Money to Burn? EDF Questions Public Health Priorities at TCEQ


Flaring in Eagle Ford Shale

The Texas Tribune recently published a piece debunking some of the science behind the Texas Commission on Environmental Quality’s (TCEQ) position on the national health standard for ozone – one of the most ubiquitous and harmful air pollutants on the planet. As outlined in the agency’s latest newsletter, TCEQ’s Director of Toxicology, Mike Honeycutt, questions the benefits of a stronger standard, even though public health experts across the country have been calling for a more protective standard for years. What’s more disappointing than the agency’s apparent anti-health position, however, is the lack of attention to other legitimate air pollution issues in Texas.

It would seem that the agency must have a surplus of staff, as well as unlimited resources to establish such an aggressive position on a standard that hasn’t been proposed yet. The reality is that there are so many more important things that the agency could and should be doing to serve and protect Texas citizens from real air pollution threats, including: 

Flaring in Eagle Ford

A recent investigation by the San Antonio Express-News found that flaring in the Eagle Ford shale has increased 400 percent since 2009 and has resulted in 3.3 billion cubic feet of gas wasted in 2013 alone. The investigation mentions that residents have filed several complaints with state officials about poor air quality associated with flaring to no avail. To be fair, TCEQ has announced a new air monitor in the Eagle Ford, a move that the San Antonio Express editorial board says is “welcome, but it’s hardly the comprehensive approach that South Texans deserve.”

Benzene in Texas City

Almost a year and a half ago, EDF and Air Alliance Houston submitted comments to TCEQ opposing the agency’s proposal to delist Texas City from the air pollution watch list. We included a sophisticated modeling analysis suggesting that benzene concentrations could exceed the state’s screening level guidelines, as well as data demonstrating significant problems with the monitoring network used to assess air quality in Texas City. To date, the agency has failed to respond to the comments.

Air Quality in the Metroplex

Health care providers in Texas, such as the Dallas Medical Association, have called upon TCEQ to control pollution from some of the country’s dirtiest industrial facilities outside the Dallas metroplex area – all on deaf ears. Where has TCEQ been in addressing these critical concerns from those on the front lines of health care protection?


Some state officials and TCEQ would like us to believe that clean air is too expensive and not worth the cost, but the arguments put forward regarding cost (which by law cannot be considered in setting a health standard anyway) are unfounded. TCEQ’s criticisms of a stronger ozone standard rely on a report from the National Association of Manufacturers (NAM) that includes inflated cost estimates and completely ignores the health benefits of the ozone proposal. The Congressional Research Service cautioned that the cost estimates provided in the NAM report are unreliable, noting that the study is highly uncertain. NAM itself acknowledged that its conclusions were based on “limited information” and contained “substantial uncertainties.” It is unfortunate that TCEQ chooses to rely upon an assessment based upon such unrealistic assumptions.

Not only does TCEQ rely on unsubstantiated analysis regarding the cost of a stronger standard, but an economic study completed by TCEQ also contradicts its own position by showing that reducing ozone has not destroyed the state’s economy. In fact, TCEQ released an analysis demonstrating that gross domestic product in Houston has actually increased while ozone concentrations have gone down. And Environmental Protection Agency’s cost benefit analysis, covering a 30 year timespan, found that the Clean Air Act has returned benefits 30 times greater than the cost of implementation. Is there a better investment than in healthy air to breathe?

EDF calls upon TCEQ to reassess its priorities and to spend its valuable time and resources supporting clean air measures instead of trying to thwart vital public health protections.

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