1. Houston Air Quality Challenges John D. Wilson Galveston-Houston Association for Smog Prevention www.ghasp.org

2. Changes to TCEQ Plan Re-submits relaxed industrial NOx standards Backs off commitments to reduce mobile emissions Drops vehicle I/M for semi-rural counties Drops commercial lawn care rule Re-submits / strengthens industrial HRVOC cap Uses an annual sitewide cap + hourly limit (rather than a daily cap) Updates grant program (TERP) Adds statewide gas can rule

3. Scientific / Technical Issues Failure to model “level red” ozone –Houston is one of two areas with a “level red” design value (182 ppb for one-hour) –None of the modeling days were “level red” in the model ORVOC emissions (butanes, propane, xylenes, etc.) –No adjustments –No controls Annual cap / hourly limit (prefer daily cap) Consider aircraft data (gaps in surface data) Accuracy of emission event data

4. Evaluating the Plan Nitrogen Oxide Emissions in Tons per Day Other Traffic Industry 2007 Current Plan 376 2007 Proposed Plan 489 32% 36% 2010 Los Angeles Plan 530 Houston plans for more than twice the per capita traffic emissions of LA * Need to rethink transportation system Houston allows three times more industrial emissions * Should cut further Slightly lower emissions from construction, heavy equipment, rail, shipping, aircraft... * Need more local and federal effort 26% 36% 38%

5. Highly Reactive Petrochemicals (HRVOCs) 0 25,000 Reported Industrial Emissions (2000) EPA Toxic Release Inventory 6,500 tons Tons Released Ethylene, Propylene, Butadiene, Butenes TCEQ “Ozone Season” Inventory 11,000 tons Measured Industrial Emissions (2000) “Capped” Industrial Emissions (2007) TCEQ 2004 Model Inventory 63,000 tons 50,000 TCEQ Proposed Site-Wide Emissions 16,400 tons

6. New Science on VOCs Industry (75%) Trees, Shrubs, Swamps (8%) Equipment, traffic, etc. (17%) Analysis of 1998-2001 TCEQ Air Monitoring Data: VOCs Measured by Potential to Form Ozone (Not Mass) Trees, Shrubs, Swamps (69%) Industry (14%) Equipment, traffic, etc. (17%) 1996 TCEQ Emissions Inventory: VOCs Reported by Mass

7. Houston Pollution is Unique OH Reactivity – Top 10% of NOAA Aircraft Samples 0 5 10 15 20 NashvilleNYCPhoenixPhiladelphiaHouston Methane Carbon Monoxide Formaldehyde Vegetation Petrochemicals NO x (ppb) : 253513214

8. Evaluating the Plan VOC Emissions Measured by Potential to Form Ozone (MIR) Harris Co. E - San Jac. M. Baytown W Harris Co. E - Galena Park Harris Co. E - Deer Park Harris Co. E - Shoreacres Harris Co. NW - Dyess Park Houston SW - Bayland Park Texas City - 17th Brazoria Co. South - Clute Galveston Island Airport Projected w/caps Capped hydrocarbons Uncapped hydrocarbons “Typical” urban areas

9. A Complete Clean Air Plan Industrial ORVOC Controls East Harris County NOx controls Trucks and Traffic Zero-tolerance enforcement for speeding trucks in East Harris County Accelerate diesel reflash program Registration program for diesel truck idling locations, with backup system for enforcement of idling rule (scaled back) Expand eligibility for diesel emission control grants (TERP) Press region for new long-term transportation system plan Other Eliminate loopholes for small diesel generators Develop innovative reduction strategy for marine vessels

10. Houston Air Quality Challenges John D. Wilson Galveston-Houston Association for Smog Prevention www.ghasp.org