Galveston-Houston Association for Smog Prevention - Syndicate Planning & research feed

Train engine emissions

John Wilson — Tue, 17 Oct 2006 16:50:21 -0700

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There are two main classes of railroad locomotives: long-haul and short-haul, or switcher, engines.

Many locomotives in the Houston region used for switching and other short-haul purposes have been replaced with cleaner engines with funding from the Texas Emission Reductions Plan (TERP).

There have been some complaints from others that railroads get a lot of funding from TERP, but do not pay much into this fund as do other classes of grant recipients. In response, railroad officials have commented that they do pay vehicle registration fees and some other fees. Furthermore, the railroad officials say that they provide a greater cost-share than other types of projects.

Railroad companies have also commented that they are on a path to upgrade their equipment ahead of expectations, which will result in emission reductions. In general, they believe that the amount of air pollution they release into the air is overstated by the emission inventory models.

However, the emission inventory models are highly simplistic and do not reflect actual measurements of emissions in the Houston region, nor do they include very specific data about the nature of Houston-area operations. So these emissions inventory data may be quite inaccurate.

Texas Emission Reduction Plan

John Wilson — Wed, 04 Oct 2006 12:54:09 -0700

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The Texas Emission Reduction Plan is one of the most efficient pollution control programs in the Houston region, and must be continued and expanded if Houston is to achieve clean air. Although cost-effective, the TERP is going to fall well short of the binding commitment made to achieve 38.9 tons per day of nitrogen oxide (NOx) emissions reduction in 2007. As of August 2006, the TCEQ reports only 17.7 tons per day of NOx reduction through the TERP, with no further scheduled grants to be awarded. Texas has met only 46% of its commitment to achieve pollution reductions through the TERP.

Presently, the TERP includes two main funding methods that primarily affects diesel vehicles and equipment that are present in the Houston region (or other eligible counties in Texas) for the vast majority of their operating time. There is also a major research program, and several other programs (not described below) with limited activity.

The Emission Reduction Incentive Grants program funds projects that reduce NOx emissions. Eligible projects may include purchase or lease, replacement, repower (replacing the engine with a cleaner-burning model), retrofit (add-on of emission-reduction technology), or on-vehicle electrification and idle reduction. The affected equipment may include heavy-duty vehicles, marine vessels, locomotives, or equipment (non-road and stationary) - basically anything that burns diesel except small equipment and light-duty vehicles.The program may also fund infrastructure for refueling (for qualifying fuel) or on-site electrification (for idle reduction).

In the Houston region, the TCEQ has awarded $162 million in grants since 2002, at an average rate of $4,468 per ton of NOx reduction. If fully spent, the awarded grants will reduce 16.9 tons per day of NOx. The vast majority of funds have been spent to replace heavy-duty vehicles (trucks and buses) and locomotives.

The Rebate Grants program funds the repowering or replacement of non-road and on-road vehicles and equipment. In 2006 (its first year), the program spent $7.7 million at a fixed reimbursement rate of $5,500 per ton. If fully spent, the awarded grants will reduce 0.8 tons per day of NOx by replacing 134 old model dump trucks, tractor trailers and haul trucks, replacing 1 forklift, and repowering 1 piece of diesel equipment.

The New Technology Research and Development program provides financial incentives to encourage and support research, development, and commercialization of technologies that reduce pollution in Texas through the issuance of state funded grants. Its history has been somewhat problematic, being administered by the University of Texas at first, then by the TCEQ, and now by the Texas Environmental Research Consortium. GHASP supports TERC's new general direction for the program, which is to seek integration of the California technogy program (which emphasizes reductions of soot) and the EPA technology program (which emphasizes new engines) with the goals of Texas (which emphasize NOx and older model engines).

Support for the TERP has generally coalesced in the Texas Clean Air Working Group, and GHASP has supported the recommendations of this group and collaborated with government and business to ensure the necessary laws, funds and regulations are available to ensure that the TERP succeeds.

The Texas Legislature should fully fund TERP

On March 10, 2006, TCEQ staff formally reported to the Commission that the TERP will fall well short of its binding commitment to fund 38.9 tons per day of emissions reductions in the Houston region, and well short of its commitment for the Dallas-Fort Worth region as well. (The attached excerpt from the Commission meeting handouts is a bureaucratic read-between-the-lines report of this fact.) One of the reasons for this shortfall is that the Texas Legislature has not appropriated all funds collected to fund the TERP for expenditure - they're holding some of the money in the bank. GHASP has been told that the TCEQ misrepresented to the Texas Legislature that it would meet the targets with the funds appropriated under instructions from the Governor's office, but we have not been able to document that claim.

The 2007 Texas Legislature must begin to make up the shortfall by fully appropriating all funds collected for TERP to its programs.

Simplfy TERP and focus on cost-effectiveness

The initial TERP legislation set cost-effectiveness as the primary criterion for allocating funds, but also set in place various floors, ceilings and other limitations on specific uses of the funding. There were valid reasons for those limitations, but the TERP track record indicates that many of those limitations may now be removed without concern.

The TCEQ has set mandatory cost-sharing percentages that may discourage otherwise cost-effective projects from being proposed. In the future, the selection process should rely strictly on cost-effectiveness based on eligible grant funding and disregard other expenditures.
The TERP limits infrastructure grants to 3% of total TERP funding. This cap should be eliminated or substantially raised so that such projects may compete head-to-head on cost-effectiveness.
The TCEQ should determine baseline emissions from the engine being removed during a repower.

The TCEQ should work with the Houston-Galveston Area Council to formally integrate CMAQ and other available pollution-reduction grant programs into the TERP application process by using a single application form and then distributing funds from the different funding sources according to each sources' guidelines to achive the most cost-effective overall expenditure of grant funds.

The TCEQ should add new grantmaking strategies

The 2005 Texas Legislature modified the TERP to include a rebate program, and it is clear from the initial results that this is a feasible method of reaching previously-untapped opportunities for pollution control. While a good start, the two primary grant programs offered by the TCEQ are not effectively attracting some types of pollution control projects. Enhancements are needed to reach small-to-medium businesses who might consider repowers, retrofits or add-ons during routine or unexpected maintenance, and to encourage manufacturers to provide technologies to serve this market.

Successes of existing grant strategies

The Emission Reduction Incentive Grants program (described above) is most effective at working with large companies who can mange the technical complexity of the grant application program and are sophisticated enough to work with technology vendors to understand the pollution control opportunities currently in the marketplace. In the Houston region, just thirteen companies and one government agency are responsible for two-thirds of the emission reductions attributed to TERP.

Four companies and Metro received $43 million to reduce emissions from trucks and other equipment by 5 tons per day. These projects included all the options available under TCEQ rules (retrofits, repower, replacement, and on-site infrastructure).
Three railroad companies received $62 million to reduce emissions from locomotives by 4 tons per day, generally through replacement of older model locomotives.
Six marine companies received $11 million to reduce emissions from inshore vessels (e.g., tugboats) by 2 tons per day, generally through repower (replacement of older model engines).

These companies are to be commended for stepping forward and dealing with the complications and delays during the early stages of TERP.

The Emission Reduction Incentive Grants program is also effective at funding replacement and repower projects through small-to-medium sized companies, particularly in the cargo handling and construction industries. Both the Emission Reduction Incentive Grants and the Rebate Grants programs have reached small companies with haul trucks, dump trucks and freight trucks, primarily with repower and replacement project. These projects are planned well in advance and reflect business decisions related to equipment that might otherwise be maintained.

Shortcomings of existing grant strategies

One opportunity that is being missed is to reduce emissions from vehicles or equipment that has been brought in for routine or urgent maintenance service. During such service visits, the owner is certain to be unwilling to file a complex grant application and wait days (or months) for an answer. If a program could be provided to offer that equipment owner an emission reduction choice on the spot, it could achivieve highly cost-effective emission reductions.

Another opportunity that is being missed is to provide a direct market signal to major engine and equipment manufacturers to offer retrofits to older model vehicles. Major manufacturers are under significant pressure to produce low-emission engines to meet EPA standards for new equipment, and have not placed as much emphasis on offering choices to reduce emissions from older model engines. For many types of large equipment, feasible repower engines are not available, it is not cost effective to replace the entire piece of equipment, and owners are understandably reluctant to purchase after-market equipment that may affect the service or warranty eligibility of their equipment or vehicle.

Ideas for improving TERP grant strategies

Direct engagement with major manufacturers seems to be the most feasible path towards making emission reduction grants available in "real time" and sending better "market signals" to major engine manufacturers. In early 2006, GHASP suggested the following concept.

The TCEQ could offer performance contracts to major diesel engine manufacturers to achive emissions reductions based on achieving substantial reductions in emissions across the entire fleet of engines in Houston, Dallas-Fort Worth, and other nonattainment regions of the state. The performance contract would allow a manufacturer to achive emissions reductions using any qualified technology, but would not include specific technology commitments up front. In order to be paid under the program, a manufacturer would have to achive a contract-specified minimum pollution reduction each year.

Hypothetically, the state might estimate that a manufacturer had about 22 ton per day (tpd) of emissions in the Houston region and, based on some reasonable projection of engine types and technology potential, that it might be possible to reduce emissions to 10 tpd over six years. The manufacturer might be challenged to reduce a minimum of 1.0 tpd at a rate of $5,000 per ton, with a bonus of an additional $100 per ton for each 0.1 tpd that the contract minimum is succeeded. So if the manufacturer certified reductions of 2.0 tpd, the grant would be paid for $6,000 per ton.

Equipment owners would be reached directly by the manufacturers, who could work through their service centers, parts distributors and other repair facilities. From the owner's perspective, the emission reduction project (whether retrofit, replacement or repower) would function in practice more like a voluntary recall than a government grant program.

Manufacturers would be required to transparently audit their program to determine that it is achieving the desired goals, and that factors such as replacing little-used equipment, importing of equipment into the eligible region, and other 'tricks' are not offsetting the claimed emission reductions.

A benefit of this manufacturer-based grant program concept is that it would give the market an immediate and large incentive to supply better engines and aftermarket devices. Third-party companies would now have the benefit (and challenge) of selling their aftermarket devices directly to the original equipment manufacturer rather than to the equipment owners.

A more limited variation on this concept would be allow manufacturers or distributors to apply for a grant to offer a specific number of emission reductions activities (repowers, replacements, or retrofits) at a fixed rate. This would be similar to the existing rebate program, except that rather than receiving the funds directly from the TCEQ, the equipment owner would work directly with a vendor who has pre-authorization to undertake the emission reduction activity for the agreed class of equipment and specific technology application.

Under this coupon-style rebate program, the manufacturer/distributor would be responsible for establishing a system to ensure that the maximum number of activities allowed by the grant is not exceeded, and would be required to refund the unexpended grant within a specified time if the goals of the grant were not achieved.

In contrast to the existing rebate program, however, the TCEQ would not set the value of the rebate in advance. The applicant would propose a cost-effectiveness value in response to an Emission Reduction Incentive Grant program application opportunity and would compete against other applications on an equal basis.

Another related issue is the administrative capacity of the TCEQ in handling the paperwork associated with the TERP grants. There has been widespread (but muted) criticism of paperwork delays that have affected the finances of grant recipients who are ultimately responsible for payment. One issue may be the legislative cap on the number of employees at the TCEQ, which may have resulted in understaffing of administrative functions.

Potentially, the administrative responsibility for the TERP program might be transferred to another state agency with a strong track record of administring grant programs. The TCEQ would retain statutory responsibility for setting the environmental performace objectives and audit standards.

An emission testing center for heavy-duty vehicles and equipment is needed

The Texas Clean Air Working Group has encouraged the state to establish one primary center and four low cost satellite centers around the state to:

test emissions from heavy-duty vehicles and off-road machinery to support pre-screening of new technologies,
provide durability tests of TCEQ approved technologies,
support a voluntary emissions testing program for heavy-duty vehicles/machines,
ultimately pilot test a structured emissions testing program for on-road diesel vehicles.

GHASP supports this TCAWG proposal.

Seek emission reductions from older large gasoline powered cars and trucks

In 2005, the TCAWG recommended a new program to reduce emissions from SUVs, pickup trucks and delivery vans. Other than the AirCheck Texas Inspection and Maintenance (I/M) program, Texas is not reducing emissions from older model, large vehicles of these types. GHASP supports legislation to authorize the TCEQ to implement this program when it becomes cost-effective compared to other alternatives.

Considering model years 1988 through 1995, there are 418,025 of these gasoline powered trucks registered in the eight county Houston Galveston (HGA) non-attainment area, and 348,348 of these trucks in the four county Dallas-Fort Worth (DFW) non-attainment area. These vehicles are estimated to emitt 5,069 tons per year of NOx in HGA and 4,163 tons per year in DFW. That is approximately 13.9 tons per day HGA and 11.4 tons per day in DFW.

TCAWG members estimated that a program targeting these vehicles could reasonably be expected to reduce NOx emissions by 1.5 tons per day in the Houston region (and 1.3 tons per day in the Dallas-Fort Worth region). The proposed program would provide rebates for installing low cost emissions control technologies on internal combustion engine powered vehicles and equipment. Rebates could range from $50 to $400, depending on the typical NOx emission rate of the vehicle being improved, and would be available for technologies and vehicles qualified for the program by the TCEQ based on expected emissions reduction.

While this program could be funded with TERP funds, it would probably need to be integrated into the Clean Air Plan (or SIP) by considering its impact using MOBILE6, the computer model used to estimate vehicle emissions, since it would not be practical to implement the usual TERP methods for verifying vehicle use given the large number of low-value rebates that would be offered.

Container port emissions (Bayport, Texas City and Morgan's Point)

John Wilson — Fri, 29 Sep 2006 07:43:16 -0700

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The TCEQ's emissions estimates for container port operations are a subject of some controversy. Its SIP development has assumed one container port would be built, but the US Army Corps of Engineers permitted construction of two facilities.

If both facilities are built as represented in the US ACE permit documents, the resulting air pollution will be about 20 tons per day of nitrogen oxides, or about 6% of projected regional NOx pollution.

This estimate is just the emissions from operations at the port (cranes and other cargo handling equipment). Diesel truck, train and ship emissions are not included.

On the positive side, the Port of Houston Authority has at times been an "early adopter" of emission reduction technology, such as PuriNOx low-emission diesel fuel (an emulsified fuel) and purchase of cargo handling equipment using selectic catalytic reduction emission control devices (SCR).

Pollution control strategies - an overview of (potential) SIP measures

John Wilson — Thu, 28 Sep 2006 08:32:38 -0700

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The Clean Air Plan for Houston, formally known as a State Implementation Plan, describes how the Texas Commission on Environmental Quality expects pollution control measures to result in clean air for Houston. Those pollution control measures are adopted by both the federal and state (typically the TCEQ, although some measures are adopted by local governments or other state agencies) governments.

Federal pollution control measures

The federal government has primary authority for pollution caused by transportation sources, commercially available engines, and other commercially available products. Where the Clean Air Act places responsibility in the hands of the federal government, it alone may regulate the emissions rate for such equipment and products (there is a special exception for California).

The federal government also directly regulates the emissions of hazardous air pollutants. In the case of many industrial emissions that contribute to the formation of ozone (and other criteria air pollutants such as PM_2.5), these regulations may overlap significantly with pollution control measures adopted by the state.

State pollution control measures

The state government has primary authority for regulating major industrial "point sources" of air pollution. It may also regulate certain products sold in the state if they are not already regulated by the federal government. It may also regulate the use of products that cause air pollution, even if those products are separately regulated by the federal government.

A state government may also establish separate pollution standards that are more health-protective than the federal government, but Texas has generally avoided establishing such standards. The most important exception is that Texas has a nuisance rule.

Local governments may enforce many state regulations. Municipalities may also adopt local regulations; this is rarely done in Texas.

Emissions inventories - measures of air pollution releases

John Wilson — Thu, 28 Sep 2006 08:16:00 -0700

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Emissions inventories are used to represent the present and future amount of pollution released into the air. Typically, emissions inventories are maintained by the TCEQ in five separate databases.

Industrial (point source)

Industrial emissions inventories are calculated using either approved measurement methods or approved emissions estimate factors; these figures are assembled by the TCEQ into a point source emission inventory.

Traffic (mobile on-road)

The Houston-Galveston Area Council is a focal point for developing an inventory of emissions from traffic. A recent regional inventory is described in its transportation conformity decision.

Other transportation (mobile off-road)

Mobile off-road emissions data for airports & planes, ships, trains and other sources of pollution considered to be mobile are calculated using emissions factors and other methods by the TCEQ.

Small equipment (area sources)

A wide variety of small sources of air pollution are lumped together in the area source category. In Houston, these sources typically play a less significant role in causing air pollution than industrial and transportation sources.

Trees and shrubs (biogenic)

The relative importance of emissions from trees, shrubs and other vegetation is often a subject of intense scrutiny. To the extent that these sources can be implicated as a cause of air pollution, some interested parties believe that they can then claim that pollution is "natural". When estimated by mass over a large region, biogenic emissions can appear quite large. However, in the absence of other human-caused pollution, the chemicals released by vegetation are pleasant to smell and fairly harmless. The TCEQ has a description of biogenic emissions and we provide additional information on emissions from wildfires and vegetation.

Ozone SIP: 2006 version

John Wilson — Wed, 27 Sep 2006 10:46:55 -0700

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The Texas Commission is drafting pollution control strategies to be formally proposed on December 13, 2006. The proposals include a plan (the Houston-Galveston-Brazoria (HGB) 8-hr Ozone Attainment Demonstration State Implementation Plan, 2006-027-SIP-NR) and associated rules. Under EPA rules, the plan must "demonstrate attainment" with the 8-hour ozone standard by 2010. The plan covers what is formally called the Houston-Galveston-Brazoria nonattainment area (Brazoria, Chambers, Ft. Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties).

In order to reduce ozone exposures in the Houston region, emissions of nitrogen oxides (NOx) and volatile organic compounds (VOCs) must be reduced. The amount of ozone smog pollution formed in Houston is a complex function of the amounts of pollutants released, weather patterns, effects of other air pollutants (such as carbon monoxide and chlorine) and many other factors. While the complex equations governing air pollution in the Houston region will never be fully understood, we do know enough to reduce NOx and VOCs, and protect public health.

An effective strategy to solve Houston's air pollution requres the reduction of both NOx and VOCs. Because the most intense pollution is formed in the plumes of air pollution that originate in the Houston Ship Channel and nearby industrial areas, the sources located in those areas must be effectively targeted by the strategy.

Sources of air pollution that are more characteristic of urban (rather than industrial) areas are also important to control, but somewhat less critical. Compared to other major cities, Houston is relatively less affected by the transport of air pollution from other parts of the state and nation - we breath our own pollution, mostly.

The types of strategies that will solve Houston's air pollution problem include, in order of importance:

New and more restrictive regulations on regulated sources of air pollution, particularly chemical plants and refineries;
Expanded grant and incentive programs for sources of air pollution that cannot be directly regulated, particularly diesel trucks, trains and other equipment;
New regulations and innovative strategies for reducing pollution from ships and trains that are not easily reached using grant and incentive programs;
Better verification of existing and new pollution control programs; and
Policy changes to encourage less-polluting behavior by drivers and other consumers of polluting equipment.

Through mid-2006, the Houston-Galveston Area Council was the lead agency managing the process for developing proposed pollution control measures for the 8-hour SIP. Much of the TCEQ and H-GAC work in this area came to a gradual halt in fall 2006, probably because the most feasible pollution control measures would target industry.

Nevertheless, the studies produced an extensive record of the proposed pollution control measures affecting transportation and other mobile sources and those affecting major industrial (point) and other non-mobile (area) sources. A major conceptual flaw in the approach of these studies was that the consultants were instructed to ignore potential pollution control measures that required federal government action to implement - even if a federal-state partnership might be contemplated. These studies also looked only at short-term benefits of the programs, which severely limited the potential of many beneficial measures.

New and more restrictive regulations on chemical plants and refineries

The most important step that the state could take to improve air quality in the Houston region is to reduce industrial NO_x allowances by 50% (possibly only in east Harris County). Industry has created a formidible sense that such a step is impossible, blocking even study of the status of industrial pollution control or the potential for further controls by the TCEQ. Industry influence has even prevented the most basic evaluation of the performance of the allowance trading system.

The second major class of regulatory changes needed are more extensive regulation of VOC emissions from chemical plants and refineries. While 2006 is the deadline for complying with new regulations restricting the emission of highly reactive VOCs by chemical plants and refineries, these regulations must be extended in some way to include other VOCs that play a major role in causing ozone smog in the Houston region. In 2006, the TCEQ initiated several rulemaking projects to address this issue - but then 'inactivated' all but one project to develop new VOC emission controls.

Beyond regulatory changes, the state could also rethink its (nonexistent) strategy for dealing with operational practices in plants - at the root of this problem is often unhelpful attitutdes of employees. One of the reasons this is a problem in the Houston region is the underfunding of the field office of the TCEQ. Without sufficient employees to be a visible presence in the major chemical plant and refineries, environmental protection becomes more a paperwork exercise rather than a matter of personal responsibility.

Key operational practices include the real-world decisions about when to shutdown units for repairs to leaks and pollution control problems, and whether plants consider air quality in process management planning. (A counter-example is the systematic presence of safety considerations in many companies' process management planning.)

A related issue is the presence of older, outdated equipment. Often permitted under lax rules during the 1970s and 1980s, some companies view the continued operation of such equipment as an entitiement, even if it is prone to occasional high-pollution accidents. The state almost never challenges the status quo, even at permit renewal.

Another shortcoming of the state's permitting program with real impacts on our pollution level is the use of sitewide (or 'flexible') permits. While acceptable in theory, in practice such permits are almost impossible to enforce due to the lack of accountability for specific problems at the plant. In order to enforce a sitewide permit, the state's legal position is that it must do a comprehensive sitewide evaluation - which is beyond the capability of its limited field investigation staff. We simply don't know whether plants with these types of permits are in compliance - we just know that they say they are.

Beyond the focus on the major chemical plants, refineries and power plants, the TCEQ should review industry sectors that have gotten little recent attention to identify additional pollution reduction strategies. Light manufacturing, plastics fabrication in particular, should be the subject of a field study to identify issues that may have been overlooked from a regulatory or enforcement perspective. We suspect, but do not know, that such efforts may yield useful pollution control strategies.

Expand the Texas Emission Reduction Program

The Texas Legislature should enact an immediate increase in TERP funds. Several changes are also needed to this effective program to continue its cutting-edge momentum in reducing air pollution.

While businesses with large fleets and large public agencies have made effective use of TERP, small and medium-sized businesses often find the program too administratively complex and not well suited to the nature of their operations. Texas should fund coupon programs to allow equipment owners to obtain standard, pre-qualified pollution reduction upgrades without having to go through a cumbersome appliation process.

Texas governments should try to do business with clean contractors. The City of Houston has adopted a "Clean Contracting" incentive for its public works contracts. These programs should be expanded as a means of rewarding those contractors that go to the trouble to upgrade their fleet with low-emission vehicles and equipment.

Texas should collaborate with other states to press for a nationwide cleanup of railroad engines. If those states most closely linked to Texas by rail freight traffic joined together, they could require a certain percentage of freight rail traffic to be hauled using cleaner engines. Presently, the only pollution reductions that have been made by rail companies have been to switch to lower emission engines for local trips and switchyard activities.

Develop new regulations and strategies for reducing ship, train and aircraft emissions

Texas should adopt a "no net increase" policy for emissions of NOx and VOCs by ocean-going ships calling on Houston region ports. There are a number of ways this might be accomplished, but to date there has been an insufficient amount of effort directed towards solving this problem.

The most aggressive efforts to reduce pollution from ships are being made in the Puget Sound (Washington) and Los Angeles (South Coast) areas. While the types of ships and issues in these areas are somewhat different than in Houston, it is notable that these areas have made progress while our region has not.
One concept that GHASP has suggested is to strictly limit the daily number of ships that may call on Houston-region ports during air pollution episodes, giving priority in the queue to ships that meet low emission standards.
Another concept advanced by GHASP is to focus on those specific ships that make a relatively high frequency of calls per year to Houston-area ports. There are a number of ships that service the chemical industry, travelling among the different chemical plants along the Texas and Lousiana Gulf Coasts.

Many intercoastal ships use marine distillate fuels that are very similar to Grade No. 1-D or Grade No. 2-D diesel, which are not covered under the current definition of diesel fuel. The state is considering a revision to 30 TAC 114 (2006-036-114-EN) to cause further reductions in NOx in coastal areas of counties where Texas low emission diesel (TxLED) is required. GHASP strongly supports removing what amounts to a loophole in the TxLED rule.

GHASP has also opposed the excessive and poorly planned expansion of the region's container port facilities.

While it would be quite difficult or impossible to cause airplanes to reduce emissions of NOx while aloft, it would be very useful and practical to seek reductions in emissions while airplanes are on the ground. Houston airports and airlines should examine taxi way operating practices to determine if airplanes could be moved with less fuel consumption and hence less air pollution. For example, the FAA is studying the use of auxiliary power for taxi use at the DFW airport.

Emissions from rental car shuttles has already been reduced at Intercontinental Airport by consolidating shuttles. This concept could be extended to Hobby Airport and to remote parking lots at both airports.

Over the past decade, the freight handling strategy pursued by Houston area governments can be summed up in one word: more. There has been little attention given to the air pollution impacts of government subsidies to the freight movement industry intended to attract as much freight handling activity to the Houston region as possible. As an economic development strategy, using scarce public dollars to subsidize bringing more pollution to Houston 'stinks.'

The Houston region should undertake a regional freight movement study with the objective of determining how freight can be moved more efficiently, causing less air pollution. There has been discussion of using barges to move containers to smaller regional ports so that truck and rail traffic could be diverted from the congested industrial corridors. There has not been study of whether a regional freight rail system might help reduce pollution from trucks by getting freight cargo closer to its destination before being loaded onto trucks for the final leg of the journey.

Better verification of existing and new pollution control programs

One of the major issues with existing pollution control programs is the failure to accurately reflect their impact, and to instead rely upon the initial projections of their effectiveness. Since Texas and often the US EPA systematically underfund enforcement and implementation efforts, programs are more likely to be underachievers rather than over achievers.

A particularly compelling example is the diesel truck reflash program, which is intended to bring a large number of highly polluting diesel trucks into line with the emissions regulation they were supposed to meet at manufacture.

Several programs that affect average citizens are also of questionable effectiveness because they have not been verified.

The public is well acquainted with the vapor recovery systems at gasoline stations, known as Stage II systems. There are proposals to repeal the requirement to maintain these systems because it is believed, based on unverified projections, that their benefits are no longer significant. In theory, the majority of the on-road vehicle fleet is now equiped with on-board vapor recovery systems that prevent the emission of vapors during refueling.

To verify the actual effectiveness of these vapor recovery systems, environmental investigators could use special cameras that can detect such vapors at low concentrations to determine how effective these systems may be. Then actual data could be used to determine if the systems need improvement or if, indeed, it does make sense to retire now-unnecessary equipment.

Likewise, the state assumes that the vehicle inspection and maintenance program is as effective as computer models predict. While the state collects vast data from roadside inspections, it has not analyzed those data to answer the simple question, how well is AirCheck Texas working?

A new gas can rule requires use of low emission gas cans for lawn care equipment, etc. This equipment actually pays back the owner in saved fuel over the lifetime of the can. However, it is unclear whether the new cans are being stocked by stores, whether there is a trade in now-illegal cans, and whether the projected replacement rates are being met in practice.

Less-polluting behavior by citizens and smaller businesses

While Houston Metro is working on extending light rail service, comparatively less investment has been made in promised enhancements to bus service. Bus service can be enhanced more quickly and with more immediate air pollution benefits than light rail (which represents a long term investment that has potentially greater benefits). The TCEQ should work with Houston Metro to identify new funding sources, or needs to submit to the Texas Legislature, to fund rapid deployment of signature bus service, bus rapid transit and enhanced marketing/passenger information systems.

Many businesses, institutions and even apartment or condominium buildings own and operate backup diesel generators or other types of stationary diesel engines. The emissions and operation of this equipment may be regulated by Texas, but it has chosen to regulate this equipment quite lightly. Equipment located in the industrial and urban areas of Houston should be regulated to set a maximum emission rate (phasing out older, more polluting equipment rapidly) and a limit on use (total number of hours). Equipment should also be regulated for its placement near sensitive sites such as intakes for building HVAC systems.

Forklifts are a significant source of air pollution. The state should consider adopting California requirements for retrofits or replacement to eliminate the most polluting equipment. The Texas Railroad Commission would play a key role in such regulations.

Environmental Defense is leading an initiatve to reduce air pollution caused by truck idling. Truck stop electrification, such as the system promoted by IdleAire, is a promising new technique that is cost-effective for truck drivers and owners, reduces regional air pollution, and mitigates the nuisance of large truck stop facilities for nearby neighbors. Steps should be taken to accellerate the introduction of this technology, including penalties for facilities that move slowly.

The TCEQ has considered adopting regulations on consumer and commercial products to reduce VOC emissions (Rulemaking 2006-007-115-EN), but has made that project inactive.

The proposed rule would require that certain VOC-containing products sold, offered for sale, supplies, distributed, or manufactured for use in Texas meet specified VOC content limitations.

GHASP has not researched this proposal and is uncertain whether such a rule would significantly reduce air polluiton in the Houston region.

Odors - dealing with the nuisance of industry

GHASP — Fri, 22 Sep 2006 07:50:23 -0700

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Concerns about odors are well-founded. Unpleasant odors are often an indication that dangerous pollutants are in the air.

Even if the odors don't indicate danger, they can make people ill or at least cause people to curtail activities. How about that picnic to celebrate a 50th wedding anniversary being canceled?

A good resource for information on odors is the Global Community Monitor website. GHASP collaborates with this organization from time to time.

TexAQS II in town

SStrawn — Mon, 18 Sep 2006 07:18:55 -0700

Houston is home, at least temporarily, to another 200 scientists from 60 different institutions. All have come here in the second effort in a decade to characterize Houston's smog problems. The first air quality study (actually a number of separate efforts all under one umbrella) confirmed industry's role in ozone formation here and led to greater recognition and controls on highly reactive volatile organic compounds.

As for this effort, University of Houston professor Barry Lefer notes

that the efforts of TexAQS-II will be a good test to see how industry has cleaned up since the first TexAQS initiative six years ago. In this second air quality study, he said, UH scientists are determining what the photochemical processes are, which ones are most important and what the best strategy is to solve the problems.

Hundreds of air quality scientists converge on Houston

John Wilson — Thu, 07 Sep 2006 07:00:25 -0700

On Monday, August 21, more than 200 scientists began what will be a month-long study of air quality in the Houston-Galveston region. It's the second Texas Air Quality Study (known as TexAQS II), and is similar to the study that occurred here in 2000. Researchers will be measuring the weather patterns and levels of air pollutants that cause ozone and soot (particulate matter).

This major research event was recently covered in The Baytown Sun.

You'll find the scientists spread all over Houston. Some will work at major land-based sites at the University of Houston and in the Williams Tower. Others will travel in five aircraft, which will conduct fly-overs of the region taking air pollution measurements. And some will even sail around Galveston Bay and the Gulf of Mexico aboard the Ronald H. Brown.

Air Quality Forecasting

John Wilson — Thu, 24 Aug 2006 13:23:26 -0700

The University of Houston has announced the availability of an online ozone smog forecasting tool. Â

With the intent to not only increase public awareness, but also help Texas manage air quality issues, the Institute for Multi-dimensional Air Quality Studies (IMAQS) at UH has been operating an air quality forecasting system for a year that has been tested, fine-tuned and now determined ready for public use. Over the course of this past year, the system has been expanded and improved to serve the entire eastern half of Texas, including the Houston and Dallas metropolitan areas.

Galveston-Houston Association for Smog Prevention - Syndicate Planning &amp; research feed

Train engine emissions

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Texas Emission Reduction Plan

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The Texas Legislature should fully fund TERP

Simplfy TERP and focus on cost-effectiveness

The TCEQ should add new grantmaking strategies

Successes of existing grant strategies

Shortcomings of existing grant strategies

Ideas for improving TERP grant strategies

An emission testing center for heavy-duty vehicles and equipment is needed

Seek emission reductions from older large gasoline powered cars and trucks

Container port emissions (Bayport, Texas City and Morgan's Point)

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Pollution control strategies - an overview of (potential) SIP measures

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Federal pollution control measures

State pollution control measures

Emissions inventories - measures of air pollution releases

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Industrial (point source)

Other transportation (mobile off-road)

Small equipment (area sources)

Trees and shrubs (biogenic)

Ozone SIP: 2006 version

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New and more restrictive regulations on chemical plants and refineries

Expand the Texas Emission Reduction Program

Develop new regulations and strategies for reducing ship, train and aircraft emissions

Better verification of existing and new pollution control programs

Less-polluting behavior by citizens and smaller businesses

Odors - dealing with the nuisance of industry

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TexAQS II in town

Hundreds of air quality scientists converge on Houston

Air Quality Forecasting

Galveston-Houston Association for Smog Prevention - Syndicate Planning & research feed