This commentary is a response to a recent article in the pages of Green Source DFW on 'The Air Out There - The Quest for Clean Air in DFW', pollution and ozone levels in Dallas Ft. Worth.    

July 6, 2012

1) "The downward trend" that Mr Clawson of TCEQ says has only been "interrupted," is, in fact continuing, and he knows this because it's TCEQ monitoring that's proving it. This last March saw the highest ozone levels ever recorded for that month since TCEQ air quality monitoring began in 1997. It's only June, and there are already two monitors whose three-year runing average "Design Value" is above the old 85 ppb standard. The "best ever" ozone summer we were supposed to experience this year, according to TCEQ's prediction to EPA submitted in December, is completely off the rails.

2) The "87 ppb" Design Value Mr. Clawson cites is from 2010. Last year it was 92 ppb – at the Keller monitor. This year so far, the Keller monitor is already at a Design Value of 87, a violation of the old standard and something TCEQ said would not happen.  

3) The NCTCOG claim that,"the DFW region has a tougher time than other metropolitan areas in the U.S. because of its climate plus its position downwind from outside sources of pollution" is also misleading. Houston is a hotspot for bad air, and yet last year DFW exceeded the number of bad air days and the severity of the violations in that city. Other metropolitan ares downwind of power plants as well as DFW, and yet they've all managed to do better in achieving cleaner air. Atlanta, Phoenix, and other Sunbelt cities that started out at the same smoggy spot a decade ago have all conquered the old 85 ppb std. DFW has not. It's already blown it again this year. Instead of blaming climate or coal plants, it is more realistic to blame DFW's air quality failure on a lack of political will by local and state officials to get serious about decreasing air pollution.

However, there is one large area of policy where the excuses of lack of will and new downwind sources collide – in the official lack of attention paid to the rise of Barnett and Haynesville Shale gas pollution as a source of smog in DFW.

4) The statement that only "5 percent" of the smog-forming emissions in DFW come from oil and gas drilling and production is also highly misleading. First, we know this is one of the fastest-growing categories of air pollution over the last decade. The increase in gas pollution is erasing decreases in emissions from other sources. Second, according to the information submitted by TCEQ to EPA last December, oil and gas emissions are the second largest source (20%) of smog-forming Volatile Organic Compounds, or VOCs in the 9-county DFW non-attainment area. That's more than the total VOCs produced by all on-road vehicles in the same 9 county area. Based on recent field studies by NOAA and others, this is probably an underestimate.

This statement also ignores the impact of gas emissions to the south and east of DFW, like Freestone County's, that are not included in the 9-county area inventory, but are probably influencing air pollution here.  

What's always left out of this pie chart is the fact that cars now have a removal efficiency of approximately 90%. No other major sources come close to that kind of effort, despite technology being available to achieve it – at cement kilns, gas operations. and coal plants. That's where "the lowest hanging fruit" remains. But since all those industries are large contributors to the politicians directing the status quo, there's no political will to target them. Exhibit A: the 2011 DFW clean air plan submitted by the state, which relies primarily on marketplace forces to replace old cars with new ones, instead of any new round of pollution controls for any industry sources.

5) The NCTCOG claim that "monitors in the north Dallas and Frisco areas have had the highest readings of the region but the plume seems to be shifting west" is also based on old data. In fact, the opposite is occurring. Violating monitors are moving EAST (just like gas mining). And there are more of them. From 2008 to 2010, Eagle Mountain Lake and Keller were the epicenter of smog in DFW. But in 2011, while Keller tripped the std, EML did not. Moreover, during that same 08-10 period there were only 1-3 monitors in violation of that std. Last year, there were seven. And they included not just Keller and Parker County, but Denton, Grapevine, Pilot Point, Frisco and North Dallas – directly in contradiction to the NCTCOG claim.

This year, the very first monitor to record four "exceedances" of the 85ppb std was located near Mockingbird and I-35 in Central Dallas – the first time that monitor has done so since 2005. Moreover, the fourth exceedance came in June – the earliest that has happened since 2006, when 12 out of 19 monitors were in violation at the end of the summer.

As much as the officials and agencies would like us all to ignore the summer of 2011 and think of it as an aberation, it would be more prudent to see it as another warning sign that DFW needs to do much more to get safe and legal air.

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