Public Citizen Comments to the Williamson County Commissioners Court in Support of CAPCOG Clean Air Coalition Funding
Williamson County Commissioners Court
710 S Main St 2nd Floor
Georgetown, TX 78626
Via hand delivery.
August 13, 2024
Re: 2024-2025 General Fund Budget: Public Citizen supports funding for the CAPCOG Clean Air Coalition.
Public Citizen is a nonprofit consumer advocacy organization that champions the public interest in the halls of power. Founded in 1971, we have 500,000 members and supporters throughout the country. Our Texas office was founded in 1984 and counts more than 25,000 members and supporters.
I have been a Williamson County resident and homeowner since 2017 when I moved back to the Austin region to serve as the Texas Director for Public Citizen. I am from Houston and have worked in air pollution, public health, and energy policy since 2011.
We appreciate the opportunity to provide these comments. We urge the Williamson County Commissioners Court to restore air quality planning funds to the CAPCOG Clean Air Coalition. They are essential to the economic prosperity and health of the region. We would welcome the opportunity to discuss our recommendations further. Please contact Adrian Shelley at ashelley@citizen.org, 512-477-1155.
TCEQ funding for regional air quality planning pays for air monitors, but not associated activities.
The Texas Commission on Environmental Quality (TCEQ) budget includes Rider 7, which provides funding for air quality assessment and planning for specific counties designated as “affected counties” but not designated as nonattainment. Governor Abbot vetoed Rider 7 in 2017, impacting the budget for FY2018-2019. The program returned with $4.5 million in funding for ozone affected counties in FY2020-2021 and FY 2022-2023. These funds are especially needed so that CAPCOG can communicate with the public about air quality.
CAPCOG receives Rider 7 funds from TCEQ. For FY2022-2023, CAPCOG received $1,009,018.93, an amount determined in part by the population of the affected counties.
In 2023, the legislature added funding to Rider 7 for a new program for fine particulate matter (PM2.5) affected counties. For FY 2024-2025 (the budget beginning Sept. 1, 2023) this program was allocated $2.5 million. CAPCOG received between $200,000-300,000 under this program.
The three monitors that CAPCOG operates in our region are wholly funded by Rider 7 and related federal funds. But there is a wide range of other activities the CAPCOG Clean Air Coalition does that is not funded by Rider 7. This is why CAPCOG needs local contributions to maintain its air quality program.
Williamson County has a history of supporting regional air quality programs with funding.
On May 23, 2024, CAPCOG submitted a funding request to member county and city governments. Our of a total air quality program budget of $1,261,000 for FY25, local governments were asked to contribute 23 per cent, or $325,000 total. County governments were asked to contribute $0.055 per capita, leading to a request of $38,346 from Williamson County. This is the amount Commissioner Cook has requested for FY25.
Williamson County has contributed funds to CAPCOG for air quality planning for many years. This began in 2011 when the state legislature decreased TCEQ Rider 7 funding by 50 per cent. Williamson County has contributed funds to CAPCOG nearly every year since FY2012. When Rider 7 funds were restored after the 2017 veto, Williamson County contributed its share every year except FY2024. Williamson County is the only local government that is not contributing its share of CAPCOG funding.
Below is a list of the more recent actions taken by this Court related to the CAPCOG Clean Air Coalition. I cannot find the budget allocations for FY22 and FY23, but I assume they were included in the county budget and not specifically discussed during any Commissioners Court meetings.
Williamson County support for CAPCOG Clean Air Coalition:
May 19, 2020. This Court unanimously approved annual funding of $15,762 for the Capitol Area Council of Governments (CAPCOG) air quality program for FY21. This was down from the FY2020 request of $45,706.
May 25, 2021. No action was taken on a proposed regional PM2.5 reduction plan by the CAPCOG Clean Air Coalition.
January 11, 2022. Commissioner Cook is unanimously reappointed to serve on the CAPCOG Clean Air Coalition through 2023.
August 22, 2023. The Court voted 4 to 1 to remove $36,444 in funding for air quality monitors from the FY24 budget.
May 7, 2024. The Court declares May 6-10, 2024 as Air Quality Awareness week.
CAPCOG has an important role in regional air quality planning.
Because air pollution does not respect political boundaries, regional planning is essential. Air pollution is emitted from stationary sources such as industrial facilities, area sources such as construction sites, and mobile sources such as cars and trucks. CAPCOG and the Clean Air Council play a role in regional planning, especially including transportation planning.
These planning efforts are necessary to keep our region in compliance with the federal Clean Air Act.
CAPCOG’s role in regional air quality planning was articulated in a Scope of Work for regional air quality planning for 2019-2026. There are eight major activities in the scope of work, half of which are not eligible for any state funding:1
- Clean Air Coalition (CAC) Support
- Technical Assistance to CAC Member Organizations to Implement Emission ReductionMeasures
- Outreach and Education Activities
- Annual Air Quality Report
- Monitoring (eligible for state funding)
- Monitoring Data Analysis (partially eligible for state funding)
- Emissions, Control Strategy, and Air Quality Modeling Analysis (partially eligible forstate funding)
- Other Studies and Planning Activities (partially eligible for state and federal funding)
Broadly speaking, local funding pays for outreach, planning, and technical activities.
Williamson County is at risk from nonattainment designations for ozone and particulate matter (PM).
Under authority from the federal Clean Air Act, the U.S. Environmental Protection Agency designates regions of the county as meeting or not meeting pollution standards for six “criteria pollutants.” Ozone and particulate matter are the two pollutants for which Texas counties are most commonly designated as “nonattainment.” Both TCEQ Rider 7 funds and CAPCOG Clean Air Coalition funds are used to address these two pollutants.
Right now there are no nonattainment designations in the CAPCOG region. Travis County is at risk of being designated nonattainment under both the 2015 ozone standard of 70 parts per billion and the 2024 fine particulate matter (PM2.5) standard of 9.0 μg/m3.
After Travis County, Williamson County is the county in the region most likely to be designated next under either the ozone or the particulate matter standard.
A nonattainment designation would have significant consequences for the region. Impacts would include transportation planning and the ability of large new sources of certain air pollutants to obtain permits. For example, if the newly proposed Samsung plant plans to permit emissions of nitrogen oxides (NOx) or volatile organic compounds (VOCs), then those permits would be more difficult to obtain under an ozone nonattainment designation.
It may be possible to avoid federal Clean Air Act designations, but only if we work now to reduce ozone and PM pollution in the region. Local funding for CAPCOG is essential to this.
Air pollution has significant health impacts to the region.
Air quality planning is intended to address ozone and particulate matter pollution. Taken together these pollutants have billions of dollars in public health impacts for our region.
Ozone pollution is associated with health impacts including sore and itchy throat, difficulty breathing, inflammation and damage to the airways, and exacerbation of lung or breathing conditions.2 Children, the elderly, and people with respiratory illnesses are the most impacted. In Houston, researchers measured an association between high ozone days and hospital admissions for asthma and cardiac arrest.3
Particulate matter is especially deadly. Every year more than 17,000 Texans die from fine particulate matter pollution generated from fossil fuel combustion.4 Globally, 1 in 5 deaths is caused by fossil fuel air pollution.5
Particulate matter is associated with a wide range of health impacts including death6,7, stroke8, heart attack9, diabetes10, impairment of brain development11,12, low birth weight13, and prenatal exposure14. Fine particulate matter (PM2.5) disproportionately affects people of color in the United States, an impact that is seen across all regions and sources of PM.15
The public health costs of PM2.5 pollution range well into the billions of dollars across Texas. They are estimated to exceed $3.3 billion dollars in Central Texas alone: 16
Conclusion
Air quality planning is essential to keep Williamson County healthy and prosperous. Air quality is one of the most significant drivers of public health. And Clean Air Act nonattainment designations can have economic consequences spanning decades and costing billions of dollars.
CAPCOG has years of experience managing air pollution monitoring, planning, and outreach programs. CAPCOG asks all local governments to contribute their fair share to this regional work. We encourage Williamson County to resume contributing its share.
Again, we appreciate the opportunity to provide these comments. If you wish to discuss the issues raised, please contact Adrian Shelley at ashelley@citizen.org, 512-477-1155.
Respectfully,
Adrian Shelley
Texas Director
1 This list is taken from the August 23, 2024 CAPCOG Memorandum, “CAPCOG FY 2025 Local Air Quality Program Funding Request.”
2 See generally, https://www.epa.gov/ground-level-ozone-pollution/health-effects-ozone-pollution.
3 See Ensor, K. B., Raun, L. H. and Persse, D. (2013). A Case-Crossover Analysis of Out-of-Hospital Cardiac Arrest and Air Pollution. Circulation. V127, pp 1192-1199, http://www.ncbi.nlm.nih.gov/pubmed/23406673; Raun, L. H., Ensor, K. B. and Persse, D. (2014) Using community level strategies to reduce asthma attacks triggered by outdoor air pollution: a case crossover analysis. Environmental Health, 13:58. http://www.ehjournal.net/content/13/1/58; Raun, L. and Ensor, KB. 2012. Association of out-of-hospital cardiac arrest with exposure to fine particulate and ozone ambient air pollution from case-crossover analysis results: are the standards protective? James A. Baker III Institute for Public Policy of Rice University. http://bakerinstitute.org/files/594/.
4 Karn Vohra, Alina Vodonos, Joel Schwartz, Eloise A. Marais, Melissa P. Sulprizio, Loretta J. Mickley, “Global mortality from outdoor fine particle pollution generated by fossil fuel combustion: Results from GEOS- Chem” Environmental Research, Volume 195, 2021, 110754, ISSN 0013-9351 (9 Feb. 2021) available at http://acmg.seas.harvard.edu/publications/2021/vohra_2021_ff_sup.pdf.
6 Karn Vohra, Alina Vodonos, Joel Schwartz, Eloise A. Marais, Melissa P. Sulprizio, Loretta J. Mickley, “Global mortality from outdoor fine particle pollution generated by fossil fuel combustion: Results from GEOS- Chem” Environmental Research, Volume 195, 2021, 110754, ISSN 0013-9351 (9 Feb. 2021) available at https://doi.org/10.1016/j.envres.2021.110754.
6 See https://www3.epa.gov/region1/airquality/pm-human-health.html
7 C. W. Tessum, D. A. Paolella, S. E. Chambliss, J. S. Apte, J. D. Hill, J. D. Marshall, “PM2.5 polluters disproportionately and systemically affect people of color in the United States.” Sci. Adv. 7, eabf4491 (2021) available at https://advances.sciencemag.org/content/7/18/eabf4491/tab-pdf.
8 See https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6176083/.
9 See https://www.thelancet.com/action/showPdf?pii=S2542-5196%2819%2930262-1.
10 See https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5583950/.
11 See https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5017593/.
12 Binter et. al. “Air pollution, white matter microstructure, and brain volumes: periods of susceptibility from pregnancy to preadolescence” Environmental Pollution (23 Sept. 2022) https://www.eurekalert.org/news- releases/965416.
13 See https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3055585/.
14 See https://www.abdn.ac.uk/news/16424/.
15 C. W. Tessum, D. A. Paolella, S. E. Chambliss, J. S. Apte, J. D. Hill, J. D. Marshall, “PM2.5 polluters disproportionately and systemically affect people of color in the United States.” Sci. Adv. 7, eabf4491 (2021) available at https://advances.sciencemag.org/content/7/18/eabf4491/tab-pdf.
16 See “CAC Meeting 8/12/2020 Item 6: Consider Participation in EPA’s Particulate Matter Advance Program” memo from Andrew Hoekzema, CAPCOG Director of Regional Planning and Services, to Clean Air Coalition Members (3 August, 2020).