A Look at Air Quality, Ozone Pollution, & the San Antonio Region

This page will answer six questions:

1.  What is the federal government's response to the ozone threat?

2.  If we've violated the federal air quality standards, why aren't we in Non-Attainment here in the San Antonio area?

3.  How do we know we are breaking the rules?

4.  Who is responsible locally for our clean Air Policies?

5.  What is the local response to the Ozone Challenge?

6.  What is the Timeline for action under the Clean?

1.  What is the federal government's response to the ozone threat?

Revisions in 1970 to the federal Clean Air Act authorized the National Ambient Air Quality Standards (NAAQS) in order to protect public health. The NAAQS currently sets pollution standards for six important air pollutants, the so-called “criteria pollutants”: ground-level ozone, particulate matter (fine dust, smoke, and soot, chiefly), sulfur dioxide, carbon monoxide, lead, and nitrogen dioxide . The NAAQS direct states to enforce standards as well.

Further revision to the Clean Air Act in 1979 created the 1-hour average ozone NAAQS. The one-hour averaging idea is simple: air quality monitoring equipment records levels of ozone at various locations throughout the country. Each ozone monitor is hooked up to a computer, which averages the ozone level readings on an hourly basis. If that hourly average is greater than the standard, or threshold level, set in the NAAQS, then that reading is referred to as an “exceedance” of the standard. When you hear or read about Dallas and Houston being non-attainment areas for ozone, that is because they, along with the Beaumont-Port Arthur region and El Paso, have exceeded often enough that they have been declared “non-attainment” by the EPA for violation of the 1-hour average ozone NAAQS. That is, the EPA has officially declared that they don’t meet clean air standards.

The 8-hour average ozone NAAQS was created as a Clean Air Act Amendment in 1997. Air quality monitors in the San Antonio region have shown exceedances for the 8-hour average ozone NAAQS (which is also simply called the 8-hour standard) since the 8-hour standard was created. In fact, local ozone readings have frequently exceeded the 8-hour average ozone NAAQS, which is set at 85 parts per billion (ppb), for ground level ozone pollution.

When a region’s ozone readings are consistently high – there are enough exceedances – the area is declared to be in non-attainment of the NAAQS by the Environmental Protection Agency. A declaration of non-attainment of the 8-hour ozone NAAQS requires that a region devise a plan, a methodology to return the region to attainment of the NAAQS. The individual programs that are created to fight ozone pollution are called “control strategies,” and, logically enough, control strategies seek to lower ozone levels by lowering the ozone precursors mentioned in discussion of the Emissions Inventory.

The most recent version of the 8-hour ozone NAAQS guidance requires implementation of Transportation Conformity and New Source Review for a region, following a declaration of non-attainment. Both programs seek to require, as their essential goal, that any changes in business, industry and transportation within the non-attainment region will not result in an additional burden to air quality. The San Antonio / Bexar County Metropolitan Planning Organization estimates that, if Transportation Conformity caused roadway construction funding to halt due to a declaration of non-attainment, the cost in delays and project funding loss could total several hundred million dollars per year. In much the same way, New Source Review programs enacted under a declaration by the EPA of non-attainment under the 8-hour ozone NAAQS require that businesses and industry will not, through construction of a new facility or modification of any existing facility, increase the air quality problem.

2.  If we've violated the federal air quality standards, why aren't we in Non-Attainment here in the San Antonio area?

This is a very good question. We have exceeded the 8-hour average ozone NAAQS a number of times since its inception in 1997. We know what remedial programs the current federal guidelines prescribe. So why haven’t we been declared non-attainment?

The simple answer is circumstance. Litigation over the 8-hour average ozone NAAQS lasted for several years, and, as a result, no classifications of non-attainment have been issued under it. To make a long story short, on February 27, 2000, the U.S. Supreme Court issued a decision  that upheld the 8-hour ozone NAAQS standard itself as it was written in 1997. However, the implementation plan – the set of instructions to be followed after non-attainment is declared – was found to be unlawful by the Supreme Court, and is currently being rewritten. This means that the 8-hour standard, as a measurement of attainment or non-attainment, with its 85 ppb threshold, is a valid standard, a valid “measuring stick”. The court directed the EPA to rewrite the implementation plan in accordance with guidance from the lower court which, earlier, found against the EPA (the United States Court of Appeals for the District of Columbia). It is only a matter of time until the implementation policy will be rewritten and the standard enforced.

3.  How do we know we are breaking the rules?



There are four air quality monitors in our region which monitor ozone levels. They are called Continuous Air Monitoring Stations (CAMS) and are known by their CAMS numbers. The four monitors are:

CAMS 59, near Calaveras Lake;
CAMS 678, on the near east side of San Antonio, near a City Public Service power plant;
CAMS 23, across the street from Marshall High School in northwest San Antonio, and;
CAMS 58 (in Camp Bullis).

Their locations are given in the map above.

Here, a little detail is helpful. As mentioned, the eight-hour average is just as the name implies… at each individual ozone monitor, the ozone level readings recorded are averaged together over each eight-hour period. At each ozone monitor, the fourth-highest eight-hour average for a calendar year is noted. Finally, the average of the fourth-highest readings over three years is calculated at each monitor. This three-year average of the fourth-highest readings must be below 85 parts per billion at each monitor in an area, or else an area is in “non-attainment,” that is, in violation of federal law.

The table below shows our local ozone readings for complete calendar years 1998-2001. Due to our history of violations, San Antonio has been called a “near non-attainment” area.

 
4.  Who is responsible locally for our Clean Air Policies?

The Air Improvement Resources (AIR) Committee is a committee of the Alamo Area Council of Governments. While the AIR Committee does not enact policy, the AIR Executive Committee is composed of some of the elected officials in Bexar, Comal, Guadalupe, and Wilson Counties. These four counties make up the San Antonio Metropolitan Statistical Area (MSA), which comprise the non-attainment area if our region is declared non-attainment, according to EPA recommendations. These elected officials develop policy and planning responses to the ozone challenge by consensus.



However, by the summer of 2003 the U.S. Census Bureau is expected to issue revised MSA boundaries nationwide. Based on 1990 US Census Bureau Data, there is strong evidence  that the 2003 boundary of the San Antonio MSA will be expanded to include Atascosa, Bandera, Kendall and Medina Counties. So, in order to prepare the leaders in those counties for the role they may be called upon to play, the AIR Committee has extended an invitation of membership to elected officials in those four counties.

The AIR Advisory Committee is made up of regional stakeholders from business, industry, and the citizenry at large, who advise and inform the AIR Executive Committee. The AIR Public Education Committee is charged with disseminating information about the ozone challenge through the news media and public events. The AIR Off-Road Equipment Committee works with local industry to promote voluntary implementation of ozone control strategies and studies the impact of legislation and other legal issues on their community. The AIR Technical Committee is composed of technical staff from the various governmental and private agencies knowledgeable about air quality issues.

All members of the AIR Committee system work closely with the US Environmental Protection Agency (EPA) and the Texas Commission on Environmental Quality (TCEQ), as well as local governments, to meet the ozone challenge on an informed, coordinated, resource-efficient basis.

5.  What is the local response to the Ozone Challenge?

The AIR Committee developed the Clean Air Plan for the San Antonio Metropolitan Statistical Area. The Clean Air Plan:

		Is a blueprint for improving regional air quality in a faster, regionally specific way.
		Includes voluntary measures committed to by organizations all around the region.

The Clean Air Plan has been in development for several years. Although local leaders have long sought a means to implement the plan, federal policy or guidance has not been available that is designed for implementation of voluntary measures prior to a non-attainment designation.

On March 20, 2002, the TCEQ proposed policy to the EPA that encompasses proactive, voluntary actions by local areas as they endeavor to meet the 8-hour average ozone NAAQS. This draft protocol, now being considered for approval by the EPA, provides a vehicle for the early action planning for our region that has been underway since the creation of the AIR Committee. This protocol provides the structure to the region’s Clean Air Plan.

The details of the Early Action Compact (EAC), as proposed by the TCEQ and as incorporated into our region’s Clean Air Plan, include:

		Early planning, implementation, and emission reductions, locally devised, leading to expeditious attainment and maintenance of the 8-hour ozone standard;
		State support to ensure technical integrity of the early action plan;
		Formal incorporation of the plan into the State Implementation Plan (SIP);
		Deferral of the effective date of nonattainment designation and/or designation requirements so long as all compact terms and milestones are met; and
		Safeguards to return areas to traditional SIP attainment requirements should compact terms be unfulfilled, with appropriate credit given for reduction measures already implemented.

The Clean Air Plan would accelerate implementation of air quality measures while avoiding the penalties currently associated with a non-attainment designation. In exchange for the accelerated implementation of air quality control strategies at the state and local levels, the San Antonio Metropolitan Statistical Area would not be designated by the EPA as a non-attainment area under the 8-hour ozone NAAQS for the duration of the Clean Air Plan agreement.

At this time, the EPA is considering the approval of the EAC as a planning mechanism available to any appropriate region. The AIR Committee leadership is working to revising their current air quality plan to work within the EAC protocol.

6.  What is the Timeline for action under the Clean Air Plan?

		December 31, 2002: Execution of compacts; Clean Air Plan signed by all parties and including a timeline for milestones
		December 31, 2004: State adoption of plan in SIP (EPA approval about 9 months later)
		All control measures incorporated into the SIP; any modifications are SIP revisions
		December 31, 2005: Implementation of adopted control strategies, at the latest
		December 31, 2007: Attainment Date
		December 31, 2012: Maintenance Demonstration Date; to ensure attainment through this period

In Review:

		Ozone pollution is a health risk. Federal Law has been established to provide standards and provide enforcement of the standards.
		Monitors reveal unhealthy ozone levels in the San Antonio region.
		On-road vehicles are the largest single source of all ozone precursors, the gases that mix and react in the atmosphere to make ozone.
		We have developed a voluntary Clean Air Plan to reduce the hazards of ground-level ozone.

Back to What We're Doing: click here
Back to Air Quality : click here

For more information about AACOG's Air Quality Program contact:

Peter Bella, AACOG Natural Resources Director
8700 Tesoro Drive, Suite 700
San Antonio, TX 78217
Phone: (210) 362-5249
Fax: (210) 225-5937
E-Mail: pbella@aacog.com