with more shade trees, fruit trees, and landscaping full of native plants and flowers. Gardens built with permaculture methods bloom everywhere, full of vegetables and herbs. Butterflies, bees, birds, and bats provide a peaceful, steady hum of life. You pluck a ripe plum, it tastes sweet. This is familiar, this is home.

Posted in Global Warming | Tagged Texas |

EPA Proposed Rollbacks to Chemical Disaster Rule will Harm Communities

June 21, 2018 by Citizen Stephanie

UPDATE: The EPA has extended the public comment period for this rule. You can now submit your comments by an August 23rd deadline:
https://action.citizen.org/p/dia/action4/common/public/…

Last week, I, Stephanie Thomas, Houston Organizer for Public Citizen, joined members of community and environmental groups testifying in opposition to Polluting Pruitt’s proposed rollbacks of the 2017 Chemical Disaster Rule.

The Chemical Disaster Rule helps better protect workers, first responders, and fenceline communities. So what exactly is the Environmental Protection Agency (EPA) gutting?…

Almost all of the disaster prevention measures in the Chemical Disaster Rule.

What’s Being Lost

The repeals mean that industry will no longer be required to invest in third party audits when accidents happen nor will facilities need to conduct a root cause analysis as part of incident investigations following incidents with a catastrophic release or a near miss.

The EPA is merely putting out fires, not working to prevent the fires, explosions, and deaths from happening in the first place.

Safer technologies? The EPA proposal rescinds requirements for certain facilities to complete safer technology and alternatives analyses to minimize the amount of hazardous substances used. Also, they are rolling back demands to use less hazardous substances, incorporate safer designs, and minimize the impact of releases. This seems like a a no-brainer, but unfortunately, these rollbacks toss safer technology out the window.

Even first responders will be losing out. The proposed changes remove a requirement to provide, upon request, information to the public on chemical hazards, including substance names, safety data sheets, accident history, emergency response program information, and LEPC contact information (Under the Emergency Planning and Community Right-to-Know Act (EPCRA), Local Emergency Planning Committees (LEPCs) must develop an emergency response plan, review the plan at least annually, and provide information about chemicals in the community to citizens).

Let us remember Hurricane Harvey and its devastating chemical impacts along the Gulf Coast – most notably the explosion at the Arkema facility in Crosby, Texas. Floodwaters caused the backup generator to fail, leading to explosions of unstable organic peroxides and the release of a slew of toxic chemicals, including an unpermitted release of cancer-causing ethylbenzene. Had the 2017 chemical disaster rule been in place, first responders and community members would have had access to safety data sheets providing information for protecting themselves against the harmful chemicals released into the air and water; and would not have had to file lawsuits such as the one filed in Harris County by first responders alleging Arkema failed to take adequate safety steps to secure dangerous chemicals ahead of Hurricane Harvey.

Known Impact to Communities

By the EPA’s own account, more than 150 chemical incidents occur each year. And the agency knows that repealing these rules will hurt minority, low-income communities the most.

Who benefits? The chemical industry – and all for a measly $88 million per year, a drop in the bucket for these big corporations.

The EPA only provided one opportunity to testify on the rollbacks to the Chemical Disaster Rule. While I was glad to be able to testify there, that’s not good enough. Because this proposal knowingly harms communities, impacted communities need a seat at the table.

While the EPA leaves out environmental justice communities, industry interests are well-represented within the agency. Several administrators and counselors for the EPA have served as lobbyists and litigators for industry. Just yesterday, the US Senate held a confirmation hearing for DowDupont lawyer Peter Wright, who will likely be leading the EPA’s Office of Land and Emergency Management, which oversees the Risk Management Program.

It’s no accident that these rollbacks are being proposed at a time when industry’s foxes have taken over the henhouse. The EPA should be supporting the health and wellbeing of Texas communities, not padding the profits of corporate polluters.

Posted in Energy, Good Government | Tagged accident prevention, Chemical Disaster Rule, chemical safety, Environmental Protection Agency, EPA, human health, risk management, RMP, safety, Texas, worker safety |

Coal-Fired Power Plant with Carbon Capture – Cutting Emissions or Increasing Them?

June 19, 2018 by Nafi Shah

Petra Nova, the world’s largest post-combustion carbon capture project, has been in commercial operation at the W. A. Parish Plant in Thompsons, Texas, southwest of Houston, since January 2017. The project offers no hope for combating climate change.

Petra Nova Facility

The Parish station has 10 generating units, but only unit 8 has been upgraded with carbon capture technology, and thus, the other 9 units are still emitting CO₂. The project was supposed to divert 40% unit’s exhaust into a post-combustion capture (PCC) system, which designed to capture 90% of the CO₂ in that stream. However, once the emissions from the gas-fired turbine that powers the carbon capture system and the emissions from the additional petroleum products resulting from enhanced oil recovery are taken into consideration, the total impact of the carbon capture system is actually an estimated 2% increase in CO₂ emissions.

The Petra Nova has retrofit cost $1 billion and benefitted from a $190 million Clean Coal grant from the U.S. Department of Energy. This huge amount of money has been invested to build a new coal power plant and enhance oil recovery by injecting 5,200 tons of carbon dioxide per day at West Ranch. However, NRG’s CEO has claimed that the Petra Nova CCS project “made both strategic and economic sense at $75 to $100 a barrel” and that “obviously [with West Texas Crude selling for less than US$50 a barrel], it does not currently make economic sense.”

Fossil fuel industries have promoted the use of CCS technology as a solution to enable the continued burning of fossil fuels for electricity generation. The coal industry has been seeking to increase its profit by lobbying Congress to get subsidies even though they are aware of the negative impacts of burning fossil fuels on the human health and climate change. Moreover, fossil fuel industries have influenced the EPA to reduce penalties and long-term liability to increase the profitability of CCS projects at the expense of public health and the environment.

Petra Nova Carbon Capture

Health and Environmental Impacts of CCS Technologies Include:

Power plants that are capable of capturing carbon require 15-25% more energy than conventional plants in order to capture and store CO₂. The mining, transportation, and burning of the additional fuel (usually coal) needed for CCS produces more CO₂ emissions.
Particulate matter and Nitrogen Oxide are both expected to increase as a result of the additional fuel consumption in order to capture carbon dioxide. Particulate matter is identified by the World Health Organization to be the deadliest form of air pollution as its ability to enter the respiratory system
Due to the degradation of the solvents in the process of capturing carbon, Ammonia is expected to increase, which can lead to form particular matter in the atmosphere
Possible damages or any leakage in the pipeline or storage reservoir would result in serious environmental impacts
Gradual leakage in the storage site can damage fresh groundwater resources if the incorrect storage site is selected or the site is not prepared correctly
Injecting CO₂ into aquifers can cause acidification of the water and increase its ability to break down the surrounding rocks, aggregate the potential for leakage into the soils or water table, which could worsen the impact of climate change in ocean sinks as a major reservoir of carbon dioxide.

Since burning fossil fuels is the main reason for global warming, do we really need another coal power plant with CCS capability? Isn’t better to allocate federal tax credits and incentives for building energy storage or solar/ wind farms to generate electricity?

Recently, the average cost of solar energy has decreased by $2.71 to $3.57 per watt and the wind energy cost has dropped to around $30/MWh to $60/MWh in 2017. Solar battery energy storage technologies have also advanced and costs have declined by $400 dollars per kilowatt hour (kWh) to $750/kWh. Therefore, it is more viable and profitable to invest in the clean renewable energy to cut CO₂ emissions instead of building new coal power plants with CCS capability.

As a result of a growth in the world population and energy demand, greenhouse gas emissions are increasing and have accelerated climate change. In order to combat climate change, nations must shift their reliance away from fossil fuels to renewable energy instead of applying new technologies to produce “clean coal.” Relying on carbon capture and sequestration (CCS) technologies to rescue the world from climate change instead of focusing action on reducing greenhouse gas emissions is a dangerous gamble.

Posted in Climate Change, Coal, Health | Tagged carbon capture and sequestration, CCS, clean coal, climate change, negative emissions, Texas |

A Tale of Two Possible Cities: Fossil Fuels and Renewable Energy In San Antonio

June 12, 2018 by Briauna Barrera

CPS Energy’s Flexible Path plans to use fossil fuels until 2040 and beyond. The Wednesday, June 13th Public Hearing Session allows us an opportunity to speak up against fossil fuels and speak up for the well-being of our families, our communities, and our environment.

Common wisdom says that if something isn’t broken, don’t fix it. But in regards to the CPS coal-fired Spruce units, there is a broken and outdated system in dire need of fixing. There are a variety of reasons to switch to renewable energy; positive environmental, public health and economic outcomes chief among them. All of these are reasons to retire CPS Energy’s Spruce power plant.

Confronted with the changing tide of technology and the public’s favorable view of renewable energy, Synapse Energy Economics conducted an analysis comparing the costs of installing selective catalytic reduction (SCR) technology in the coal-fired Spruce 1 power plant. SCR technology reduces nitrogen oxide (NOx), a toxic gas compound that can be found in smog, cigarette smoke, and vehicle exhaust. But adding SCR to a coal plant is less effective than switching to clean energy technology (see Figure 11).

Rather than ridding Bexar County of coal plants and the costs they impose upon the environment and public health or investing in renewable energy and in our community, CPS plans to continue using an energy source known to increase rates of cardiovascular diseases such as asthma and heart disease, impair brain development in fetuses and lower life expectancy. Developed internally, without community input, the plan is called the Flexible Path.

The Climate Action SA coalition spoke out against this plan and called on CPS Energy leadership to involve the public in this important decision. A public hearing has now been scheduled for Wednesday evening:

WHAT: CPS Energy Public Hearing

WHEN: Wednesday, June 13th from 5:00 – 8:30 PM

WHERE: Villita Assembly Building (401 Villita St)

RSVP: http://bit.ly/CPSPublicHearingRSVP

The CPS Energy Board of Trustee meetings don’t normally include citizens to be heard. This makes the upcoming public input session all the more important to attend and speak at. CPS could benefit from another bit of common wisdom: an ounce of prevention is better than a pound of cure.

In addition to being a major source of pollution, the Spruce power plant isn’t economically viable. Last August, Synapse Energy Economics released a report evaluating the economics of the J.K. Spruce power plant and found it would economically benefit CPS – and by extension the taxpayer – to switch over to renewable energy.

They found that Spruce 1 lost more than $20 million during 2015 and 2016 and Spruce 2 lost more than $80 million in the past two years. Part of this loss in profits comes from the decrease in natural gas prices, but even if natural gas prices were to increase again and thus increase the economic viability of the Spruce units, it is likely Spruce 1 would never recover the costs of the SCR installation. The future for the Spruce units is likely one of ongoing economic costs, and those costs will be paid by San Antonio taxpayers.

Currently, almost 20 percent of our energy use comes from coal (see following table). In 2040, that percentage is estimated to drop by more than half, but the important thing to note is that in 22 years there is still estimates for coal energy use. CPS also plants to keep burning natural gas, another major contributor to climate change. And “flexible generation” is undefined, so that could also be fossil fuel-based.

Source: CPS Energy

Just being better than a theoretical “Traditional Path” isn’t good enough. By CPS projections, we will still use coal and other fossil fuels in 2040. We don’t have time to use coal for two more decades. Presently, there is a global increase in the occurrence and intensity of flooding, wildfires, hurricanes, heat waves, droughts and other extreme weather events. San Antonio, already one of the most flash-flood prone areas in the country, will experience more extreme droughts, heat waves, and flooding. Our city is becoming hotter and hotter, and as global temperatures rise and the heat island effect worsens, San Antonio will continue to become a sweltering desert of cement and asphalt.

We have the power to mitigate these consequences and contribute to the global effort of reducing and reversing the acceleration of climate change. We have the power to decide for ourselves to be the change we need to see. We have the power to demand more of CPS and of our local government. We have the power to become a 100 percent renewable energy city and challenge other cities to do the same.

We join our Climate Action SA partners in calling for the retirement of the Spruce coal plant by 2025 and a transition to 100% fossil fuel-free energy by 2030.

Renewable energy is increasingly favored by the public; wind and solar are now the cheapest energy sources in Texas; and renewable energy is unequivocally better for the wellbeing of people and the environment than coal and other fossil fuel sources.

It’s time we speak louder and we have a chance to do so this Wednesday, June 13th at the public hearing.

Come out. Speak up. Demand better. Our well-being, our communities, and our future depend on it.

Posted in Global Warming | Tagged Texas |

Energy storage coming into its own all over the world, but there are some issues in Texas.

June 11, 2018 by Citizen Carol

As renewable energy is expanding throughout the world in response to declining, insecure and climate changing fuel sources, the issue of intermittency has prompted the development and deployment of energy storage. Below are just a few examples:

Australia

Less than a month after Tesla Inc. unveiled a new backup power system in South Australia, the world’s largest lithium-ion battery has already been put to the test.

Reports today say that it appears to be far exceeding expectations. In the first three weeks alone, the Hornsdale Power Reserve smoothed out at least two major energy outages, responding even more quickly than the coal-fired backups that were in place to provide emergency power.

The area where the battery has been deployed in South Australia is in the grips of an energy crisis. In 2016, an outage left 1.7 million residents in the dark and storms and heat waves have caused additional outages. With the price of electricity soaring in Australia, this test of an industrial battery backup is being closely watched.

In March, Elon Musk vowed on Twitter to deliver a battery system for South Australia’s struggling grid. By early July, the state had signed a deal with California-based Tesla and the French-based energy company Neoen to produce the battery, and by Dec. 1, South Australia announced it had switched on the Hornsdale battery.

Fed by wind turbines at the nearby Hornsdale wind farm, the battery stores excess energy that is produced when the demand for electricity isn’t peaking. It can power up to 30,000 homes, though only for short periods — meaning that the battery must still be supported by traditional power plants in the event of a long outage.

Nonetheless, the Hornsdale reserve has already shown that it can provide what’s known as a “contingency or ancillary” service — keeping the grid stable in a crisis and easing what otherwise would be a significant power failure.

And, more important, the project is the biggest proof of concept yet that batteries such as Tesla’s can help mitigate one of renewable energy’s most persistent problems: how to use it when the sun isn’t shining or the wind isn’t blowing.

United Kingdom/Europe

In the UK, Pivot Power is not far behind, as they’ve just unveiled plans for an ambitious network of grid-connected energy storage and electric vehicle charging which could simultaneously balance supply and demand on the grid, and also provide electric vehicle rapid charging to hundreds of vehicles at once—without causing the kinds of surges in demand that naysayers were once so worried about.

Specifically, once built, the proposed battery network would be the world’s largest of its kind—consisting of 45 sites (already identified) with 50MW of stationary battery storage at each location. Each spot would be co-located with electricity sub-stations in order to maximize grid-stabilization services, but also happen to be near major towns, cities or roads—potentially supporting up to 100 rapid 150KW chargers, and even 350KW chargers once cars are around that can charge that fast.

Pivot Power is pretty explicit about their intention—and that’s to “accelerate the decline of petrol and diesel”.

If nothing else, it’s refreshing to hear clean technology advocates talking in such ambitious, absolute terms. Because there’s no doubt that this is what needs to happen in order to achieve a low carbon transition.

And for those folks who fear a shift from petrol/diesel car dependency to electric car dependency, it’s an encouraging sign that the Pivot Power network isn’t just focused on private car ownership. Alongside public charging, the network is also looking at providing services for “electric bus depots and bases for large transport fleets.”

The Middle East

There is increasing high-level interest in the potential for energy storage in the Middle East, with grid-connected systems forecast to reach 1.8GW in the region by 2025.

The region is at present a small market as far as energy storage and especially utility-scale advance battery energy storage is concerned. In fact, the majority of the Middle East’s installed base comes from just one project, a 108MW sodium-sulfur battery energy storage project for Abu Dhabi Electricity and Water Authority supplied by Japanese company NGK. While energy storage is in its infancy in the region, it is unlikely to remain so long term.

The UAE, Saud Arabia and Qatar are among the region’s countries that have enjoyed progress in solar PV in very recent times, with all of them adding significant utility-scale projects. Meanwhile Jordan, another of those countries to see large-scale PV rollout underway, signed a Memorandum of Understanding (MoU) for a 20MW battery-based energy storage system with AES Corporation in 2015.

Latin America

According to the World Economic Forum, energy storage in the form of large arrays of batteries is still in the early stages of deployment in Latin America. However, the role of electricity storage promises to become much more significant as the region diversifies its sources of power generation, and looks to batteries to help smooth out intermittent energy generation and mitigate the costs of peak demand.

Some policymakers and private companies in the region are already preparing for the rise of battery storage with test projects and new policies. In Mexico, General Electric has announced plans to develop five energy storage projects that will help integrate solar and wind projects into the grid. And in the Dominican Republic, two 10MW arrays of batteries, installed by AES Dominicana in August 2017, were credited with helping that country’s grid remain operational when Hurricane Irma struck a few weeks later.

Energy storage will affect the entire electricity value chain across Latin America as it replaces peaking plans, alters future transmission and distribution (T&D) investments, reduces intermittency of renewables, restructures power markets and helps to digitize the electricity ecosystem.

Africa: A great opportunity for a continent of developing countries

Namibia, a nation that’s considerably bigger than Texas but with only around 2.5 million people, installed almost 55 megawatts of generation from renewables and has projects under construction for another 121 megawatts, according to NamPower, the state-owned utility. However, the total installed capacity combined with committed renewable generation is reaching a threshold, at least until their grid can catch up.

This illustrates how intermittent power generation penetration hits limits in these nations before bigger investments are required in the power distribution network.

Technically, Nambia can handle about 275 megawatts of renewables, which is about half of the midday load according to a 2017 study. The country relies on imports for about 60 percent of its electricity, mainly from South Africa’s state-owned Eskom Holdings SOC Ltd., and even the import of baseload power does not guarantee grid reliability as some areas have daily power outages as a norm.

Africa presents huge opportunities for developers of renewable-energy plants, since wind and solar are quicker and sometimes cheaper to build than coal and natural gas plants. While renewable sources such as wind and solar can leapfrog traditional generation, they do not provide consistent 24-hour baseload electricity.

Namibia’s biggest domestic source of power is the Ruacana hydropower plant near the border with Angola. However, it has its own intermittency limit as it depends on the seasonal run of the Kunene River.

Reaching a bottleneck hasn’t deterred Namibia from adopting more renewables in the future as it aims to reduce power imports. The National Integrated Resource Plan includes an allocation for biomass power plants with capacity of as much as 200 megawatts.

Concentrated solar power is also called for in the plan. That technology concentrates the sun’s energy on heating a liquid that drives power turbines. Because the liquid can retain heat for a time after the sun goes down, those systems also can be used to store energy and deliver power to the grid at predictable times.

If African nations begin to adopt storage into their power distribution network, it could go a long way to stabilizing their grids and potentially their countries.

The USA

Stories like these are happening all over the globe. Right here at home, the Department of Energy recently awarded $20 million in funding for nine projects to advance early-stage solar power electronics technologies. The projects chosen were deemed critical to addressing solar photovoltaic reliability challenges, lowering the cost of installing and maintaining a photovoltaic solar energy system and achieving the DOE’s goal of cutting in half the cost of electricity for a solar system by 2030.

Three million was awarded to engineering researchers at The University of Texas at Austin to overcome the same dilemma of overcoming the issues of intermittency with renewables.

Experts from UT’s Cockrell School of Engineering have developed a way to integrate solar power generation and storage into one single system, effectively reducing the cost by 50 percent. The UT project will develop the next generation of utility-scale photovoltaic inverters, also referred to as modular, multifunction, multiport and medium-voltage utility-scale silicon carbide solar inverters.

Big Batteries Raise Texas-Sized Policy Questions at PUC

Utility-scale energy storage holds great promise both for energy conservation and grid reliability. But the quickly advancing technology also raises tough regulatory challenges, especially for complex power markets like that existing in Texas.

Look for a future guest blog post from Public Citizen’s retired director, Tom “Smitty” Smith on the history of deregulation in Texas and what the impacts of that policy change are having on this new technology.

Posted in Energy Storage, Global Warming | Tagged batteries, energy storage, Grid stabilization, Texas |

Climate Action SA Coalition Calls for CPS Energy to Phase out Fossil Fuels

June 6, 2018 by kaibawhite

SAN ANTONIO, Texas – Yesterday, a few days after the one-year anniversary of President Trump announcing US withdrawal from the Paris Agreement, the Climate Action SA coalition called on the City of San Antonio to establish significant goals to help San Antonio fight climate change.

Climate Action SA proposed the following goals for CPS Energy, our city-owned public utility: CPS Energy electric generation Coal-Free by 2025 and Carbon-Free (no fossil fuels) by 2030. Significant reduction in the reliance on fossil fuels can be achieved with aggressive investment in energy efficiency, demand response, renewable energy and energy storage.

These goals for CPS Energy put the city on a path to achieve of a goal proposed by Climate Action SA for city-wide greenhouse gas emissions to be reduced to net-negative by 2050 or sooner, following a path that prioritizes near-term reductions. Net-negative means that community activities would pull more greenhouse gases out of the atmosphere than they emit into it. This is assumed by almost all of the climate models used in the development of the Paris Climate Agreement.

Diana Lopez, Southwest Workers Union – photo by Angel Amaya

“The climate community in San Antonio is taking the right step towards including the neighborhoods most affected and creating solutions that are just, resilient, and keep the ecosystem of neighborhoods strong,” says Diana Lopez of Southwest Workers Union. “We are taking this beyond the Paris Climate Agreement and localizing action in San Antonio.”

The public health benefits of phasing out fossil fuels are well known. In addition to releasing carbon pollution which leads to climate change, coal and fracked gas produce pollution that creates ozone (smog) and particulate matter (fine soot), impacting vulnerable populations here at home the hardest.

“San Antonio is now failing federal air quality standards for ozone,” points out Peter Bella of imagineSanAntonio. “We insist on reductions in both carbon- and ozone-causing pollution, and SA Climate Ready provides the path.”

San Antonio can be a leader, but we don’t have to do it alone. Cities around the world are taking action to address climate change. The goals supported by the Climate Action SA coalition are necessary to avoid the worst of climate change and reflect the commitments in the resolution passed last June by Mayor Nirenberg and the San Antonio City Council to support the Paris Climate Agreement.

Keeping global temperature rise to between 1.5 and 2 degrees Celsius requires massive greenhouse gas reductions in the coming decade. The good news is that this transformation not only reduces local air pollution – it will also create new jobs and tax revenues.

Briauna Barrera, Public Citizen – photo by Angel Amaya

“Climate change is an existential threat and what we do in the next couple of decades will determine the fate of billions of people and future generations,” says Briauna Barrera of Public Citizen. “We need to ground ourselves in urgency. We need to be compelled into rapid, collective action to preserve a livable planet.”

Although ending our reliance on fossil fuels for power generation is key to solving the climate crisis, we must also be moving aggressively in other areas like transportation and solid waste. The coalition also plans to make recommendations on these topics soon.

The Climate Action SA coalition consists of 35 nonprofit organizations working together to support the creation and implementation of a robust climate action and adaptation plan for San Antonio, developed and implemented with strong community engagement. The coalition has a strong focus on protecting San Antonio’s most vulnerable communities from extreme weather and pollution, and ensuring that all members of the community can benefit from climate solutions.

Posted in Air Quality, Climate Change, Coal | Tagged climate action plan, climate change, Texas |

Chemical Safety Board: Arkema Knew of Flood Risk Well Before Harvey

May 25, 2018 by Citizen Stephanie

https://www.csb.gov/arkema-inc-chemical-plant-fire-/

U.S. Chemical Safety Board: Arkema Inc. Chemical Plant Final Investigation Report

Arkema Inc. knew about the risk of flooding at its Crosby facility.

That’s the conclusion of a new report by the U.S. Chemical Safety Board (CSB), which comes nearly a year after a fire and explosion at the facility injured twelve first responders.

Hurricane Harvey caused catastrophic flooding at Arkema Crosby, leading to the failure of backup generators and an explosion of organic peroxides on the premises.

The CSB report details the investigation and outlines best practices for future events. While the rainfall that occurred during Harvey was extraordinary, the report notes the rise in extreme weather events and Arkema’s location in the 100-year floodplain.

The report also finds that Arkema cannot claim ignorance of its precarious situation. A year before Harvey, Arkema’s insurer Factory Mutual Insurance Company (FM Global) notified the company of its flooding risk.

The CSB recommends more robust guidance to allow industry to better evaluate flood risks. The report also recommends that the EPA take more steps to limit risk from reactive hazards.

Chemical safety reform is needed to protect communities like Crosby. We shouldn’t be in harm’s way.

View the final investigation report at https://www.csb.gov/arkema-inc-chemical-plant-fire-/.

Posted in Air Quality, Climate Change, Harvey | Tagged Texas |

Ozone in the Woodlands? A Visit with Air Quality Researcher Dr. Jimmy Flynn

May 23, 2018 by Citizen Stephanie

In the greater Houston area, ozone season lasts from March to November. In 2018, we’ve already had 12 ozone action days. According to the Texas Commission on Environmental Quality, ozone action days are designated on warm, sunny days that are favorable to the formation of ozone, a compound that forms at near the ground in the atmosphere through complex reactions between nitrogen oxides and volatile organic compounds. While a lot of people think bad air quality occurs only in areas near the industry along the Houston Ship Channel, on some days readings at the ozone monitor near the Woodlands can be higher than at monitors along the Ship Channel. Public Citizen, along with Corey Williams from Air Alliance Houston, and a small group of Woodlands residents sat down with UH Professor Jimmy Flynn to learn more.

The Jones State Forest Air Monitor

University of Houston operates the Jones State Forest Air Monitor. The monitor is not part of TCEQ’s network of regulatory air monitors. It collects data on ozone, carbon monoxide, and meteorology. The monitor is attached to a tower and collects readings above the tree tops to help ensure that it is measuring ambient air quality.

Stagnant Air = Bad Ozone

Ozone is a harmful byproduct of a reaction between nitrogen oxides (NOx) and volatile organic compounds (VOCs). NOx and VOCs are emitted from transportation, industrial processes, and some natural processes. Ozone can cause serious problems especially for people who are already vulnerable, like children, the elderly, and people with pre-existing conditions.

One of the biggest risk factors for ozone formation, according to Dr. Flynn, is stagnant air. Stagnant air occurs when an air mass remains over a region for an extended period of time. There are no heavy breezes or precipitation to clear pollutants out of the atmosphere. Dr. Flynn also mentioned that for ozone in particular, rainfall events will not do much to clear ozone out of the air due to its lack of solubility. Ozone needs air movement to clear it out.

Do you know what to do on an ozone action day?

Learn how to protect yourself and your family when ozone action days occur. You can sign up for alerts through the TCEQ here. Dr. Flynn told us that staying inside on high ozone days is a great way to protect your health because ozone concentrations tend to be much lower inside. Stay safe!

Posted in Air Quality, Ozone | Tagged air monitoring, Air Quality, ozone, Public Citizen, Texas, the Woodlands |

What is Ozone Pollution and what is an Ozone Action Day?

May 17, 2018 by Citizen Carol

If you live in certain cities in Texas, including Austin, Dallas, and Houston, you may see that Texas sometimes calls “Ozone Action Days.” Ozone Action Days are hot, dry, sunny days when ground-level ozone is forecast to reach levels of health concern. Ground-level ozone (as distinct from the “ozone layer” of our atmosphere that protects us from the harmful rays of the sun) is one of six pollutants that are regulated by the Clean Air Act. These six common air pollutants are:

Particle Pollution (particulate matter or PM)
Ground-level ozone.
Carbon monoxide.
Sulfur oxides.
Nitrogen oxides.
Lead

The EPA uses the Air Quality Index (AQI) to notify the public about local air quality. Certain groups of people are especially vulnerable to air pollution including children, the elderly, and people with respiratory conditions such as asthma. When the AQI reaches levels of ozone pollution that are unhealthy for these sensitive groups, an “Ozone Action Day” is designated. This means that you should take steps to limit your exposure to air pollution and your contribution of pollutants.

The ozone forecast seasons are based on when each region is likely to experience elevated ozone concentrations. Some areas, like Austin, have an ozone season between March 1 to November 30th of each year. Other areas, like Houston, can have ozone days at any time throughout the year. Each forecast predicts whether ozone levels in the area are expected to reach or exceed the EPA’s AQI Level Orange (or a level that is “Unhealthy for Sensitive Groups”).

The Texas Commission on Environmental Quality (TCEQ) forecasts ozone pollution each day during ozone season. TCEQ sends its forecasts to the National Weather Service, which broadcasts them across its “weather wire.” You can get email or text notifications of these forecasts from TCEQ or EPA. You may hear local news station announce that today or tomorrow will be an Ozone Action Day.

Above are nonattainment and near nonattainment areas (counties) in Texas. It was derived from TIGER data, and it precisely matches the Texas Outline, Texas Counties and the TCEQ Service Regions layers. Nonattainment is an area that has not achieved compliance with the National Ambient Air Quality Standards (NAAQS). The ozone standard is currently set at 75 parts per billion (ppb). These nonattainment counties were designated by the U.S. Environmental Protection Agency (EPA). They are designated based on their air quality monitoring data. Near nonattainment means an area is very close to falling into non compliance with the NAAQS. These counties have been designated by the TCEQ Office of Policy and Regulatory Development for planning reasons. These counties either have an ozone monitor or are part of a metropolitan statistical area (MSA) that has an ozone monitor. It is very uncertain at this point which near nonattainment counties, if any, will ultimately be designated by the EPA as nonattainment. There are 16 ozone nonattainment areas in Texas: 8 counties in the Houston/ Galveston area (Montgomery, Liberty, Waller, Harris, Chambers, Fort Bend, Brazoria, Galveston); 3 in the Beaumont/Port Arthur area(Hardin, Orange, Jefferson); 4 in the Dallas/Fort Worth area (Denton, Tarrant, Dallas, Collin); and 1 in El Paso (El Paso). There are 25 ozone near nonattainment counties: 1 in the Victoria area (Victoria); 2 in the Corpus Christi area (San Patricio, Nueces); 9 in the San Antonio/Austin area (Williamson, Travis, Bastrop, Hays, Caldwell, Comal, Bexar, Guadalupe, Wilson); and 5 in the Tyler/Longview area (Upshur, Harrison, Smith, Gregg, Rusk), and 8 in the Dallas/Fort Worth area (Johnson, Ellis, Kaufman, Parker, Rockwall, Hunt, Hood, Henderson).

Posted in Air Quality, Ozone | Tagged Ozone Action Day, Texas |

A Visit to Houston and the Healthy Port Communities Coalition

May 15, 2018 by Adrian Shelley

Six years ago, Public Citizen and our partners founded the Healthy Port Communities Coalition (HPCC), which advocates for the health and well-being of residents of communities on the Houston Ship Channel. The coalition also includes Air Alliance Houston, the Coalition of Community Organizations, and Texas Environmental Justice Advocacy Services.

Recently, we had an opportunity to convene the HPCC in Houston to discuss our work. One purpose for the trip was to introduce our new Press Office, Angel Amaya, to Port Houston. Port Houston is the largest exporting port in the nation and the center of Houston’s petrochemical industry.

We started at Morgan’s Point Cemetery, the oldest continually operated cemetery in Harris County. It is the small green square in the middle of the photo above. Surrounding the cemetery is the Barbours Cut terminal and turning basin. This is one of two container terminals at Port Houston. Goods from all over the world come into Barbours Cut on very large vessels packed with shipping containers. One ship can carry as many as 4,500 containers. (There are even larger ships, the so-called “Post-Panamax” ships, that can carry as many as 9,000 containers, but they are too large to enter Barbours Cut.) The containers are offloaded by cranes (top of photo) and moved on to trucks and trains to be shipped around the country. Many of the engines that operate at a terminal like Barbours Cut–including marine vessels, cranes, short-haul equipment, drayage trucks, and locomotives–use polluting fossil fuels such as diesel. The Healthy Port Communities coalition advocates for replacement of these polluting vehicles with newer, clean technologies. Many funding opportunities are available for these replacements, including the Diesel Emissions Reduction Act and the Texas Emissions Reduction Plan.

A container terminal like Barbours Cut is probably what most people think of when they think of what goes on at a port. There is plenty of container traffic at Port Houston, but in fact this represents only about 15% of the total traffic.

The rest of the traffic consists of bulk products, most of them petrochemical. We visited many of the industrial facilities that produce these petrochemical products. One of the most infamous petrochemical facilities on the Houston Ship Channel is the Pasadena Refinery, owned by the Brazilian national oil company Petrobras.

Pasadena Refinery is notoriously troubled. In recent years, its woes have included explosions with injury, protests by environmental groups and concerned neighbors, lawsuits by environmental groups, and international bribery scandals. It was recently announced that Petrobras is trying to sell the refinery, although it is unclear who would want to buy such a dangerous liability.

We also visited Hartman Park in the community of Manchester, sometimes referred to as “Houston’s most polluted neighborhood.” Our friends at t.e.j.a.s. have advocated for years for the people of Manchester. When our new Press Officer Angel visited Hartman Park, she was struck by this mural:

Created by children living in Manchester, the mural perhaps unintentionally shows how intrusive polluting facilities are in the lives of people living on the Houston Ship Channel. An idyllic scene of children playing in a park is flanked by industrial stacks spewing pollution into the air. The mural is a stark reminder of what life is like for some of our most vulnerable neighbors in certain parts of Texas.

The Healthy Port Communities Coalition is advocating on the behalf of those neighbors who live in Houston. We finished our trip to Houston with a meeting of HPCC member groups. One topic of discussion was the Chairman’s Citizens Advisory Council (CCAC). The CCAC was created after the Port of Houston Authority Sunset Review in 2013. Public health advocates had asked for representation on the Port Commission itself, with the addition of a new seat representing community interests. That recommendation was rejected by the state legislature, although certain other reforms were implemented. After the sunset review was complete, some advocates continued to call for more representation of community interests at the port. Longtime port community advocate Sen. John Whitmire joined this call, asking the new Port of Houston Authority Chairman Janice Longoria to act. Chairman Longoria responded by creating the Chairman’s Citizens Advisory Council.

The Healthy Port Communities Coalition has had members and allies on the CCAC since it was created. Although we appreciated the move, in the years following we have not seen the CCAC be an effective body advocating for public health protections. This is in part due to the manner in which it was created and operates. In order to improve the CCAC, we have compiled a list of recommendations:

The existence of the Chairman’s Citizens Advisory Council (CCAC) should be codified in statute, regulation, or by memorandum.
The chairs on the CCAC should be designated for particular constituencies or neighborhoods, including the chair already designated for the Healthy Port Communities Coalition.
The representative for each chair should be selected by each corresponding constituency, via a process of their choosing.
The CCAC should have the authority to set agenda items for CCAC meetings.
CCAC members should be given time to make presentations at CCAC meetings. Port Houston should be required to formally respond to any presentations and answer any questions posed.
The CCAC should have the authority to make information requests and pose questions to Port Houston. The Port Commission should be required to respond.
The CCAC should be given monthly opportunities to report on its work to the Port Commission.
The CCAC should be able to recommend studies to be conducted by Port Houston. If Port Houston declines to undertake a recommended study, it should clearly state its rationale for doing so.

To her credit, Chairman Longoria did implement #7 above at the request of one of the CCAC members (a t.e.j.a.s. employee). But for the most part, the CCAC still functions as an isolated body whose members serve at the pleasure of the chairman. We believe that the above reforms would make the body a more effective advocate for portside community residents. This would lead to a port that took better care of its neighbors and served as a better steward of public health and the environment.

Posted in Air Quality, Climate Change, Gulf Coast Ports, Houston, Transportation | Tagged Texas |

Texas Cities Taking on Climate Change

May 10, 2018 by kaibawhite

Texas cities are stepping up to take on the climate change crisis. Austin was an early leader, but now San Antonio, Dallas and Houston are in the game too. Instead of waiting for leadership at the federal or state level, these cities are taking action.

Taking action at the city level makes a lot of sense. Cities are responsible for over 70% of global carbon dioxide emissions. When cities choose to act, they are often able to reduce emissions quicker than federal or state governments. Cities can tailor solutions to address specific local challenges, while also stepping up to support broader changes that are needed.

So how do cities take action? Any policy or program that reduces emissions is helpful, but the most effective way for cities to reduce emissions as much as possible is to develop a community-wide climate action plan.

There are several steps to this process:

GHG Inventory: Conduct a greenhouse gas inventory, following the Greenhouse Gas Protocol. This is an accounting of all emissions that the community is responsible for. At least scope 1 and 2 emissions should be included, and ideally scope 3 emissions as well.
GHG Reduction Goal: Establish a goal for reducing greenhouse gases. Establishing interim goals is helpful.
Stakeholder Process: Establish a community stakeholder process to develop recommendations. This should include outreach to the community at large.
Identify Actions: Identify actions to reduce greenhouse gas emissions throughout the community to meet the goal. Estimate expected emissions reductions, cost and time needed to implement for each action item. Identify co-benefits. Prioritize the list based on these factors.
Schedule Reports & Updates: Establish a schedule for progress reports and updating the climate action plan.
Release Draft Plan: Release the draft climate action plan for public comment.
Adopt Plan: Adopt the climate action plan.
Implement: Begin implementation of the plan, starting with priority items.
Report & Update: Report on progress made, as well as challenges at least as frequently as scheduled. Update the plan as scheduled, or more frequently, if needed.

Let’s take a look at where each of these Texas cities are in this process: Continue Reading »

Posted in Climate Change | Tagged Texas |

NRC Public Meeting on Holtec High-Level Radioactive Waste Storage Project – 85% of Speakers Oppose

May 1, 2018 by Citizen Carol

A packed room at the Roswell Public Meeting on the Holtec proposal. (Photo by Karen Hadden)

UPDATE 5/11/2018

Since the meeting in Carlsbad, NM, because of public pressure, the NRC has both scheduled two additional public meetings and extended the public comment period from May 29th to July 30th.

The May 21 meeting will be held at the Gallup Downtown Conference Center, 204 W. Coal Ave., in Gallup.

(UPDATE: 30 people spoke in at the Gallup public meeting all but one (a HOLEC employee) spoke in opposition to the proposed site)

The May 22 meeting will be held at the Crown Plaza Hotel, 1901 University Blvd., in Albuquerque.

(UPDATE: Over 200 people show up to the Albuquerque NRC meeting. 69 people spoke in total— 63 shared their opposition. Only 6 people spoke in favor of it.)

Both meetings are scheduled to run from 6-9 p.m., with an open house beginning at 5 p.m., for members of the public to meet informally with NRC staff.

You can still submit a comment letter until July 30th to the NRC from our action page. This letter is editable by you. We are still hearing that the NRC site is working intermittently so this is an alternative way for you to comment on this proposed site. Even if you live outside New Mexico but may be concerned that high-level radioactive waste might be transported though your community from the 104 nuclear power plants around the country to the proposed site, you should voice your concerns.

UPDATE:

A second public meeting was held Wednesday night in Hobbs, NM.
The third public meeting was held Thusday night in Carlsbad, NM
Due to conversations between citizens and the NRC after the Roswell meeting about the issues submitting comments via the NRC website, the NRC provided this email address as an alternative way for comment submission – Holtec-CISFEIS@nrc.gov

At the May 1 meeting in Hobbs, NM, 33 signed up and spoke in opposition to the Holtec proposed site. Only 13 spoke in favor of which there was a spokesperson from Holtec and one from ELEA. Others included the usual suspects (a few local state legislators and someone from the Chamber of Commerce as well as Xcel Energy, which owns two nuclear plants – Monticello Nuclear Generating Plant near Monticello, Minnesota, and Prairie Island Nuclear Generating Plant near Red Wing, Minnesota and currently stores the spent fuel from these nuclear plants on site in independent spent fuel storage installations. (ISFSIs). Both plants have licenses that run through 2033/34 and 2030, respectively and are probably hoping to have off site storage available when the plants are decommissioned). There is one final public meeting in Carlsbad this evening.

At the final May 3rd meeting in Carlsbad, NM, 34 citizens spoke in opposition and turned in 1300 comment letters opposing the siting of the Holtec proposed interim high level radioactive waste dump in New Mexico. Twenty seven spoke in favor of the proposal. One of these was pro-Yucca dump, pro-WIPP, and pro-nuke, but skeptical of Holtec.

In addition to the public comments on the proposal itself, at least one individual has pointed out issues with the process.

Specifically, the NRC has not had information in Spanish available before the hearings in this highly Hispanic, Low English Proficiency (LEP) area. This has been the subject of not only a Title VI complaint to EPA, a recent complaint to NMED, numerous comments on various facilities to NMED and to NRC as well as litigation. There is at least a 15 year history outlining the need for information in Spanish in this area. NRC should have been aware of this before even considering licensing a facility in Southeastern New Mexico and certainly before starting the public process for the Holtec application.

Questions were asked about Spanish outreach and public notice done by NRC in the state about these hearings and the licensing process for this facility? Was there any public notice in a language other than English? Without enhanced public notice in Spanish (and possibly in various Native languages as well as oral notice in communities where this is the primary way of communicating), a significant portion of the people of New Mexico have been left out of the public process for this facility. At this time there has been no detailed response from NRC to these questions.

A large portion of the people of the state will be impacted by the transportation phase of this project. More than 60% of the people of the state are Hispanic, Native American or African American and 35.7% of the population speaks a language other than English in the home. These New Mexicans should not have been eliminated from the public process for this facility.

Yesterday, April 30th, the Nuclear Regulatory Commission (NRC) hosted an open house in Roswell, New Mexico on a controversial high-level radioactive waste storage project, proposed for a site between Hobbs and Carlsbad. The open house was followed by a public meeting which included an opportunity for public comment. There were over 95 in attendance, filling the room to capacity, causing the local fire marshall to close the doors to additional attendance. Community members from around the state showed up to oppose the storing of the nation’s high-level nuclear waste in southeast New Mexico.

There are many reasons for opposing this dangerous plan and 36 spoke in opposition citing various reasons for their objections that included:

Concerns about the health, safety and financial impacts of this controversial high-level radioactive waste storage project on surrounding communities and communities along the transportation routes.
Impact of potential contamination on local dairy and pecan farms, tourism and oil and gas industries that employ more than 15,000 people for a project promising just 55 local jobs
It’s a train wreck waiting to happen. Over 10,000 overweight rail cars would carry this waste to the site, and the waste would likely go very near the Carlsbad sinkhole
The federal government may never find a permanent place for this waste, potentially leaving it here forever in a site designed for temporary storage.
This isn’t our waste, and we didn’t get the power from the nuclear reactors that produced it. Those near existing reactors know the risks and don’t want the waste. Why should we take it?

There were only 6 who spoke up in support of the proposal, one was a Holtec spokesperson and the other five were University of New Mexico nuclear engineering students.

Holtec seeks “interim” storage of the nation’s deadly high-level radioactive waste, which they anticipate will be for 120 years. An unsafe de facto permanent dump site could be created and the waste might never move again if there is no political will or inadequate funding in the future for a permanent waste site. The company plans to transport 10,000 canisters of irradiated reactor fuel rods from around the county and store them near the surface in New Mexico, inviting disaster and creating massive risks. This is more waste than has been created by all U.S. nuclear reactors to date.

“There is everything to lose with this plan to bring the nation’s high-level radioactive waste to New Mexico. The risks to health, safety, security and financial well-being are immense and people need to act now to stop this massive mistake that imperils people in New Mexico as well as along transport routes throughout the country,” said Karen Hadden, director of the Sustainable Energy and Economic Development (SEED) Coalition, who has been working with local opposition groups for months opposing this application and a similar one just across the border in Andrews County, Texas.

There are two other opportunities for New Mexican citizens to comment in a public forum

Tuesday, May 1st Hobbs 7-10 pm
Lea County Event Center, 5101 N. Lovington Highway

Thursday, May 3rd Carlsbad 7-10 pm
Eddy County Fire Service, 1400 Commerce Street

In addition, comments can also be submitted at www.regulations.gov, Docket ID NRC-2018-0052; or by mail, to May Ma, Office of Administration, Mail Stop: TWFN–7– A60M, U.S. Nuclear Regulatory Commission, Washington, DC 20555– 0001.

Some folks have been having problems submitting their comments through the NRC website, but we have a request in to NRC to get an email address where folks can submit their comments directly. That update is at the top of this post.

You can visit these websites for more information on High-level radioactive waste:

Posted in Nuclear, Radioactive Waste | Tagged Texas |

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UPDATE: The EPA has extended the public comment period for this rule. You can now submit your comments by an August 23rd deadline:
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