CEC Newsletter May 1996
by Galveston-Houston Association for Smog Prevention
Recently EPA scientists, after an extensive review of the medical literature, recommended that the federal ozone smog health standard be changed, noting that the current standard does not adequately protect public health. The current standard is a maximum of 0.12 parts of ozone per million parts of air (0.12 ppm) averaged over one hour and not to be exceeded more than once a year averaged over three years. They suggested that a new standard be established between 0.07 and 0.09 ppm averaged over eight hours, with between one and five exceedances per year averaged over a three-year period. The final decision on a standard is expected to be made this summer.
In response to the EPA's request for feedback on this recommendation and the range of options presented, the Texas Natural Resource Conservation Commission (TNRCC) developed a so-called "Texas Plan" that, taken as a whole, would create an ozone standard far less protective of health than anything recommended by the EPA. This plan is not only an embarrassment to all Texans because of its open disregard for public health and the sloppy thinking that underlies the proposal, but is especially scary for Houston area residents who already breathe the second highest ozone levels in the nation - levels that would almost assuredly worsen were the Texas Plan to be enacted.
Why? Because the Texas Plan is not about health. Rather, it is a largely undisguised attempt, using mathematical manipulations, to average away our high ozone levels. Applied to last year, for example, the Texas Plan cuts the number of days the Houston area exceeded the standard by approximately half - from 63 under the current EPA standard to 32 under the Texas Plan, without removing one molecule of pollution.
The plan itself? Part of the Texas Plan - a maximum level of 0.08 ppm ozone averaged over eight hours with no more than five exceedances per year averaged over a three-year period - falls within the guidelines put forth by the EPA. While much of the medical establishment and many countries feel this level still does not protect health (for example, in Europe the eight-hour standard is 0.05 - 0.06 ppm with no allowed exceedances), this much of the plan could at least be argued for based on public health. Not so the remainder of the Plan.
First, the Texas Plan would use five years - and then delete the high and low years - to derive the three-year average. This would mean that our worst years, such as 1995, would no longer count. Remember now that the ozone standard is solely about health, about what level of ozone people can reasonably breathe without getting sick or dying. Deleting the high and low years would mean that children, outdoor workers, exercisers and others who struggle with asthma, pneumonia or even die during "high pollution" years simply do not count. If anything, it is the high pollution years on which our pollution reduction strategies need to focus. After all, in health terms these years are the most catastrophic.
In Los Angeles, approximately 1,600 people die each year from breathing outdoor air pollution. Although no similar figures were available at press time for the Houston area, last year's ozone pollution eclipsed all other cities in the U.S. except L.A which had approximately one third more exceedance days than we did (98 to our 63). Thus it is not unreasonable to postulate slightly over 1,000 deaths last year in the Houston area due to air pollution. And this ignores the asthma, the bronchitis, the pneumonia, the sinus headaches and other pollution-related illness that sidelined so many area residents so many days of the year.
An even more distressing feature of the Texas Plan is composite averaging. Composite averaging would average together the hourly ozone levels from all monitors in the area (approximately 7 to 12 monitors give valid data each hour and these are spread out throughout the eight-county area), and then derive the eight-hour average from the composite averages. In effect, the TNRCC is saying, "Look. All we have to do is average those pesky monitors showing high pollution with a bunch of monitors showing low pollution (and perhaps install a few extra monitors in rural areas) and then average everything again and voila! no pollution."
The TNRCC even offers a Houston-based example. On August 19, 1993, three monitors exceeded the current federal standard for multiple hours, with the highest one-hour reading being 0.231 ppm in the Aldine area. This is well over the current standard of 0.12 ppm. The eight-hour average at that monitor was 0.125 ppm, well over any of the eight-hour average levels proposed by the EPA. But under the Texas Plan, the ozone level is calculated to be 0.077 ppm - a safe level according to the TNRCC's proposal.
The TNRCC argues that composite averaging will encourage more monitors in the Houston-Galveston area because many local governments refuse to install monitors for fear that they will show high levels of pollutants and thereby reflect poorly on the community. If this is true, changes need to be made - but not by composite averaging. The sole concern in siting monitors should be public health, yet GHASP notes with rue that of the 28 new monitors the TNRCC is proposing statewide, 15 will be in rural areas - and none in the Houston-Galveston region, where pollution is at its worst.
Finally, the Texas Plan proposes something called "Individual Monitor Mitigation Strategy." Residents in areas where ozone levels exceed 0.12 ppm, averaged over one hour, would be notified so that they could take measures (such as staying indoors) to protect their health. Monitors that exceeded 0.12 ppm more than five times in a year would be targeted for additional monitoring and analysis.
Sounds good?
Guess again. Ozone is not a hot-spot pollutant. Ozone forms from precursor pollutants in the presence of sunlight, and routinely travels considerable distances. According to the TNRCC's figures, 12 monitors in the Houston area exceeded the 0.12 ppm standard more than five times in 1995. Hot-spot mitigation is meaningless in the Houston area, It is only a way to appear to care about people who must breathe the high levels of pollution that composite averaging otherwise makes invisible.
One aspect, however, of the mitigation plan is an important addition to EPA's proposal, and that is requiring notification of area residents when a high one-hour reading occurs. Currently, most cities warn residents when ozone smog approaches or exceeds the one-hour 0.12 ppm federal standard, and many schools cancel outdoor activities. It is imperative that we keep a one-hour standard in addition to the eight-hour standard EPA is likely to adopt (a dual approach most countries have taken), or that we make certain another mechanism is in place to warn residents when outdoor levels of ozone smog reach unhealthy levels.
The TNRCC's Texas Plan is an embarrassment and should be withdrawn from the national forum. It is sad to know how little our state leaders care about the health of Texans. And once again it is the health of Houston-area residents that will bear the brunt of this indifference.
Action Item! We urge you to contact state officials on this critically important issue. The three TNRCC commissioners, appointed by Governor Bush to establish overall agency direction and policy, are Barry R. McBee (chair), R. B. "Ralph" Marquez, and John M. Baker. They can be contacted at the TNRCC, P.O. Box 13087, Austin, Texas 78711-3087 (513-239-1000; FAX 512-239-1500). An e-mail comment form to the TNRCC is available on its web site at http://www.tnrcc.state.tx.us/. In addition, citizen concerns can be given to the TNRCC citizen ombudsman at 800-687-4040. Governor George W. Bush can be contacted at State Capitol, P.O. Box 12428, Austin, Texas, 78701 (512-463-2000 or 800-252-9600). An e-mail comment form to the Texas capitol is available on the state's web site at http://www.texas.gov/.
The Galveston-Houston Association for Smog Prevention (GHASP) is a local citizen group working to improve the quality of the air we breathe. For more information, call Ron Parry at 713-669-1195 or visit our web site at http://www.neosoft.com/~ghasp/sites.htm.
Texas Ozone Plan an Embarrassment,
Threatens Health of Area Residents