TALKING POINTS FOR CLEAN AIR HEARINGS
IT'S TIME TO EXPRESS YOUR CONCERN FOR CLEANER AIR
Because DFW’s air is still in violation of the Clean Air Act for ozone, or smog pollution, the Texas Commission on Environmental Quality (TCEQ) must submit a new plan to clean it up to EPA by June 2007. The TCEQ has written a draft plan that is now subject to public comment.
Nothing will show the TCEQ, Governor Perry, state regulators, and the state legislature that the public wants a more effective plan for better air quality like your testimony in person at these hearings. Bring your children, your asthma medication, and your stories about how bad air quality has affected your life.
TALKING POINTS -- WHAT THE PLAN LACKS AND NEEDS
1. The plan misses its goal, barely achieving a technical legal solution with no margin of error. It needs to reach the clean air goal with room to spare in order to protect public health.
The TCEQ plan falls short of the requirement for cleaning up the air by the federal Clean Air Act deadline of 2010, with at least two ozone monitors, in Frisco and Denton, predicted by the state to still register levels over the federal limit. A federal provision allows states to argue that their plans are close enough to the goal to deserve approval by the Environmental Protection Agency. And Texas is using that "close enough" clause to seek approval of the Dallas/Fort Worth plan. “Close enough” does not protect public health.
Read the Dallas Morning News editorial on the failure of the plan to reach the goal
(http://www.dallasnews.com/sharedcontent/dws/news/texassouthwest/stories/112206dntexsmogplan.32b4ead.html
2. The proposed plan uses an ozone standard allowing up to 85 ppb when scientific
experts are suggesting that air plans at 80 ppb are not even protective enough of
human health. DFW’s new air plan should address a higher standard of 60-70 ppb.
In 2006, the EPA’s Clean Air Scientific Advisory Committee (CASAC), a group of 23 independent science and medical experts, recommended that the current 8-hour ozone standard (80 ppb) is not protective enough of human health and recommended that a stronger standard of 60 to 70 ppb be adopted. (see the recommendation letter at “http://www.epa.gov/sab/pdf/casac-07-001.pdf”)
For more information on this lack of protection for public health, read this article in the Dallas Morning News (http://www.dallasnews.com/sharedcontent/dws/news/localnews/stories/120306dntswunhealthyair.3369cdd.html)
3. The TCEQ plan requires only the industry-supported scheme of a 40% emission reduction from nearby Ellis County cement plants, while an 80 to 90% emission reduction is achievable through cost-effective, available technology.
The proposed plan lets the Midlothian cement plants off the hook...again. This is the second state clean air plan to not require state-of-the-art controls on the cement plants. While letting ozone levels remain at dangerous levels, the air plan doesn’t demand advanced controls on the Midlothian cement plants. These three Ellis County cement plants produce half of all smog pollution emitted by industry in the entire North Texas region. These plants already raise DFW smog levels 3 times as much as ALL the 18 proposed new coal plants combined.
A recent state report concluded that pollution from the cement plants could be cut by 80 to 90% through cost-effective and available technology. State computer modeling shows adding these controls could significantly cut ozone levels in DFW. Yet the TCEQ is ignoring this technology, and is supporting an industry backed plan requiring only 40% reductions from the cement plants. For more information on this report and how the state is ignoring it, read this article in the Ft. Worth Weekly. (http://www.fwweekly.com/content.asp?article=4200)
4. The proposed plan doesn't require existing power plants whose pollution blows into the DFW area, but are located outside of our 9-county nonattainment region, to clean up as much. TCEQ should require the same standards of power plants located outside the non-attainment area as those units located in DFW’s non-attainment area.
Because a key source of emissions leading to elevated background ozone concentrations entering the DFW area is power plants in East and Central Texas, it is critical to require that all major electric generating sources in East and Central Texas meet fuel-specific emission requirements comparable to those in place in the DFW and Houston/Galveston nonattainment areas.
5. The proposed plan DOES NOT address the proposed coal plants. The projected impacts on the DFW area should be fully explored with at least the latest "clean coal" technologies applied to any pending or new power plant permits.
Nothing in the new plan anticipates the emissions of the 18 proposed coal plants that Governor Perry has ordered fast-tracked through the permitting procedure. No one with the state has modeled the cumulative effects to DFW smog levels of all these plants. These plants will not be equipped with the latest "clean coal" gasification technology that would reduce both smog and global warming gases. While TXU promises to reduce emissions by a total of 20%, they won't say how they plan to do that.
6. The TCEQ plan doesn't require stricter auto emission standards. Texas should adopt California Clean Car standards.
Regulators are always quick to blame cars for DFW's smog problems, yet they have never required Texas vehicles to adopt the strict smog-cutting auto emissions standards of California. These California standards would cut smog pollution significantly from one of the largest sources of pollution in North Texas, without adding significantly to the cost of new cars. Since Texas is one of the largest car markets in the U.S., adopting California Clean Car standards would also move the entire country closer to these cleaner new standards.
7. A Better Plan Is Already Written
Last October, the North Texas Clean Air Steering Committee, a body of local elected officials, Chambers of Commerce and environmental groups passed a series of 13 resolutions on what the new DFW clean air plan should have in it, including advanced controls on the cement plants, tougher emissions standards on all new coal plants, and California auto emission standards. To read their resolutions, go to this web site and download the pdf. (http://www.nctcog.org/trans/committees/ntcasc/index.asp).
FOR MORE INFO – AND TO SEND YOUR COMMENTS
You can view the background of the DFW area air problems, strategies and plans for cleaning the air, including the proposed TCEQ plan at http://www.tceq.state.tx.us/implementation/air/sip/dfw.html
If you can't attend these public hearings, please send your comments by Feb. 12th, 2007 to:
Joyce Spencer
Texas Commission on Environmental Quality
P.O. Box 13087, Austin, TX 78711-3087
Project number 2006-034-117-EN
Let Governor Perry know about your concerns regarding the DFW air plan. Send them to:
Honorable Rick Perry
Office of the Governor
P.O. Box 12428
Austin, TX 78711-2428
Because DFW’s air is still in violation of the Clean Air Act for ozone, or smog pollution, the Texas Commission on Environmental Quality (TCEQ) must submit a new plan to clean it up to EPA by June 2007. The TCEQ has written a draft plan that is now subject to public comment.
Nothing will show the TCEQ, Governor Perry, state regulators, and the state legislature that the public wants a more effective plan for better air quality like your testimony in person at these hearings. Bring your children, your asthma medication, and your stories about how bad air quality has affected your life.
TALKING POINTS -- WHAT THE PLAN LACKS AND NEEDS
1. The plan misses its goal, barely achieving a technical legal solution with no margin of error. It needs to reach the clean air goal with room to spare in order to protect public health.
The TCEQ plan falls short of the requirement for cleaning up the air by the federal Clean Air Act deadline of 2010, with at least two ozone monitors, in Frisco and Denton, predicted by the state to still register levels over the federal limit. A federal provision allows states to argue that their plans are close enough to the goal to deserve approval by the Environmental Protection Agency. And Texas is using that "close enough" clause to seek approval of the Dallas/Fort Worth plan. “Close enough” does not protect public health.
Read the Dallas Morning News editorial on the failure of the plan to reach the goal
(http://www.dallasnews.com/sharedcontent/dws/news/texassouthwest/stories/112206dntexsmogplan.32b4ead.html
2. The proposed plan uses an ozone standard allowing up to 85 ppb when scientific
experts are suggesting that air plans at 80 ppb are not even protective enough of
human health. DFW’s new air plan should address a higher standard of 60-70 ppb.
In 2006, the EPA’s Clean Air Scientific Advisory Committee (CASAC), a group of 23 independent science and medical experts, recommended that the current 8-hour ozone standard (80 ppb) is not protective enough of human health and recommended that a stronger standard of 60 to 70 ppb be adopted. (see the recommendation letter at “http://www.epa.gov/sab/pdf/casac-07-001.pdf”)
For more information on this lack of protection for public health, read this article in the Dallas Morning News (http://www.dallasnews.com/sharedcontent/dws/news/localnews/stories/120306dntswunhealthyair.3369cdd.html)
3. The TCEQ plan requires only the industry-supported scheme of a 40% emission reduction from nearby Ellis County cement plants, while an 80 to 90% emission reduction is achievable through cost-effective, available technology.
The proposed plan lets the Midlothian cement plants off the hook...again. This is the second state clean air plan to not require state-of-the-art controls on the cement plants. While letting ozone levels remain at dangerous levels, the air plan doesn’t demand advanced controls on the Midlothian cement plants. These three Ellis County cement plants produce half of all smog pollution emitted by industry in the entire North Texas region. These plants already raise DFW smog levels 3 times as much as ALL the 18 proposed new coal plants combined.
A recent state report concluded that pollution from the cement plants could be cut by 80 to 90% through cost-effective and available technology. State computer modeling shows adding these controls could significantly cut ozone levels in DFW. Yet the TCEQ is ignoring this technology, and is supporting an industry backed plan requiring only 40% reductions from the cement plants. For more information on this report and how the state is ignoring it, read this article in the Ft. Worth Weekly. (http://www.fwweekly.com/content.asp?article=4200)
4. The proposed plan doesn't require existing power plants whose pollution blows into the DFW area, but are located outside of our 9-county nonattainment region, to clean up as much. TCEQ should require the same standards of power plants located outside the non-attainment area as those units located in DFW’s non-attainment area.
Because a key source of emissions leading to elevated background ozone concentrations entering the DFW area is power plants in East and Central Texas, it is critical to require that all major electric generating sources in East and Central Texas meet fuel-specific emission requirements comparable to those in place in the DFW and Houston/Galveston nonattainment areas.
5. The proposed plan DOES NOT address the proposed coal plants. The projected impacts on the DFW area should be fully explored with at least the latest "clean coal" technologies applied to any pending or new power plant permits.
Nothing in the new plan anticipates the emissions of the 18 proposed coal plants that Governor Perry has ordered fast-tracked through the permitting procedure. No one with the state has modeled the cumulative effects to DFW smog levels of all these plants. These plants will not be equipped with the latest "clean coal" gasification technology that would reduce both smog and global warming gases. While TXU promises to reduce emissions by a total of 20%, they won't say how they plan to do that.
6. The TCEQ plan doesn't require stricter auto emission standards. Texas should adopt California Clean Car standards.
Regulators are always quick to blame cars for DFW's smog problems, yet they have never required Texas vehicles to adopt the strict smog-cutting auto emissions standards of California. These California standards would cut smog pollution significantly from one of the largest sources of pollution in North Texas, without adding significantly to the cost of new cars. Since Texas is one of the largest car markets in the U.S., adopting California Clean Car standards would also move the entire country closer to these cleaner new standards.
7. A Better Plan Is Already Written
Last October, the North Texas Clean Air Steering Committee, a body of local elected officials, Chambers of Commerce and environmental groups passed a series of 13 resolutions on what the new DFW clean air plan should have in it, including advanced controls on the cement plants, tougher emissions standards on all new coal plants, and California auto emission standards. To read their resolutions, go to this web site and download the pdf. (http://www.nctcog.org/trans/committees/ntcasc/index.asp).
FOR MORE INFO – AND TO SEND YOUR COMMENTS
You can view the background of the DFW area air problems, strategies and plans for cleaning the air, including the proposed TCEQ plan at http://www.tceq.state.tx.us/implementation/air/sip/dfw.html
If you can't attend these public hearings, please send your comments by Feb. 12th, 2007 to:
Joyce Spencer
Texas Commission on Environmental Quality
P.O. Box 13087, Austin, TX 78711-3087
Project number 2006-034-117-EN
Let Governor Perry know about your concerns regarding the DFW air plan. Send them to:
Honorable Rick Perry
Office of the Governor
P.O. Box 12428
Austin, TX 78711-2428
posted by Downwinders At Risk at
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