Austin Risks a Nonattainment for Ozone Pollution Designation. Here’s What It Means and How We Can Fix It.
By Adrian Shelley and Kaiba White
Austin has an ozone pollution problem. While ozone in the stratosphere – nine to 18 miles from the surface of the Earth – protects us from harmful cosmic radiation, ground-level ozone is bad for public health and could soon become bad for our local economy.
Ozone causes and worsens several health problems. It causes coughing and wheezing, throat irritation, and chest pain. It can cause more serious health problems, such as asthma attacks, heart attacks, decreased lung function, and airway inflammation. Some people are especially vulnerable: children, the elderly, and people with respiratory illnesses such as asthma and COPD.
Federal and State Roles in Clean Air Regulation
The federal Clean Air Act directs the U.S. Environmental Protection Agency (EPA) to set and enforce air pollution standards for ozone and certain other air pollutants to protect public health. These are called “National Ambient Air Quality Standards” or “NAAQS.”.
In Texas today, most large cities are designated by the EPA as nonattainment areas for ozone pollution, meaning they don’t meet the standard. These include the metropolitan areas of Houston, Dallas-Fort Worth, San Antonio, El Paso, and a few other counties around the state. Typically, the entire multi-county region around a large metropolitan area is designated as a nonattainment area for ozone.
Each state must make a plan, called a “state implementation plan” or “SIP,” to meet the ozone standard. Part of the plan focuses on areas of the state that don’t meet the standard, called “nonattainment areas.”
Austin’s Ozone Situation
Austin has always met the ozone pollution standard until now. The Clean Air Act requires states to place air monitors in cities to monitor compliance with air pollution standards. Austin has had about a dozen ozone air monitors for many years. The data from these monitors is submitted to the EPA, which certifies it as correct and determines whether the area still meets the standard.
Two air monitors in Austin now fail to meet the ozone pollution standard, meaning the city is out of compliance with the Clean Air Act. But it doesn’t mean the region is automatically designated as “nonattainment.” The EPA still has to make that designation officially. It could do that at any time, but it could also wait until the ozone pollution standard changes, which won’t be for several more years.
Austin needs to control its ozone problem before the EPA’s next assessment. Fortunately, one of the best strategies is straightforward: stop burning fossil fuels. Austin is already taking steps to reduce fossil fuel use in transportation, but it could do much more.
What Happens if Austin Becomes a Nonattainment Area for Ozone?
If the EPA designates Austin as nonattainment for ozone pollution, Texas will have to devise a plan to reduce ozone pollution in the Austin region. These plans are very detailed and take decades to work (in fact, Texas has never brought a region from “nonattainment” to “attainment,” so none of its ozone plans have worked yet). Ozone isn’t emitted directly from sources of pollution. It is formed in the atmosphere when two other pollutants, called “ozone precursors,” mix and react with sunlight. The ozone precursors are nitrogen oxides (NOx) and volatile organic compounds (VOCs).
Because we can’t reduce ozone pollution directly, we must combat it by reducing the precursor pollutants NOx and VOCs. The amount of NOx drives the amount of ozone in Austin’s air. This means the best way to reduce ozone pollution is to reduce NOx pollution. The other ozone precursor pollutant, VOCs, is mostly produced naturally by trees. There is not a good strategy to reduce VOC pollution coming from trees.
NOx, or nitrogen oxides, come mainly from burning fossil fuels. Our car tailpipes produce NOx when they burn gasoline. Reducing vehicle pollution is a major strategy to reduce ozone, especially pollution from older diesel trucks, the most polluting vehicles on the road. To its credit, Texas has a pretty successful program to incentivize replacing old, polluting vehicles. It’s called the Texas Emissions Reduction Plan (TERP). But there are over a million registered vehicles in Travis County alone, so addressing NOx from vehicles will take time.
NOx Pollution Also Comes From Industry
Cars are called “mobile sources” because they move while they pollute. Air pollution also comes from “stationary sources,” typically industrial facilities, that stay put while they pollute. A good plan to reduce ozone pollution will address NOx from mobile and stationary sources.
The largest nearby stationary source of ozone precursors is the Fayette Power Project, a coal plant near La Grange. Fayette is the third largest emitter of NOx in Texas (the first two are other coal-burning power plants). Fayette releases about 17 tons of NOx pollution every day it operates. And this is just permitted pollution reported to the Texas Commission on Environmental Quality (TCEQ). It does not include illegal pollution from maintenance, start-up, shut-down, or “upset” events.
Although Fayette is around 70 miles southeast of Austin, its NOx emissions contribute to ozone pollution in the city. Ozone forms in the atmosphere as large plumes that move slowly across a geographic region. It is not unusual for ozone plumes to travel hundreds of miles and impact one area for hours.
Austin Energy’s methane gas-burning power plants at Decker and Sand Hill are also among the five most significant sources of NOx pollution in Travis County.
To meet the ozone pollution standard, Austin must reduce pollution from industrial sources, including Austin Energy’s power plants. We also have to avoid adding new sources of NOx pollution. Austin Energy has proposed building a new power plant that would burn fracked methane or “natural” gas. This new plant would produce ozone precursor pollution, including NOx. Austin Energy also says it wants to convert this new plant to burn a blend of methane and hydrogen and, eventually, pure hydrogen in the future. While hydrogen can be a carbon-free fuel if it is produced using clean energy, it still produces lots of NOx pollution when burned – more than from burning methane if standard emissions controls are utilized. While new emissions controls are being developed, NOx emissions from a hydrogen-burning plant would still be similar to a methane-burning plant, even with those new controls.
A Clean Energy Future Should Reduce Ozone Pollution as Well as Greenhouse Gases
Air pollution is deadly, with the World Health Organization estimating that one in seven deaths worldwide is related to polluted air. In Austin, this translates to billions of dollars in health costs. The costs come not only in health care bills but also in lost economic opportunity from missed days at work. Asthma is the number one cause of school absences, and we know that missing school can create a risk of falling behind on critical education and set a person on a path for lower economic opportunity.
A 2015 study by the Capital Area Council of Governments estimated that an ozone nonattainment designation would cost Central Texas between $0.9 – $1.4 billion annually for up to three decades. These costs come from:
- A permanent pollution abatement expense impacts an industry’s Gross Regional Product (GRP).
- The impact of a delay in transportation infrastructure growth on the region’s GRP.
- The impact of loss of likely capital investment on regional GRP. (Facilities with air pollution emissions that might consider locating in the region could instead locate elsewhere to avoid new restrictions that would be triggered.)
- The impact of a shift in sales from one industry to another on regional GRP
Austin might be too late to avoid being designated nonattainment for ozone, but it’s worth trying. Perhaps we can succeed and if we don’t, we will still reap the benefits of reduced health costs. The amount of ozone in our air now is dangerous. While reducing ozone air pollution will have some costs, the cost of continued pollution is far greater.
Since we know Austin has to reduce ozone pollution, it wouldn’t be wise to add new sources of ozone precursor pollution. It would be much cheaper to avoid building a new fracked methane gas/hydrogen-burning power plant by investing in batteries and other clean energy technologies than to reduce its pollution in the future. Avoiding new fossil fuel plants today will benefit public health and the climate in ways Austinites can enjoy for decades.
Shelley is the Texas director of Public Citizen. White is a climate policy and outreach specialist in the Texas office of Public Citizen.