Posted by: greeningwashington | April 28, 2009

Houston: Ground-Level Ozone Part 3


First, I recommend that the EPA tighten the NAAQS for ozone due to the significant health issues that I discussed. This would not only help alleviate the problem in Houston, but in other polluted cities throughout the nation. Pursuant to the CAA, the EPA must set the ozone standard at levels that protect the health of the public from the pollutant. The science seems conclusive that ozone pollution is damaging not only to human health but also to vegetation. Many studies on ozone levels and human health have shown that ozone levels, even under current standards, can lead to premature death and other serious respiratory conditions. In May of 2007, experts at the EPA even agreed that the ozone standard should have been lowered to 60 ppb instead of 75 ppb. In their letter to the then EPA administrator, Stephen Johnson, the Clean Air Scientific Advisory Committee (CASAC), which is composed of a group of scientists and policy makers who provide independent advice to the EPA, unanimously recommended a range of 0.060 to 0.070 ppm for the primary ozone NAAQS. They stated that, “the primary 8-hr NAAQS needs to be substantially reduced to protect human health, particularly in sensitive subpopulations.”[i] If NAAQs were to be tightened to 60 ppb, human health would increase and we would see a reduction in health care expenses related to respiratory conditions. However, the costs would be substantial in not only implementation but also private-sector costs. While the benefits of human health and welfare seem to outweigh the economic costs, benefit-cost analysis like this sort is effectively precluded for setting standards under the CAA.[ii]

With the election of a new president and a majority of Democrats in Congress, many of whom support such tightening of standards, I project that my suggestion would be widely accepted among Democrats and even some Republicans from urban areas. Organizations like the American Lung Association would certainly be in favor of a move like this; however, the energy sector and the oil and gas industry would definitely be opposed to such a move. Tightening NAAQS for ozone levels would lead to an increase in industry expenses, however, some of these costs could be offset by federal funds. With proper implementation and enforcement, coupled with mandatory reduction of industrial and motor vehicle emissions, the Houston area would be able to meet a stricter NAAQS of 60 to 70 ppb.

Secondly, because motor vehicles and other on-road sources produce greenhouse gas emissions, which gases directly and indirectly contribute to harmful ozone build-up, I recommend that Congress pass legislation regulating greenhouse gas emissions, with the EPA acting as the enforcement agency. According to an EPA report, “climate change has the potential to produce significant increases in ground-level ozone in many regions, particularly for the highest-ozone events.”[iii]

Texas has many voluntary emission reduction programs such as the VMEP and TERP; however, these programs have not done enough to reduce greenhouse gas emissions. In addition, with the problem of population in the Houston area on the rise, transportation emissions will only continue to grow, according to the Houston SIP.[iv] Under the Obama administration, the EPA has already taken steps to begin regulating greenhouse gases from motor vehicle emissions with their CAA endangerment finding released two weeks ago.[v] The EPA’s endangerment finding clears the way for widespread federal regulation of greenhouse gases, including those from motor vehicles.

The obvious advantages to passing federal legislation regulating vehicle emissions are a real reduction of NOx in the air, which would result in lower levels of ground-level ozone, among other things. On the other hand, placing such widespread federal regulations on vehicle emissions will be difficult to implement and very hard to monitor. Many opposed to the ruling say that it will just produce a regulatory mess, with no way of reducing vehicle emissions. Another concern is the cost of legislation. For example, automobile makers may complain about the cost of new technologies and the cost that the consumer would incur. However, if national legislation were passed regarding greenhouse gas emissions, automakers should be able to successfully streamline their production, and would not have differing standards in different states. The federal government could also subsidize the automakers or the consumer until the cost of new technologies has been significantly reduced. Despite setbacks, if states were able to adequately enforce a reduction of greenhouse gases, ozone levels would be reduced.

Finally, due to the complexity of regulating on-road sources of NOx and VOC, a final recommendation I propose is for new initiatives and funding for the enforcement side of the Houston SIP. Control regulations already in place must be strictly enforced. For instance, monitoring of point sources, which contribute to 35 percent of ozone precursors, must be carefully regulated. This means more inspection teams and better monitoring equipment. If standards are not being met due to negligence or willful incompliance by industries, human health will continue to be endangered. The best way to make sure that current standards are met is to heavily enforce standards. I would hope that industry would not be opposed to enforcing the current law; however, I am certain some power plants and refineries are opposed. The people of Houston only stand to gain from enforcing the ozone NAAQS.


Ozone pollution in the Houston area is a serious problem that affects human health and welfare. Studies have shown that children and the elderly are endangered by increased levels of pollution on warm, sunny days. Also affected, are outdoor enthusiasts like my own father. While the federal government, through Congress and the EPA, has set NAAQS that address the problem of ozone pollution, the standards need to be tightened further. Houston has continuously ranked among the top 10 cities for ozone pollution and has been listed as a severe nonattainment area as of October 2008.[vi] In order to ameliorate the problem of ozone, the EPA should tighten the NAAQS, greenhouse gas emissions should be capped and regulated by state and national governments, and the Houston SIP should provide for tougher and stricter enforcement practices. If all of these actions were taken, ozone levels in the Houston area, and around the country, would decrease.

Until next time.

[i] Henderson, Dr. Rogene. “Clean Air Scientific Advisory Committee’s (CASAC) Peer Review of the Agency’s 2nd Draft Ozone Staff Paper.”

[ii] Vig, Norman, and Michael Kraft. Environmental Policy, page 196.

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

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

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

[v] Motavalli, Jim. “E.P.A. Takes On Tailpipe Emissions.”

[vi] EPA. “Clean Air Act Reclassification of the Houston/Galveston/Brazoria Ozone

Nonattainment Area; Texas; Final Rule.”


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