Posted by: greeningwashington | April 28, 2009

Houston: Ground-Level Ozone Part 2


In order to assess what steps can be taken to prevent or reduce the problem of ozone, it is important to first analyze the current policies in place. Currently, the federal Clean Air Act (CAA) is the legal foundation for national air pollution programs. Under the CAA, each state is required to produce a State Implementation Plan (SIP), which sets control strategies and other measures to ensure that cities meet the NAAQS. Currently, the national standard, for ground-level ozone is .075 ppm (75ppb), which means cities cannot exceed this level of ozone.[i] According to the TECQ, each state SIP must set control strategies and devise ways to deal with nonattainment areas. In broad terms, each state is responsible for industrial and area source controls, vehicle maintenance and inspection, and voluntary emission reduction programs at local levels. Within each state, there are local and regional plans, which address specific local problems. The most important part of the Texas SIP and the Houston, Galveston, Brazoria SIP are the control strategies. TECQ provides information on the Houston, Galveston, Brazoria area SIP. Currently, this region is classified as severe nonattainment area under the 1997 eight-hour ozone standard, 80 ppb, with a maximum attainment date of June 15, 2019.

What controls are in place currently? According to the Houston, Galveston, Brazoria Ozone SIP, this area includes “one of the most comprehensively controlled industrial complexes in the world.”[ii] In order to control NOx and VOC emissions, precursors to ozone, the Houston SIP monitors five sources of pollution: point sources, which contribute to 35 percent of ozone pollution; on-road sources (34 percent) such as motor vehicles; and ships, area, and non-road (each 10 percent).

Regarding point source pollution, the Houston SIP provides for a cap and trade program for utility boilers, gas turbines, heaters and furnaces, etc. On-road control measures include both federal and state controls. State plans include: (i) the Texas Emission Reduction Plan (TERP), which provides funds for heavy-duty diesel engine replacement and retrofitting, (ii) vehicle inspection and maintenance, (iii) speed limit reduction, and (iv) voluntary mobile source emission reduction program (VMEP). Other control measures include emission standards on stationary diesel engines, and monitoring, testing, recordkeeping, and reporting requirements for VOC storage tanks, transport vessels, and marine vessels.[iii]

In order to help alleviate the ozone problem in Houston, I recommend three policy solutions: (i) tighten the NAAQS for ozone to between 60-70 ppb, (ii) pass national legislation dealing with a reduction of motor vehicle and industrial emissions including greenhouse gas emissions, and (iii) implement more efficient enforcement techniques.

[i] Environmental Protection Agency. “Ground Level Ozone.”

[ii]Texas. Texas Commission on Environmental Quality. Adopted HGB 1997 Eight-

Hour Ozone SIP Narrative: Chapter 4: Control Strategies And Required Elements.

[iii] Texas. Texas Commission on Environmental Quality. Adopted HGB 1997 Eight-

Hour Ozone SIP Narrative: Chapter 4: Control Strategies And Required Elements.


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