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Item 10ADear Council Member Zito, I don't believe we've ever met. Diane Harris recommended I contact you. My name is Jim Schermbeck, and I'm with a 16- year -old local clean air group called Downwinders at Risk. You may have heard about us in connection with our successful "green cement campaign" that organized North Texas local governments into a powerful purchasing block directed at cleaning up the cement plants in Midlothian. The idea for that campaign originated in the North Texas air quality planning meetings surrounding the writing of the last clean air plan in 2006. Now, we're attempting to mobilize North Texas cities on behalf of cleaner air again. On June 8th, the Texas Commission on Environmental Quality will be voting in Austin on a new DFW clean air plan to reduce ozone, or smog, to meet the 1997 federal ozone standard of 85 parts per billion per 8 -hour episode. This "do- over" plan is necessary because DFW failed to meet that older standard in 2009. As of this date, the new plan TCEQ is proposing has no new control measures in it. It relies only on the status quo and a market trend of older dirtier cars being traded in for newer, cleaner ones. In this way, the Commission says it will reduce smog pollution enough to reach the 85 standard in 2013, four years behind schedule. By law, the TCEQ must reduce two smog - forming pollutants by 3% a year for the duration of the plan: Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOCs). Right now, the TCEQ plan of relying on "fleet turnover" results in lots of NOx tonnage being cut, but not enough VOCs. In fact, there's a 140 tons -a -day gap in the amount of VOC cuts the TCEQ needs to show it's implementing in the plan. TCEQ can use the excess NOx tonnage it gets from its "fleet turnover" to fill part of the hole, but as of this date, it can't fill all of it. And these are NOx reductions that would take place as a part of the predicted turnover in cars regardless of the VOC gap. They are not new cuts. My group and others are trying to build a local consensus in North Texas that says there's a better way to fill that VOC gap - with real VOCs from the Barnett Shale that have never before been included in a DFW clean air plan, and that now have surpassed cars and trucks as the primary source of this kind of air pollution. We're calling this effort the "Fair Share Campaign." One of the ways we can demonstrate regional consensus is to have local city councils and county commissioners courts passing resolutions addressed to the TCEQ stating that all things being equal, we would like the state to take this opportunity to reduce VOCs from the gas industry rather than filling in the gap with the cuts of NOx tonnage it will accumulate anyway. I've included a template for a resolution on the subject that I hope you find is a sufficient starting point for one the Southlake Council could pass. There are numerous advantages to North Texas residents, public officials, and even industry in such an approach. They are outlined over the course of two documents I've attached to this e-mail - a four page walk through the case for the gas industry doing its Fair Share, and a shorter flyer on the campaign itself. We also have a page devoted to the campaign on our website: http://downwindersatrisk.org/fairshare.htmi Time is of the essence. Our first deadline is June 8th to show the TCEQ Commissioners that there is widespread support for including gas industry VOCS in this DFW air plan. Since there are no budgetary or city policy issues at stake, I'm hoping that the council can pass a supporting resolution at one of its May meetings. i appreciate your consideration. If you have any questions, please contact me. Thank you. Jim Schermbeck Director, Downwinders at Risk D rc ,o6+0K ere)Oded !a► DouKcviKders oW 44k RESOLUTION ON REDUCING BARNETT SHALE VOLATILE ORGANIC COMPOUNDS (VOCs) TO COMPLY WITH THE RATE OF FURTHER PROGRESS REQUIREMENTS IN THE PROPOSED 2011 DFW STATE IMPLEMENTATION PLAN FOR OZONE WHEREAS, the the Dallas -Fort Worth non - attainment area for ozone pollution (DFW non - attainment area) failed to meet the 1997 85 parks per billion federal ozone standard and was recently reclassified as a ` °serious" violator of the federal Clean Air Act; and WHEREAS, the Texas Commission on Environmental Quality and the U.S. Environmental Protection Agency must develop control strategies and measures to enable the DFW non - attainment area to achieve compliance with the 1997 85 ppb ozone standard thorough submittal of a complete and adequate State Implementation Plan for Ozone; and WHEREAS, since 2005 the DFW non- attainment area has experienced and expects to continue a rapid growth in the development of Barnett Shale natural gas and oil resources, and WHEREAS, the Texas Commission on Environmental Quality and the U.S. Environmental Protection Agency have concluded emissions of Volatile Organic Compounds (VOCs) are a major source of ozone pollution in the DFW non - attainment area; and WHEREAS, the Texas Commission on Environmental Quality has estimated that emissions of VOCs from development of Barnett Shale resources have risen significantly in the last five years, while VOC emissions from every other major source category but one has declined; and WHEREAS, the Texas Commission on Environmental Quality has estimated that emissions of VOCs from development of Barnett Shale resources will total over 100 tons per day by 2012, eclipsing on -road mobile sources to become the second largest source category of VOCs in the DFW non - attainment area; and WHEREAS, the Texas Commission on Environmental Quality has estimated that total annual emissions of VOC air pollution in the DFW non - attainment area will continue to increase, despite control measures and strategies required by previous DFW State implementation Plans; and WHEREAS, the emissions of VOCs from development of Barnett Shale resources are unregulated by any previous DFW State Implementation Plan for Ozone; and WHEREAS, the Texas Commission on Environmental Quality has previously regulated significant emissions of Nitrogen Oxide, another major ozone precursor, resulting from development of Barnett Shale resources through its new diesel engine rules; and WHEREAS, the Texas Commission on Environmental Quality has concluded it must reduce emissions of VOCs between by 140 tons per day in the DFW non - attainment area over the next two years to meet required Rate of Further Progress goals in the 2011 State Implementation Plan for ozone pollution being submitted to meet the 1997 federal ozone standard; and WHEREAS, an accurate accounting of the impact of new emissions of VOCs from the development of Barnett Shale resources for the purposes of meeting the 2011 DFW State Implementation Plan's Rate of Further Progress goals requires using a inventory year prior to 2006; and WHEREAS, existing control measures for emissions of VOCs from development of Barnett Shale resources (pneumatic valves, vapor recovery, electric compressors, flaring bans, green completions) can reduce VOC pollution by 90% opr more while producing a profit for the operators through the recovery and marketing of otherwise lost products; and WHEREAS, a consistant regional standard for control of emissions of VOCs resulting from development of Barnett Shale resources that is applicable to all operators throughout the DFW non - attainment area is preferable to the current patchwork of regulations that leave some operators at a competitive disadvantage based on geography and jurisdiction; and WHEREAS, emissions of VOCs resulting from development of Barnett Shale resources, including benzene and formaldehyde, represent a source of concern among many residents living adjacent to oil and gas facilities in the DFW non- attainment area, NOW, THEREFORE, BEIT HEREBY RESOLVED THAT THE URGES THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY AND ENVIRONMENTAL PROTECTION AGENCY TO: Section 1: The recommends that as part of their efforts to meet Rate of Further Progress goals for the 2011 DFW State Implementation Plan of Ozone, the Texas Commission on Environmental Quality and Environmental Protection Agency implement control measures for emissions of VOCs from the development of Barnett Shale resources throughout the DFW non - attainment area, including pneumatic valves, vapor recovery, electric compresors, flaring bans, and green completions. Section 2: We request that our state and federal representatives work with us to see that TCEQ implements VOC controls on gas industry faciltities and equipment in the 2011 DFW State Implementation Plan for Ozone. THE FAIR SHARE CASE for REDUCING BARNETT SHALE VOCs In NORTH TEXAS 1. The Most Recent TCEQ Inventories for Barnett Shale Air Pollution are Staggering (All data from the Nov 5 2010 Presentation by TCEQ to the North Texas Clean Air Steering Comm.) A. Revised TCEQ Oil & Gas VOC Emissions Inventories for 2006 - 2012 2006 2012 Condensate Tanks 40.6 tpd 30.5 Tons Per Day Pneumatic Devices (valves, etc) 21.5 tpd 52.0 Tons Per Day All Oil & Gas TOTAL 73.1 tpd 103.3 Tons Per Day B. Revised VOC Pollution from All Maior Source Categories 2006 -2012 2006 2012 On -Road Mobile 120tpd (24 %) 93tpd (18 %) Area (minus oil &gas) 210tpd (42 %) 237tpd (46 %) Elevated Point Sources 8tpd (2 %) 7tpd (1 %) Low -level Pt. Sources 28tpd (6 %) 24tpd (5 %) Non -Road 63tpd (13 %) 45tpd (9 %) Off -Road 6tpd (1 %) 6tpd (1 %) Oil & Gas Production 67tpd (13 %) 103tpd (20 %) 9 County Total 504 tpd 515tpd Condensate Tanks and Valves weren't even in the official 2006 SIP VOC emission inventories. Now they account for 61 of the 73 tpd TCEQ estimates was being emitted by Shale sources in the DFW non - attainment area that same year. VOC pollution from Barnett Shale sources is now so large that it's obliterated previous progress from past clean air plans. Despite two SIPS over the last five years, without additional reductions, TCEQ projects they'll be more VOC air pollution in DFW in 2012 . than there was in 2006. If left unregulated, TCEQ also estimates that more VOC pollution will be emitted by Barnett Shale operations than the entire DFW passenger car and truck fleet by 2012 2. TCEQ Admits It Needs to Find More Cuts in VOC Pollution in the New 85ppb SIP From the Nov. 5 th TCEQ Presentation on Reasonable Further Progress (RFP): RFP is a Federal Clean Air Act requirement that is met by documenting in the SIP estimated prescribed ozone precursor emissions reductions For ozone, RFP is generally defined as an average 3 percent combined annual reductions from the base year inventory in VOC and NOx through the attainment year. There is a shortfall in volatile organic compounds for 2011 and 2012 RFP milestone years that we're not used to seeing. Reduction in VOC Tonnage needed for RoP 2011 Using a 2002 inventory of VOCs Using 2008 inventory of VOC 77.86tpd 21.99tpd 2012 61.43tpd 5.52tpd This tonnage is what TCEQ must cut even though they say their modeling shows DFW meeting the 85ppb standard by the year 2013 by relying only on "fleet turnover" and existing measures. These cuts are required in addition to the ones designed to get the monitors in compliance. RoP acts as an insurance that emissions are actually coming down. TCEQ is going to make the argument that they should be able to use a 2008 inventory rather than keep relying on a 2002 inventory, which they used in the last SIP (2006 -07). But by using the 2008 base year, TCEQ is able to "grandfather" a huge part of the increase in Shale VOCs that's taken place since 2005 and warped the DFW VOC inventory. They only have to reduce VOCs by 27.5 tpd total over 2011 -12, - less than half the total increase in Shale VOCS over the last 4 -5 years. Going back to 2002, (to pre- "Halliburton loophole " DFW) forces TCEQ to take the entire explosion in Shale VOCs since 2005 -6 into account, and reduce by 140 tons per day over 2011 -12, a figure closer to the actual annual Shale VOC pollution total. Using any baseline after 2005 won't reflect the entire increase in VOCs from Shale sources and automatically exempts a large portion of those VOCs from regulation. It's ultimately up to EPA to decide what baseline is required. 3. It Pays for Industry to Install 90% + Air Pollution Controls. From the November 5 th Presentation by EPA to the North Texas Clean Air Steering Committee on Cost - Effective Control Strategies for Barnett Shale Air Pollution. Criteria: Reasonably available Substantially reduce emissions Economically feasible A. ELECTRIFICATION OF COMPRESSORS Phasing in electric motors as an alternative to internal- combustion engines to drive Compressors No air emission permit needed Much lower life cycle cost Wellhead IC engines savings: $23,400 /yr /unit Occidental Oil & Gas corp. Need highly reliable source of power nearby B. VAPOR RECOVERY ON CONDENSATE TANKS/VALVE REPLACEMENT Controlling VOC emissions from condensate tanks with vapor recovery units Control efficiencies X98% Resource recovery ($100s to $Ms) Replacement of high -bleed pneumatic valves and fittings on the pipeline networks with no -bleed alternatives Payback often within a yr After payback — profit C. GREEN COMPLETIONS Use of "green completions" to capture methane and VOC compounds during well completions Natural Gas Star program Alternative to venting/flaring Filter and into production lines/tanks Up to 98 % efficient $20M profits from NG and condensate recovered 3 yr period (Devon Energy) D. EXTEND NEW ENGINE RULES Extend the 2009 engine rule to counties outside the DFW area, where BS operations are located Reduce NOx emissions Engines >50 hp Rich burn engines 50 —500 hp NSCR would reduce VOC, NOx, HAPs, CO $330/ton (500hp, 2007) 4. Summary: Unlike almost every other major source category of DFWVOC pollution, Shale VOC emissions have risen dramatically, and will keep rising unless checked. Unlike every other major source of DFW VOC pollution, Shale VOC emissions are un- regulated and untouched by past clean air plans. North Texas residents want Shale VOC emissions (Benzene, Formaldehyde, etc) reduced. TCEQ says it needs to cut DFW VOCs to comply with the Rate of Progress part of the "make-up" 85ppb SIP Industry actually makes money when it reduces VOC emissions from Shale sources. Industry actually benefits from having a regional level playing field for minimum air quality requirements - no patchwork of regulations /jurisdictions. We should use the 85ppb SIP to target reductions of Shale VOCs - Read and Learn More about Downwinders at Risk's Fair Share Campaign at our website: www.downwindersatrisk.org -At the bottom of our Fair Share Campaign page, you can download a sample resolution your city council, county court, school board, and other local governments can pass in support ofTCEQ using the current DFW clean air plan to cut gas industry VOC pollution. Work with us to demonstrate that North Texas is united in its demand that the state use this opportunity to make a significant cut in a kind of air pollution we all want to see reduced. - Sign -up to get our e- newsletter, the DFW News Plume so you can keep up with the progress we're making, and help us win this important battle for better air quality! - Invite us to do a presentation on this issue for your club, civic group, place of worship or neighborhood group. Dow n w ' in 1811111flon In downwindersatrisk.org 972 -230 -3185 Gas drilling releases more smog- producing "VOC" pollution in DFW skies than all our cars and trucks combined. Now we have an opportunity to dramatically decrease this toxic air pollution. How You Can Help Us Cut Gas Drilling Pollution Now a t,.,� ra l C a I Do �.�5 The Gas Industry is Our Largest Source of VOC Pollution In the last six years, the gas industry has replaced vehicles as the largest source of smog- formingVOC (Volatile Organic Compounds) air pollution in DFW VOCs are a category of chemicals that includes Benzene, Formaldehyde, Methane and many other kinds of toxic pollution. According to the state, there are over 100 tons a day of VOC pollution being released by the gas industry in North Texas.This pollution has never been regulated by the state or any previous DFW clean air plan. A New DFW Air Plan Means A Chance to Cut Gas VOCs The Fair Share Campaign Based on our successful Campaign for Green Cement, Downwinders is using the region's air quality future to prompt local governments, institutions, and individuals in North Texas to act in self- defense and demandTCEQ fill theVOC gap in the DFW clean air plan with cuts in uncontrolled gas industry emissions.We're calling this effort the Fair Share for Clean Air Campaign. It's called "Fair Share for Clean Air" because it's time the gas industry did its part to clean up DFW air. Over the last 20 years, every other industry and business that releases smog- forming pollution has had to reduce their emissions. Now, as its share of total air pollution continues to grow and creates an obstacle to air quality progress, gas industry emissions must be cut as well. DFW flunked the old 1997 smog standard in 2009.The state must submit a new clean air plan for the region to EPA at the end of 201 I .That plan is scheduled to be approved by the Texas Commission on Environmental Quality by THIS JUNE. TCEQ has most of what it needs to get EPA approval for their plan, but there's one big problem: TGEQ admits it still needs to cut approximately 140 tons of VOCs PER DAY. You'd thinkTCEQ would have set about months ago to fill this large VOC gap in the new DFW air plan with Barnett Shale VOCs that have never been subjected to an air plan before. But it hasn't Gas Industry Vehicles VOC Pollution In the DFW Region Cut Smog - Forming Pollution for the Entire Region Cutting Gas industryVOCs to fill the gap in the new DFW clean air plan will finally bring reductions to a source of local smog that's been growing steadily over the last six years. Based on computer modeling done byTCEQ itself, a good case can be made that it was gas industry emissions that caused the last DFW clean air plan to fail. Large volume and the location of gas industry pollution could have made the critical difference in not being able to meet the old federal ozone standard. Pollution Controls Make Money for Industry ReducingVOC pollution actually makes the gas industry money. Most of the pollution controls forVOC are designed to capture profitable product that's now literally evaporating into thin air. Think about the vapor recovery system at your local gas station and you get a good idea of how these controls work. It's been estimated that gas companies could earn millions by simply re- directing these emis- sions back into their facilities. Reduce Exposure to Toxic Air Pollution Gas fieldVOCs includes carcinogens like benzene and formaldehyde. A 2010 study by the Houston Advanced Research Center revealed levels of cancer - causing formaldehyde in North Texas air are more than double that of the Houston Ship Channel. TCEQ's own tests in the Barnett Shale have shown "some of the highest benzene concentrations we have monitored in the state:' VOC poisons are believed to be behind many of the reported acute health problems associated with gas industry downwinders, including respiratory illness, nosebleeds, headaches, rashes, nausea, and neurological problems. Using off the shelf technology available right now, these emissions could be reduced by 90% or more by 2013. That's almost nine million pounds of toxic air pollution annually that could be eliminated in the next two years. No other strategy or pending regulations at any level of government offers a quicker, more substantial cut In gas industry VOC emissions. Top: Gas condensate tanks as they appear to the naked eye. Bottom: Those same tanks os they appear to an infrared comera. Those are plumes of VOCs being released.