Posts Tagged ‘Texas’

UPDATE:  Yes the Austin Drive Electric Event is still happening on Saturday 9/15/2018 (as of 9/14/2018 3:30 PM)

Guest submission by Michael Osborne, founding member and current Texas Electric Transportation Resources Alliance (TxETRA) board Chair. 

There is something to driving electric that is more than the sum of its parts.  Sure, they are faster (generally), they are quieter, you don’t have to breath dangerous chemicals to make them go, and there is some comfort in the fact that if you accidentally fall asleep in your car while parked in the garage, you actually will wake up.

Most electric cars are smarter than their smoking hillbilly cousins and they are definitely cheaper to drive.  Want to pay a dollar for gas… drive electric.  Want to never spend $129.00 dollars on an oil change, oil filter, and air filter again… drive electric.  Tired of waiting for your car as your mechanic finishes that brake job on your 3 year old car…drive electric.

Plus, you might experience what I experienced several months ago.  I was driving east on Hwy 290, a little faster than the speed limit, when this huge “dually” truck  (four tires on the rear axel) comes roaring around me.  It’s a real fancy black truck with shiny dual vertical chrome exhaust pipes running up on both sides of the cabin. There was probably some stickers that I didn’t read but I suspect that the long haired driver was a member of a political class that rhymes with bumper.

So this guy passes me, then abruptly slows down in front of me. Then, with the flick of some switch, he zooms off leaving a huge noxious black cloud of smoke in his tracks, with me in those tracks; I mean thick black smoke like a locomotive in a western movie.

I had been “smoked”.

And yes, that is a thing.

Surely, I deserved it in his eyes, I was driving the fastest, smartest car on the road in my judgment, and he needed to communicate his unhappiness with that. It was a first amendment thing.

So watch out for those smokers.

Personally, I’m on my second electric car.  The one I have now is all electric, and the one I had before was a plug-in hybrid. The plug-in hybrid went about 40 miles on electric fuel, and then if I needed to travel, the on-board generator would kick in.  There was zero range anxiety and as a cultural transition vehicle, it is pretty smart.  A plug-in hybrid embodies the 80/20 rule quite nicely.  With 80% of trips under 40 miles, then make those emission free trips.  When you drive to Memphis, do that with gas.

I don’t have that option with my “S”.  If I’m traveling out of town, I need to do a little planning.  Fortunately, the computer makes that easy.  One night I got down to about 25 miles before I pulled into the high-speed charger behind the discount mall at mile 202.  Within a few minutes, I had 120 miles again, and Austin was only 30 miles away. Most of the time I charge overnight and wake up to a car that is almost always full and ready to go.

But electric driving is different.  You don’t think of getting a fill-up.  You think of getting home.  Because, unlike a gas car, you get most of your “go” at home.

Electric Car sales are gearing up so to speak.

According to Bloomberg New Energy Finance, “cumulative passenger EV sales worldwide are set to hit 4 million this week.  Including electric buses, the 4 million threshold has already been reached. At the end of June, there were more than 3.5 million passenger EVs sold globally and about 421,000 electric buses, bringing the total number of EVs sold to 3.97 million.

Sales were driven in large part by China, which is responsible for around 37 percent of passenger EVs sold around the world since 2011 and around 99 percent of e-buses.”

Bloomberg goes on:

Setting e-buses aside, we expect cumulative passenger EV sales to reach 4 million units before the start of September 2018. There are several new EV models that we expect to come to the market before the end of 2018, which should help increase sales numbers globally.

The next million EVs will take just over 6 months. We expect the five-millionth EV to be sold in March 2019.


There is a professor at Texas A & M who considers himself an electric car expert.  He doesn’t believe that we will ever replace the advanced gasoline cars of today because they are just so good.

He also doesn’t drive an electric car.

He also doesn’t believe that climate change is a transcendent problem. That in order to get the carbon out of our world, we will need to run our cars on wind and solar.  And with enough electric cars, we will have enough stored energy to do it.

Driving Electric is more than the sum of its parts, because electric transportation is the building block to a carbon-free world.

September is a good a time to start because it’s Drive Electric Week from the 8th to the 16th.  Here in Texas, there will be events in Houston, Dallas-Fort Worth, Corpus Christi, San Antonio, and Austin.  The Dallas event is in Grapevine on Sept 8th, and the Austin event is on the 15th.

Join us in Austin on Electric Drive Saturday, September 15th, and climb into the driver’s seat of the newest electric vehicles available. There will also be the latest scooters, motorcycles, mopeds, buses, skateboards and bikes. Grab lunch from one of our food trucks and enjoy the live music, workshops and activities for kids!

Sponsored locally by Public Citizen, the Texas Electric Transportation Resources Alliance (TxETRA), Austin Energy, and SmartCharge America, it might be your opportunity to become part of the solution.

Hopefully, it will help keep us all from getting “smoked”.

Michael Osborne led the Plug-in Partners effort to develop the 10,000-plus  soft orders that led to the production of GM’s Chevy Volt.  In the 1980s, Osborne saw the potential of Texas’ vast wind and solar energy resources. He co-founded the Texas Renewable Energy Industries Alliance (TREIA) and The Wind Coalition, both of which successfully advocated policies that helped make Texas the No. 1 wind energy producer in the nation and fifth in the world for wind energy production.

The Texas Electric Transportation Resources Alliance (TxETRA) is a nonprofit organization composed of electric energy vehicle manufacturers, industry leaders, developers, distributors, producers, utilities, and environmental and transportation equity groups. Their mission is to guide and accelerate the adoption of electrical transportation in all its forms, in the most cost-effective way, providing maximum benefit to the citizens of Texas.

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We have been posting a lot about climate change impacts on our facebook page the past several months and when I read articles about a climate action plan goal of keeping global temperature rise to 1.5 or 2 degrees Celsius, I realize that that means very little to me intuitively (and not just because I am American and think of temperature in Fahrenheit), because I cannot translate that to my day to day life.  However, living here in Central Texas, I can relate to what a 100 degree temperature high is like.

Last week a co-worker forwarded a link to a New York Times page “How Much Hotter Is Your Hometown Than When You Were Born?” that lets you put in your hometown (or any location) and the year you were born, and it shows you the number of days over 90 degrees when you were born, today and by the end of this century.  Obviously, here in Central Texas, 100 is the benchmark by which we deem a day as really hot, and over the Labor Day weekend, Austin, Texas had logged 52 days of 100+ degree highs making it the 5th most in the area since our weather record keeping began.  One of the local weather stations also reported that this has been the 3rd hottest summer in Austin, falling below the years of 2009 and 2011.

Over the past several weeks, as I heard more and more people expressing their intolerance for the relentless heat, I started to think about my 40 years of summers here in Central Texas.  My recollection was that there used to be summers with fewer days at 100 degrees when I first moved here.  Rather than depend upon my intuitive statistics, I decided to look at historical highs for the past 40 years, and they in fact bore out my initial thesis that we were experiencing more high heat days since 1978.  Now I should point out that the City of Austin has grown from a population of 331,900 in 1978 to 950,715 in 2017 along with commensurate development, creating a heat island, but even areas that have not had explosive population growth such as Clovis, NM, when I plug that into the NY Times site it still showed increasing numbers of hot weather days.  That said, I decided to look at recorded high temperatures over 100 degrees Fahrenheit during the months of May through September from 1978 through 2018 in Austin, TX.  This is what I found.

  • Between 1979 and 1988 we averaged 6.5 days of 100+ degree days per year.
  • Between 1989 and 1998 we averaged 10.1 days of 100+ degree days per year.
  • Between 1999 and 2008 we averaged 18.7 days of 100+ degree days per year.
  • Between 2009 and 2018 we averaged 41.3 days of 100+ degree days per year.

Keep in mind we had 90 100 degree days in 2011, screaming past the previous record of 62 days, and perhaps skewing the average for this past decade, but even if we corrected for that the data is daunting, especially since Texas climate scientists are telling us that 2011 could become our new norm.

As you can see, yearly we can see weather patterns, but over time you can see the number of 100 degree days trending upward.

Again looking at this information graphed out, really drove home the trends of increasingly hot years, confirming my personal perceptions which I recognize can be biased based on other things going on in my life from year to year, such as having my air conditioning unit go out during a heat wave and having to endure the heat without AC for a couple of days before a service company could get to me because they were overwhelmed.  Or my conviction that 1987 was unendurable even though we had no 100 degree days that summer, but rather because I was in my 3rd trimester during the height of a central Texas summer, had gained 40 pounds and the volume of blood in my body had increased by a whopping 50 percent. 

So if you have a spare couple of days and want to actually look at high temperatures over time, you can do you own research using Weather Underground‘s actual recorded temperatures by day in your area.



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Photo by Stephanie Thomas

Flares along the Houston Ship Channel during Hurricane Harvey.

Public Citizen has been pushing back against the EPA’s rollbacks of the Chemical Disaster Rule. The Chemical Disaster Rule came into being following an explosion at a Texas fertilizer facility in 2013, an incident that killed 15 people and injured 160. The Chemical Disaster Rule would put further protections in place to better ensure the safety of communities surrounding facilities.

Under the Trump presidency, the EPA delayed the implementation of the Chemical Disaster Rule, which was finalized in early 2017. However, that delay was met with a legal challenge, Air Alliance Houston v. EPA. (Public Citizen’s Litigation Group provided an amicus brief to the court on this challenge).

On August 17th, an appeals court ruled that the delay of the Chemical Disaster Rule was unlawful. The judges went so far as to say that the EPA’s tactics made a “mockery” of federal statute. But even though the judges shut down the Trump Administration’s attempt to delay the Chemical Disaster Rule, the EPA is still looking to rollback the rule through a proposed reconsideration rule.

Photo By Stephanie Thomas

Petrochemical processing and storage stretches for miles along the Houston Ship Channel.

Houston’s Chemical Footprint

To better understand the impact of the Chemical Disaster Rule and the Risk Management Program under the EPA, Public Citizen analyzed data publicly available through rtk.net from facilities that are required to submit risk management plans. Basically, these are facilities that store or use large amounts of hazardous chemicals.

In our new report, we found that chemical facilities currently registered as RMP facilities use 2.4 billion pounds of toxic chemicals and 38.5 billion pounds of flammable chemicals in their processes. And the bulk–two-thirds–of those toxic chemicals reside in the eight-county area of the Houston region.

In the Greater Houston region, 442 facilities have reported to the Risk Management Program (RMP) database over the past 5 years, and 314 facilities meet the conditions that require them to report to the Risk Management Program (RMP) database as of April 2018. Among the 314 facilities that are currently reporting, there are 892 processes that could have offsite consequences. This means that should an accident happen, these processes could harm communities.

The RMP facilities within the 8 county region use 51 different toxic chemicals in processes, which total to over 1.6 billion pounds. Those chemicals include chlorine, chloroform, formaldehyde, and hydrofluoric acid. Many are known to be hazardous to human health, and some are carcinogenic. Those facilities also use 29.9 billion pounds of flammable chemicals, which is 78% of the total of flammable chemicals in RMP facilities across Texas.

Accidents and Injuries

Every five years, companies submit risk management plans. When data is pulled from rtk.net, it reflects companies’ latest submissions. For instance, Company Y’s last plan may have been submitted in 2018, but Company Z’s last plan was submitted in 2013. In that way, the information summarized here doesn’t necessarily  reflect an apples-to-apples comparisons, and is not entirely current. But all these RMP submissions taken together gives us a broader understanding of the chemical risks that Houston faces.

The report shows that 89 5-year accidents were recorded in the Greater Houston area. What that means is 89 accidents happened during the 5 years that the reports are compiling. For some companies that could reflect 2008-2013, for others it could be 2013-2018, or some other five year period in the mix.

For those 5-year accidents, 5 deaths and 112 injuries were reported. The amount of property damage from 5-year accidents exceeded $175 million. Again, because RMP facilities are supposed to provide reports every 5 years, this number does not reflect the amount of property damage that took place from 2013-2018; this number reflects the amount each facility has reported over the 5 years previous to their last RMP submission.

Chemical Safeguards

The Chemical Disaster Rule helps protect workers, first responders, and the wider community from potentially injurious or life-threatening chemical exposure. With 1.6 billion pounds of toxic chemicals in a region that is home to nearly 7 million people, let’s keep the rules that protect human life.

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By Briauna Barrera
August 27, 2018


This is a story about one city and two neighborhoods that exist within its borders. A tale of two geographies that exist in a microcosm. These two neighborhoods, separated only by ten minutes of time, might as well be across the world from each other, a difference in demographics creating a rift as wide as a sea. The four miles from one to the other creates the thin line between the “haves” and the “have nots”.

One of these neighborhoods, Monte Vista National Historic District, its very name exuding importance and wealth, is situated in central San Antonio, about two miles north from downtown. Monte Vista started development in 1889 in what used to be a goat pasture and is home to about 3,000 people spread over approximately 100 blocks. Originally considered a suburb, it is now praised by real estate websites for its close proximity to downtown and is considered part of the very heart of the city. It is a treat to walk around Monte Vista. The blocks have many old oak trees whose tall, lush canopies spread out and provide shade over lawns, sidewalks, and streets. The sidewalks exist, which is no small feat in San Antonio, with ample room to boot. The architecture is particularly notable in this neighborhood, as a variety of architectural styles exist within its boundaries, from Spanish colonial to European cottage.

The other neighborhood is Dignowity Hill, a similarly historic neighborhood. Founded in 1854, Dignowity Hill was the first residential neighborhood in San Antonio. It is located about a mile and a half from downtown, on the east side of I-37. This neighborhood may not have the architectural diversity of Monte Vista, but its abundance of mansions, Folk Victorian houses, and Craftsman Bungalows radiate coziness and charm. Like Monte Vista, Dignowity Hill started off as a place of affluency, settled by Dr. Anthony Michael Dignowity, a physician and Czech immigrant. After his and his family’s settlement, the neighborhood became known as a place for upper-class residents. However, with the introduction of the railroad in 1877, an increase of urbanization and a concentration of industry came to the area. By the mid-1910s, the neighborhood was surrounded by industry and by the 1920s, the wealthy residents were moving further out to newer housing developments and with the building of smaller houses and creation of working-class, industrial jobs, people of lower socioeconomic status started moving in.

Dignowity Hill became a poorer neighborhood as the decades went on. First the wealthy moved to the edges of the town to escape the ever growing expansion of urbanization and industry, and then after WWII, with the availability of Federal Housing Administration mortgage loans to returning soldiers and the mass development of suburbs, the United States saw a boom in its, primarily white, middle class. This left the urban core deteriorating as government and private funding funneled outside city centers and forced those who could not afford to leave – primarily people of color – to remain living in urban environments with degenerating conditions. Dignowity Hill was one of the core neighborhoods. Monte Vista never experienced this change in demographics because at its advent, it was considered a suburb. It was the place that wealthy people were escaping to and it stayed desirable once people began to move back into the city, as by that point, it was considered to be part of the city core. The history can still be seen today and are illustrated in the maps below.

Figure 1. Race and ethnicity (right) and education attainment for bachelor degrees (left). Monte Vista on top, Dignowity Hill on bottom.

Figure 2. Median income (right) and poverty (left). Monte Vista on top, Dignowity Hill on bottom.

San Antonio is the one of the most economically segregated cities in the country. Economic segregation is based on racial segregation in a country where racist policies such as red-lining was only made illegal in 1968 and others, such a gerrymandering, are still exist today. Those who have historically had access to wealth and power made sure to set up systems of governance and economics that ensured their continuing wealth, while ensuring the continuing poorness of other groups. As a result, black and Latinx people experience higher rates of poverty than white people. Thus, the economic segregation of San Antonio also translates to, in large part, to the racial and ethnic segregation of it as well. Our circular highway system conveniently categorizes the city into a pie chart of the segregation: northside is predominantly white, the southside and westside are predominately Latinx, and the eastside has the highest concentration of Black people. This segregation is perpetuated by systems like property taxes funding public schools so that schools in wealthy areas with high land value do well, while schools in poorer areas are unfunded, and city bonds that distribute money evenly over districts, even though districts are not evenly wealthy. This is why some city districts use their bond money for libraries and parks and others have to use them for infrastructure creation and maintenance. Just like the landscape of the Hill Country, we are not all on even ground.




During the summer of 2016 I did research on food deserts and community gardens in San Antonio. Part of this research involved surveying blocks of houses. Considering it was summer in Texas, it was miserable, but it was noticeably more miserable in neighborhoods in the westside and eastside because of a lack of trees (and often also a lack of sidewalks and the packs of stray dogs). These areas didn’t only feel hotter, they were hotter due to the heat island effect, the warming of urban areas due to greater human presence and activity. Trees help mitigate this effect, but there was also a noticeable difference in the tree density of these areas. When I was in these eastside and westside neighborhoods, there would often be little to no trees shading front lawns and sidewalks, much less shading the actual streets. Walking around, I could feel the sun bearing down on me from above while also reflecting up from the ground. No one wants to walk in environments like this. The times I have spent walking around Monte Vista have been far more pleasant, even during the summer, partly due to the presence of those great, old oaks providing shade and some degree of relief from the summer sun.


The utility of trees goes far beyond providing shade relief for pedestrians through:


Social Environmental


  • Improve concentration and learning 
  • Improve health and wellbeing 
  • Provide aesthetic benefits 
  • Increase the quality of life where we live, work, and play 
  • Trees absorb and block noise from the urban environment 
  • Screen harsh scenery 
  • Soften the outline of masonry, metal and glass 
  • Can be used architecturally to provide space definition and landscape continuity 
  • Create feelings of relaxation and well-being 
  • Provide privacy and a sense of solitude and security 
  • Shorten postoperative hospital stays when patients are placed in rooms with a view of trees and open spaces
  • Lower air temperature through shade 
  • Reduced surface runoff of water from storms 
  • Reduce air pollution 
  • Reduced soil erosion and sedimentation of streams 
  • Increased groundwater recharge that is significantly reduced by paving 
  • Lesser amounts of chemicals transported to streams. 
  • Reduced wind erosion of soil 
  • Increase humidity in dry climates through evaporation of moisture 
  • Reduce glare on sunny days
  • Reduce wind speed 
  • Increase biodiversity  
  • Help to settle out, trap and hold particulate pollutants (dust, ash, pollen and smoke) that can damage human lungs 
  • Absorb CO2 and other dangerous gases and, in turn, replenish the atmosphere with oxygen 
  • Produce enough oxygen on each acre for 18 people every day
  • Reduce heating and cooling costs 
  • Trees enhance community economic stability by attracting businesses and tourists 
  • People linger and shop longer along tree-lined streets 
  • Apartments and offices in wooded areas rent more quickly, have higher occupancy rates and tenants stay longer 
  • Businesses leasing office space in wooded developments find their workers are more productive and absenteeism is reduced 
  • Healthy trees can add up to 15 percent to residential property value 
  • Office and industrial space in a wooded setting is in more demand and is more valuable to sell or rent
Figure 3. Benefits of trees. Source: https://www.state.sc.us/forest/urbben.htm.

If those aren’t enough reasons, there are other resources that compile the research on the benefits of trees such as this one, this one, and this oneTrees come with many benefits and contribute greatly to increasing people’s standard of living, while also contributing to the environmental and economic health of areas too.  

However, San Antonio is segregated and where you live fundamentally shapes your opportunities, your access to education and healthcare, your mental health, your physical well being, how long you live, and even to some degree, your personality. Your social security isn’t the most important number you have, it’s your zip code. That inequality of access extends to tree coverage too (see figure 4).

Figure 4. Map of tree coverage in Dignowity Hill (right) and Monte Vista (left).

It is clear that Monte Vista has more tree coverage than Dignowity Hill. Considering the wealth of benefits trees give us, our environments, and our pocketbooks, we should be doing all we can to expand coverage for all of San Antonio, not just the ones who can afford it.




San Antonio has had a Tree Preservation Ordinance since 1997 and was officially declared a Tree City in 2016. Progress is being made, but it is concentrated in wealthy areas. That is not enough progress. This tree ordinance has a 40% canopy goal for the city. The ordinance also states that it can be strengthened as needed. Considering the tree canopy in San Antonio at 22%, it’s needed.

There are programs that do exist in San Antonio to encourage the spread of tree coverage, such as a rebate program from CPS, but more can and should be done. A report released in 2009 from the nonprofit, American Forests, recommends an increase in education about the benefits of trees, but even that isn’t enough because at the heart of this matter is the inequality of access. A rebate is great, but what if you lack the resources to purchase trees in the first place? A Tree Preservation Ordinance, but what if they area you live isn’t experiencing development like other areas are? Or worse, what if the area where you do live in, like Dignowity Hill, is experiencing development so much so you can no longer live there?

The larger issue of all of this is the displacement that comes from gentrification and lack of access that exists in these neighborhoods before gentrification occurs. They both need to be addressed. If more trees are planted, land values will rise, leading to an increase in property taxes and rent prices, which will eventually price out and dislocate the people that an increase in trees was supposed to benefit in the first place. The people that have lived there for generations leave, forced to live in low-access neighborhoods elsewhere before the process begins anew.

It would be great if planting trees could be a cure-all for the problems in San Antonio, but it’s only one action of many that need to happen. The root, systemic issues of poverty and racism need to be carefully and thoughtfully examined and tackled, not just the symptoms they create. Just as with trees themselves, it is the roots that give hold so much importance and yet, are so often overlooked.

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Texas VW Plan is a mixed bag

Volkswagen plant in Wolfsburg, Germany. (JULIAN STRATENSCHULTE / EPA)

Earlier this month, the Texas Commission on Environmental Policy (TCEQ) released it’s long-awaited plan to spend Volkswagen settlement funds–$209 million in all for Texas. Our first impression was that the plan was a mixed bag: some good elements, but also some head scratchers.

A preference for electric vehicles.

On the good side of things, Texas’ plan to spend VW funds charts a future for electric vehicles in Texas. The plan dedicates 15% of the funding–the maximum allowable amount–to the Zero Emissions Vehicle (ZEV) program, which will build electric vehicle (EV) charging stations around the state. Notably, while the plan does allow that ZEV funding could be used for hydrogen fueling projects, it includes the caveat that funding will only be given to hydrogen projects “where there will be a sustainable market for use of the hydrogen fuel.” Houston, with it’s robust petrochemical infrastructure that includes hydrogen pipelines, may be such a place.

The bulk of the ZEV funding, though, will go to electric vehicles charging stations. This means that Texas will spend $31 million on EV charging in the next few years, along with a 1-to-1 match of local funding for each project. You may also know that, due to a separate portion of its settlement agreement, Volkswagen has also started Electrify America, a company that will invest $2 billion in EV charging in the next ten years. (We have commented previously that allowing VW to start a for-profit company to install infrastructure for the benefit of its own products is hardly a punitive measure appropriate to the scale of its illegal acts, but for now we will just take note of the investment in EV charging that will ultimately benefit us all.)

The ZEV program in Texas will spend $31 million. The bulk of our VW funds, some $180 million, will go into a program that allocates funding to priority areas for a variety of clean transportation projects. The projects eligible for funding are:

Electric trucks like this one can be purchased with VW funds.

  1. Class 4 – 7 Local Freight Trucks
  2. Class 8 Local Freight Trucks and Port Drayage Trucks
  3. Class 7 – 8 Refuse Vehicles
  4. School Buses
  5. Transit and Shuttle Buses
  6. Electric Forklifts and Port Cargo Handling Equipment
  7. Electric Airport Ground Support Equipment
  8. Ocean-Going Vessel Shore Power

These categories create some very interesting possibilities. A few months ago we were critical of Houston’s proposal to purchase more than 75 diesel refuse trucks. Perhaps incentives for electric refuse trucks will encourage the city to purchase those in the future. And shore-power for ocean-going vessels could mean cleaner air for residents of the Houston Ship Channel, or even a cleaner cruise ship terminal in Galveston.

Our research in communities over the years has shown, unsurprisingly, that school bus projects are always very popular with the public. And I know from my days monitoring air quality in the Houston area that clean freight and drayage trucks are sorely needed in ship channel communities. All told, the $180 million eligible for projects in the above eight categories will, if invested wisely in zero-emissions technologies, be very good for public health in Texas.

There are three project categories eligible for funding under the VW Settlement Agreement that Texas has decided not to include in its draft plan. These are:

  1. Freight Switchers
  2. Ferries and tugs
  3. Diesel Emissions Reduction Act

We know from research by our friends at Environmental Defense Fund that freight switchers and ferries/tugs are among the most cost effective options available, measured by cost per tons of nitrogen oxides (NOx) reduced. TCEQ states that it left these projects out of the VW plan because they are already eligible under the TExas Emissions Reduction Plan (TERP), another state program for clean transportation projects. But in fact these projects are limited under TERP, with a stricter cost per ton of NOx cap than that for other projects. The rationale for this treatment in TERP is that these vehicles do not pay into the TERP fund as do passenger vehicles, trucks, buses, and other vehicles. The result is that freight switchers, ferries, and tugs are not eligible for VW funding and are disfavored under TERP. This is a shame, as these may be among the most cost effective projects.

Texas also left projects out of its plan that require a match with federal Diesel Emissions Reduction Act (DERA) funds. Texas says that it doesn’t want to bear the cost of administering DERA funding and that’s why those projects are left out of the VW draft plan. In fact Texas has declined DERA funds for the last few years, unrelated to the VW Settlement. We think that it is foolish to leave federal money on the table, but Texas does seem to have a habit of it (witness our disastrous decision to reject federal Affordable Care Act funding). We also don’t agree with Texas excuse that it doesn’t want to pay to administer DERA funds. Texas administers TERP, and now VW, at a cost of about 4% of the total funding available. Texas could administer DERA as well if it wanted Texans to have access to those clean transportation funds. Doing so would provide cleaner air to more Texans.

Austin is left out and Houston is left wanting.

When Texas allocated 81% of the VW funds to priority areas, it did so to within a hundredth of a percentage point, as follows:

Those percentages, along with what we know about the timing of the plan’s release, suggest that careful deliberation went into these allocations.

I don’t want to pit one region of the state against another, but I can’t help but wonder why San Antonio gets more funding than Dallas and Houston combined. Was Houston slighted because, in the words of Harris County Judge Ed Emmet, “They wrote us off as a lost cause.”?

And why was Austin left entirely out of the plan? It is well known that Austinites purchased more VWs per capita than other areas of the state. Texas’ VW plan takes great pains to define “impacted community” as one that has offending VWs AND doesn’t meet ozone pollution standards, a definition that could be used to exclude Austin. Texas also points out that VWs could have moved around the state after purchase, though the state offers no evidence to indicate that there are fewer VWs in Austin today than past purchase records would suggest. Taken altogether, the state’s justifications for which areas it included and excluded don’t add up. Governor Greg Abbott’s disdain for Austin is not a secret, and I wonder if this was another not political slight by him.

If the people of Austin have become players in a political chess match, then our children and elderly are the pawns that will pay first, and most dearly.

What you can do.

Between now and October 8, you can share your thoughts about Texas VW draft plan with the TCEQ. Send comments on the plan to [email protected]. You can also attend one of a series of meetings on the plan happening across the state (below). In the coming weeks, we will share more thoughts about what’s in Texas’ VW plan: the good, the bad, and the ugly.

September 10, 2018 2:30PM
Tracy Gee Community Center
3600 Westcenter Drive
Houston, TX 77042

September 11, 2018 2:00PM
South East Texas Regional Planning Commission
2210 Eastex Freeway
Beaumont, TX 77703

September 14, 2018 2:00PM
North Central Texas Council of Governments
616 Six Flags Drive
Arlington, TX 76011

San Antonio 
September 17, 2018 2:00PM
Alamo Area Council of Governments
8700 Tesoro Drive, Suite 100
San Antonio, TX 78217

El Paso 
September 19, 2018 10:00AM
Rio Grande Council of Governments
8037 Lockheed, Suite 100
El Paso, TX 79925

September 26, 2018 2:00PM
TCEQ Austin, Building E, Room 201-S
12100 Park 35 Circle
Austin, TX 78753


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Even as we struggle with heat waves, hurricanes, floods, wildfires, drought, and rising sea levels are as a result of climate change, the potential to sequester carbon in forests and soils offers hope. Humans have caused climate change by burning fossil fuels and disrupting the balance of nature, but there is an opportunity to restore these natural systems for carbon sequestration. Since we already used the carbon budget to keep global temperature increase to 1.5 degree Celsius, an action is needed to not only eliminate emissions but to recapture carbon dioxide that has already entered the atmosphere.

By stopping deforestation, and restoring degraded forests and soils we can combat climate change while improving biodiversity, soil productivity, and food security. Implementing better land management practices could be an important strategy to store carbon in the ground and lowering carbon emissions. Thus, curbing the rate of deforestation and improving land management and agricultural techniques should be a priority for policymakers at the federal and state levels in order to slow climate change, which has posed a significant threat to U.S agriculture.


Forests are one of the largest carbon sinks and are currently absorbing and storing 450 billion tons of carbon. Forests are not only important in storing carbon, but they also play a significant role in preventing floods, supporting wildlife, moderating extreme temperature, presenting cultural values and providing recreation. However, after the industrial revolution, people started cutting down and burning trees for construction, shipbuilding, and energy producing, which resulted in turning a large amount of carbon back into the atmosphere. Human activities are the main reason for releasing carbon dioxide back into the atmosphere, including through deforestation.

Between 2001 and 2017, 5.57 gigatons of carbon (Gt) was released into the atmosphere as a result of tree cover loss in the United States. The U.S is cutting trees to make wood chips and wood pellets and export them from ports in the Southeast to Western Europe. Last year, Southern U.S. was identified as the largest exporter of wood pellets in the world as a result of a 70 percent increase in wood pellet exports from Southern. In 2017, the U.S lost 2.3 million hectares (Mha) of forest equivalent to 175 metric tons (Mt) of CO₂ emissions. Continued deforestation will neutralize all climate action efforts and strategies.

Afforestation and Reforestation Opportunities:

Afforestation is the process of planting forests in areas that have never been forested, while reforestation is the recovering of forests in areas where forests were destroyed.  Reforestation and afforestation could make an important contribution to curb climate change and to improve the quality of air if managed appropriately. Thus, afforestation and reforestation are identified as negative emissions options since they are able to remove CO2 from the atmosphere.  Afforestation, reforestation, and improving land management and conservation practices as a means of solution for removing CO2 from the atmosphere have several benefits to the society and environment. Planting new trees and recovering forests protects against soil erosion, helps retain soil moisture, increases biodiversity, and controls flooding. Also, these efforts can enhance agricultural productivity and develop resilient food systems. Moreover, planting trees has lower cost and environmental impacts compared to other negative emission technologies such as Bioenergy Carbon Capture & Storage.

Enterprise 50 Year Tree Pledge Surpasses 12 Million Plantings, 100 Reforestation Projects.Photo by Eterprise holdings

Afforestation and Reforestation:

The main problem is that planting forests is not an instant solution, since it takes time for seedling trees to be matured. Also, if afforestation is not properly managed, it can result in a reduction of local biodiversity, the modification of particular biomes, the introduction of non-native and potentially invasive species, and lost revenue from agriculture. Native grasslands that are altered to forests may not contain the same habitat for local species, and ill-managed reforestation efforts may result in the production of a monoculture (the practice of growing a single tree species) that lacks not only plant diversity but reduces the number of available habitat types for forest inhabitants. In addition, the application of nitrogen fertilizers would have several negative impacts on the environment. The production of nitrogen fertilizer releases a group of potent greenhouse gases known as nitrous oxides, along with CO2. Nitrogen pollution is identified as a threat to the biodiversity of species and biodiversity loss is a major environmental challenge

Soil Carbon Sequestration Opportunities:

Soil is a major sink of carbon and can store twice as much CO2 than is in the atmosphere. Unfortunately, farming currently plays a significant role in releasing a large amount of carbon into the atmosphere. As a result of an increase in the global population and the demand for food, commercial planting with the use of nitrogen fertilizer has increased, and frequent harvesting has resulted in reduced carbon levels in the soil. However, there are several land management practices which help promote inappropriate farming techniques. “Soil Carbon Sequestration” is one of the techniques which implements as a tool to remove CO2 from the atmosphere and store it in the ground. Thus, soil as a carbon sink can play a vital role in agricultural strategies to curb climate change and offset greenhouse gas emissions.

Agriculture, forestry and other land use techniques that store CO2 in the ground offer an opportunity to mitigate climate change. Farmers can help soil hold more CO2 by making sure crop residue and animal manure re-enters the soil. However, the amount of carbon that soil can hold depends on several factors such as types of soil, regional climate, and characteristics of soil microbes. Healthy soils with more organic matter can store carbon while providing agricultural and environmental benefits. Soil carbon storage directly benefits farmers by improving soil fertility, reducing erosion and increasing resilience to droughts and floods.

Conservation practices such as agroforestry, no-till agriculture, planting cover crops, forest farming, and silvopasture all increase the amount of carbon that can be sequestered in the soil.

  • In agroforestry, crops are planted between rows of trees while the trees mature. The system can be designed to produce fruits, vegetables, grains, flowers, herbs, bioenergy feedstocks, and more. Agroforestry helps improve land productivity with several potential benefits for the communities such as reducing soil erosion, increasing plant growth, climate change adaptation, and increasing food security.
  • “Forest farming” also is a way to grow food, herbal, botanical, or decorative crops under a forest canopy that is managed to provide ideal shade levels as well as other products.
  • “Silvopasture” integrates trees with livestock and their forages on one piece of land. The trees provide timber, fruit, or nuts as well as shade and shelter for livestock and their forages, help animals from the hot summer sun, cold winter winds, or a heavy rainfall.

Soil Carbon Sequestration Challenges:

Land Management Techniques: Forest farming & Agroforestry methods to keep CO2 in the ground & improve soil fertilizing

The main problem is that the initiatives are all voluntary and have not been adopted on a large scale. Farmers are experiencing several barriers in the way of implementing smart agriculture. For example, tilling the soil is a traditional practice for controlling weeds, and shifting to no-till technique requires changing farm equipment and using other weed-control methods. Therefore, farmers have to encounter with the high costs of altering farm equipment and the risk of lower yields in the short-term.  Furthermore, the benefits of soil carbon-rich take a long time to be viable and the long-term benefits of healthier crops and resilient communities are spread among societies. Thus, incentives and subsidies play a vital role in encouraging farmers to invest in cultivating healthier soils and split costs of shifting to new techniques since implementing the sustainable land management practices is critical to curb climate change and keep CO2  in the ground.

However, in the Midwest, for instance, around 50% of U.S farmland is operated by renters, and around 80% of agricultural land is owned by a non-farming landlord. Therefore, it would be difficult to encourage investments in soil health because renting tenants face short-term costs but might not receive the long-term benefits. Thus, policy-makers should provide tax incentives and subsidies for renters and non-farming landlords to be able to apply the land management practices. Since enhancing soil carbon by practicing land management techniques can prepare us to be well adapted for the negative impacts of climate change on the agriculture industry, there is an imperative need to invest in this solution and develop more helpful regulations to improve farmland productivity and communities’ resiliency.

Overall, fixing these barriers need providing the greatest financial and technical assistance and improving research and development (R&D) efforts as well as increasing private partnerships and offering incentives for farmers and renters. Improving the land management practices and the climate-smart agriculture is required a coordination and integration between various sectors dealing with climate change, agricultural development, and food security at the national, regional and local level. Local governments can provide tax credits for private companies to invest in different types of research with an emphasis on supporting soil carbon storage and to encourage them to offer useful consultant for farmers.

In Conclusion:

Well-managed natural systems carbon sequestration projects, along with the arrangement of sustainably produced timber, agriculture, and energy will produce numerous benefits including additional income for rural development, improve communities’ resiliency, and promote conservation programs. In order to improve climate change mitigation and sustainable development programs, governments must carry out the resolution of sustainability practices and oversee the implementation of these practices. The success of carbon sequestration projects will depend on the high carbon prices and aggressive emission reduction goals. Also, the political willpower plays an important role in prioritizing forestry activities and land management practices as part of mitigation portfolios. Care should also be taken to avoid unintended environmental and socioeconomic impacts that could threaten the overall value of natural systems carbon sequestration projects.


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What does it mean to make a climate action plan “Paris compliant”?  You may have heard this phrase, but do you really know what it means?  “Paris” refers to the Paris Climate Agreement of 2015, which every nation in the world except the United States is committed to. “Compliant” refers to the goals set in the agreement to keep global temperature increase to well below 2 degrees Celsius, and attempt to limit warming to 1.5 degrees, compared to pre-industrial temperatures.  So, what does that mean for a city wanting to do its fair share to avert climate crisis?

1.5 vs. 2 Degrees Celsius

The Paris Climate Agreement names two goals, but which one should we focus on – limiting warming to 1.5 or to 2 degrees Celsius?  Half of a degree might not sound like much, but, as NASA puts it, it’s a “big deal.”  That’s because the temperature increase won’t be spread out evenly over the area of the Earth or evenly throughout the year or time of day.  Some places and times will see much greater increases, resulting in more extreme weather. Heat-waves would be longer, rainstorms more intense, sea levels would rise further, tropical coral reefs would be totally destroyed, and agriculture would be hit harder.

There’s also a strong equity argument to be made for the 1.5 degree Celsius goal.  The Alliance of Small Island States (AOSIS) advocated for this more protective goal during the Paris Climate Agreement negotiations because their very existence is threatened by climate change.  Rising sea levels are already making some low-lying coastal areas uninhabitable, and a 2 degree increase would completely inundate many of the 44 low-lying AOSIS member countries.

Beyond the clear and present threat to low-lying nations, warming has been and will continue to be most pronounced in the tropics, which includes many poorer nations.  And poor people around the world will be most negatively impacted by climate change because the poor often live in more marginal areas – in flood plains or in drought-prone regions – and because the poor lack the resources to cope with extreme weather.

Global temperatures have already increased by about 1 degree Celsius and climate change is causing health problems.  As this trend continues, those without access to medical care or living in flood plains will struggle to cope.

Global Carbon Budget

Understanding the concept of the global carbon budget (which is really a greenhouse gas budget) is important.  Fundamentally, limiting warming requires limiting the total quantity of greenhouse gases released into the atmosphere, with emissions accumulating in the atmosphere year after year.

Determining an exact number is challenging and various climate models yield different results.  Some models indicate that the carbon budget for limiting warming to 1.5 degrees Celsius has already been exceeded.  The Intergovernmental Panel on Climate Change (IPCC) recognizes the need for additional analysis of the carbon budget to meet the 1.5 degree goal and is working on a report focused on this topic.

In the meantime, the carbon budget values provided in the IPCC 2013 AR5 Synthesis Report are the most comprehensive source of guidance because they include all GHGs from all sources, identify pathways to likely (defined as a two-in-three chance) meet the 1.5 and 2 degree Celsius goals, and are based on modeling out to 2100.  Using the IPCC budget for the 1.5 degree goal, and accounting for emissions since that report was released, the remaining carbon budget at the start of 2017 was 162.02 gigatonnes.  Limiting emissions to this amount would give us a 66% chance of limiting warming to 1.5 degrees Celsius.

A 66% chance of success also translates to a 34% chance of failure.  Failure to preserve a livable climate.  Ideally, we would aim to keep cumulative GHG emissions well below this budget to increase our chances of keeping to 1.5 degrees Celsius of warming.

Negative Emissions

Past inaction to reduce GHG emissions now makes negative emissions, or carbon sequestration, necessary to meet the goal of limiting warming to 1.5 degrees Celsius and likely even to meet the 2 degree goal, but the assumed scale of such efforts can easily be overestimated.  The vast majority of the climate models relied on by the IPCC – and therefore, the underlying Paris Climate Agreement – assume massive negative emissions.  While there are existing technologies and techniques for achieving negative emissions, all face significant challenges, including cost, other impacts on the environment, and use of land needed to feed the growing world population.  Recent research suggests that negative emissions technologies are more limited than climate scientists have assumed in their modeling.

GHG Emissions Reductions Goals for U.S.  Cities

The realities of the carbon budget and limits of negative emissions technologies makes a rapid reduction in greenhouse gas emissions necessary to avert climate crisis.  While meeting the goals set in the Paris Climate Agreement is still possible, there is no time to waste on inactionNet zero global GHG emissions must be reached by around 2050, and substantial near-term emissions reductions are critical.

C40 has developed a roadmap, called Deadline 2020, for how cities can translate these global goals and carbon budgets to local goals and actions.  The emissions reduction curve for a given city depends on how much greenhouse gases the city emits and how much wealth the city has.  Compared to the global average, U.S. cities are high emitters and have high wealth (defined as greater than $15,000 per capita gross regional product per year).  The Deadline 2020 roadmap calls for such cities to get on a “steep decline” GHG emissions trajectory, with emissions reaching zero before 2050.  The roadmap makes it clear that wealthy, high emitting cities, such as those in the U.S. must take significant action prior to 2020 to make it possible to achieve the 1.5 degree goal.

The good news is that more and more cities are engaging in climate planning.  In Texas, that includes Austin, San Antonio, Houston, and hopefully soon Dallas.  While each city has its own challenges and opportunities, the C40 Deadline 2020 roadmap can and should be used to set fair, science-based goals.

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As global temperatures continue to rise along with CO2 emissions, leaders in need of solutions should be cautious when considering the potential of bioenergy with carbon capture and storage (BECCS).  While the wholesale success of these technologies was assumed in many of the climate models used in developing the Paris Climate Agreement in 2015.

In the 2015 United Nations Climate Change Conference, the world agreed on implementing greenhouse gas mitigation plans which focus on producing negative carbon dioxide emissions to help curb climate change.

Illinois Industrial Carbon Capture and Storage Project. Capture CO2 from ADM’s Decatur corn processing facility and store it underground.

Bioenergy with carbon capture and storage (BECCS) facilities generate electricity by burning trees and crops that have taken CO2 from the atmosphere throughout their lifetime. When the biomass is burned, BECCS facilities capture the CO2 emissions and store them or, more often, use CO2 in order to enhance oil recovery (EOR). BECCS is one of the technologies the potential to achieve negative emissions if easy-to-grow feedstocks, such as switchgrass, are grown with sustainable practices and the captured CO2 is sequestered. However, these conditions don’t currently exist at commercial facilities.

BECCS Case Study: Illinois Industrial Carbon Capture and Storage Project

In April 2017, the U.S Department of Energy (DOE) announced that the Illinois Industrial Carbon Capture and Storage (ICCS) project at Archer Daniels Midland Company’s (ADM) Decatur corn ethanol facility had begun operations by injecting carbon dioxide into a large saline reservoir. The ICCS project stores more than 1 million tons of CO2 a year. The project captures CO2 from ADM’s Decatur corn processing facility, and stores it almost a mile and a half underground. The total project cost is $207.9 million and it has received a cost-share agreement of $141 million investment from the Department Of Energy. The project team members include ADM, Schlumberger Carbon Services, Illinois State Geological Survey (ISGS), University of Illinois, and Richland Community College (RCC). The technology demonstrated for this project aimed to help the development of the regional CCS industry (i.e., enhanced oil recovery in the depleted oilfields in the Illinois Basin).

Although the main purpose of BECCS technology is to reduce greenhouse gases and help combat with climate change, practically, CO2 has been captured in order to enhance oil recovery, which will result in more CO2 in the atmosphere. As the world’s focus is on keeping global temperature below 2 degree Celsius, using carbon capture storage (CCS) and BECCS in this way will perpetuate the use of fossil fuels. Also, emissions from the transportation of feedstock and the use of nitrogen fertilizer for growing crops could be a big challenge and accelerate the trend of global warming especially associated with ozone destruction.

The Illinois Basin Decatur facility and the EBCCS plant as a whole emit more CO2 than the BECCS plant has been designed to capture. The graphics info provided by Carbon Brief shows that the total CO2 emissions have been emitted by Decatur facility over 2.5 years of the operation was 12,693,283 tons of CO2. However, the EBCCS plant only absorbed 2,095,400 tons of CO2 which means that Decatur facility as a whole has emitted 10,597,883 tons of CO2 even with BECCS capacity. Thus, this project failed to fulfill the purpose of reducing carbon and curbing climate change.

The Illinois Basin Decatur Project. By Rosamund Pearce for Carbon Brief.

Caption: The Illinois Basin Decatur Project.  By Rosamund Pearce for Carbon Brief.

Challenges and Concerns of BECCS Projects:

  • High Cost of Capturing and Storing Carbon: It costs $100 to capture a ton of CO2 for a biomass plant. Whereas, fossil fuel plants are capturing carbon for about $60 a ton. This difference is based on varying bioenergy feedstock prices; energy production process; and capture technology. Also, transporting large amounts of biomass long distances to the storage site would significantly add to the cost of BECCS, since biomass tends to have a lot of weight relative to its energy.
  • Transporting CO2 to the reservoirs via pipelines or trucks: The transportation networks are costly and also turn more CO2 back into the atmosphere. More infrastructure – such as pipelines – would need to be built, which increases the cost of BECCS and indirectly results in more emissions through the construction process. Also, CO2 leakage from pipelines or storage sites could endanger people, harm marine ecosystems, and threaten freshwater ecosystem. Navigating the property rights of local communities can also be a challenge.
  • Effects of increased fertilizer use, such as nitrogen: Nitrogen fertilizers can be leached into the groundwater and washed into waterways, resulting in serious health, environmental, and economic damage. Nitrogen fertilizers applied in agriculture can add more nitrous oxide to the atmosphere than any other human activity. Nitrous oxide also moves into the stratosphere and destroys ozone which could result in increasing global heat. Nitrogen pollution is identified as a cause of decline in native species and is a threat to biodiversity for vertebrate, invertebrate and plant species. A study found 78 federally listed species identified as affected by nitrogen pollution. Use of fertilizer nitrogen for crop production also influences soil health, by reducing organic matter content and microbial life, and increasing acidity of the soil.
  • Water concerns: Agriculture and power generation are highly water intensive. In order to produce 1 ton of ethanol, 3.5 t of CO2 and 5 t of H2O is needed, which means that more than 21,000 t of CO2 and 300,000 t of water vapor are consumed each year. However, more than 3 billion people are already affected by water scarcity so it is a critical challenge in utilizing BECCS technology.
  • Food Scarcity: food prices would increase as a result of changes in land use. Also, since climate change has already threatened the crop yields harvest, sudden changes in the weather could result in food shortage or even famine in some regions. Altering lands to a specific crop yield would affect the land quality and may result in regional resource shortages.
  • Geological storage sites for CO2: In the fertile Midwest of the U.S., croplands are too far from geologic storage to be a viable location for BECCS in the near-term. There are relatively few pipelines in place for transporting CO2 and the long-distance transportation of large volumes of captured CO2 is expensive, particularly if many small pipelines have to be built. Biomass could be transported to sites where CO2 storage is available, but that would significantly add to the cost of a BECCS project.
  • Land Use challenges: Could displace or expose small farmers to the volatility of world markets. Also, as a result of changing land applications, soil erosion, and degradation could happen and soil would lose its fertility. Poor management of bioenergy crop production can result in soil carbon loss from direct and indirect land use changes and significantly affect the net amount of CO2 removed by BECCS. In addition, land rights of farmers & ranchers should be considered as important challenges as well.
  • Cost of Ethanol Production: Depending on a cost of a barrel of oil and production cost of gasoline refining, ethanol can either increase or slightly decrease the cost of a gallon of gasoline.

Overall, even though the U.S has a large potential for geological storage sites, there is still a need for transportation systems for either biomass or CO2 for the large-scale deployment of BECCS. Also, concerns associated with the land, water, and fertilizer use that would be required at the large-scale deployment of BECCS make the long-term economic viability of this technology uncertain. Tax incentives such as 45Q might cover some parts of the related costs, however, the health, environmental, and economic impacts of this project on the society is still unclear as well.

Overly optimistic assumptions about quickly achieving negative emissions on a large scale are dangerous. The world carbon budget is running out for 2 degree Celsius and we have already used the 1.5 degree’s carbon budget. While investments in BECCS are needed, these technologies do not give us a license to postpone eliminating emissions from other sources. And BECCS is only a solution if sustainable agriculture practices are employed, CO2 emissions are permanently sequestered and not used for oil recovery, and project sites are carefully selected to reduce emissions from transportation.

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On Monday, July 30, 2018, Public Citizen and the Sustainable Energy and Economic Development (SEED) Coalition submitted comments to the NRC on an application from Holtec seeking a license to put an “interim” storage site for the nation’s deadly high-level radioactive waste, which they anticipate will be for 120 years.  An unsafe, de facto permanent dump site could be created and the waste might never move again if there is no political will or inadequate funding in the future for a permanent waste site. The company plans to transport 10,000 canisters of irradiated reactor fuel rods from around the county and store them near the surface in New Mexico, inviting disaster and creating massive risks. This is more waste than has been created by all U.S. nuclear reactors to date.

“There is everything to lose with this plan to bring the nation’s high-level radioactive waste to New Mexico. The risks to health, safety, security and financial well-being are immense and people need to act now to stop this massive mistake that imperils people in New Mexico as well as along transport routes throughout the country,” said Karen Hadden, director of the Sustainable Energy and Economic Development (SEED) Coalition, who has been working with local opposition groups for months opposing this application and a similar one just across the border in Andrews County, Texas.

The application has been assigned docket number NRC-2018-0052-0058.  We have heard thousands of comments were submitted in opposition to this license application, but expect it will be some time before NRC’s website reflects the actual number of comments submitted, so don’t be fooled by the low number of comments reported on the website.  We had 10,561 people submit comments via our action page and thousands signed comment letters that were submitted by local New Mexican citizens.  On Tuesday after the comment deadline, a Nuclear Regulatory Commission spokesperson told a reporter with the Santa Fe New Mexican that they had received more than 2,300 public comments – the overwhelming majority in opposition to the project, but they wouldn’t have a definitive tally for a few weeks.

The application for the site in Andrews, Texas by Waste Control Specialists (WCS) has been resubmitted after the company was bought by private equity firm J.F. Lehman & Co. this Spring and is moving forward.  We expect to be submitting comments for that application by the end of the year.

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Earlier this month, I visited Exploration Green, a former golf course that local residents have helped to transform into a storm water detention basin and green space.

Located in Clear Lake, TX, Exploration Green finished its first phase in March 2018, and has 3 more phases to go. Yet even before Phase 1 was completed, Exploration Green is already paying off for residents of Clear Lake.

Hurricane Harvey

Rains from Hurricane Harvey hit the Clear Lake area strongly, and the detention basin, then under construction, held 100 million gallons of rainwater and prevented about 150 homes from being flooded. Exploration Green serves as a model for what Houston and other flood-prone areas can do to manage storm water.

Wetland Restoration

Profound development in the greater Houston area led to the loss of 20% of Harris County’s freshwater wetlands between 1990 and 2010, a loss of 15,855 acres. And as Harris and surrounding counties continue to be developed, more and more freshwater wetlands will be lost.

Wetlands serve an important function. They clean polluted runoff that enters Galveston Bay, and without them, the health of Galveston Bay will suffer.

Exploration Green has been working with Texas A&M’s Texas Coastal Watershed Program to design and build storm water wetlands that can enhance the environment and provide habitat for the many creatures that call the Clear Lake area home.

Putting It All Together

A recent report in the journal PLOS ONE states that the cost of flooding along the Gulf Coast will range from $134 and $176 billion by 2030, and the annual risk of flooding in the region is expected to more than double by 2050. This is due to climate change, land subsidence, and the concentration of assets in the coastal zone.

Nature-based solutions like the storm water detention basins and wetlands at Exploration Green are a cost-effective way to help mitigate flooding in communities in Houston. Communities can and should used them alongside policy measures and other infrastructure improvements to enhance our resilience to floods.

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Carbon Engineering’s direct air capture facility sucks CO2 directly from the atmospheric air. – Carbon Engineering

To maintain climate, we need to cut greenhouse gas – especially carbon – emissions down to zero. The more greenhouse gases that are released, the hotter our planet will be. If we are seeking to keep the global temperature below 1.5-2 degree Celsius, we need to find a way to reduce CO2 emissions. Direct Air Capture (DAC) is a technology which sucks CO2 out of the atmosphere by using large fans that move air through a filter to generate a pure CO2 stream. Depending on the application of the captured CO2, DAC can be either a “carbon recycling” or “carbon removal” technology. Carbon recycling refers to the process of using CO2 produced by DAC as fuel, or in other ways which will release CO2 back into the atmosphere, such as to carbonated beverages. Carbon removal requires CO2 to be stored underground or used in materials that do not allow CO2 to be released into the atmosphere, such as in cement or plastics.

DAC Carbon Recycling Case Study: Carbon Engineering

Recently, “Carbon Engineering,” a Canadian-based company leading the commercialization of direct air capture technology, have been working on Air to Fuels project, which uses renewable electricity to generate hydrogen from water, and then combines it with CO₂ captured from the atmosphere to use it as an input to produce synthetic fuels that can substitute for diesel, gasoline, or jet fuel. DAC’s cost at a commercial scale is not exactly determined yet. However, the latest estimate cost announced by Carbon Engineering is a range cost from $94 to $232 per ton for capturing CO2 and they hope to produce fuels from the Air2fuel project for less than $1.00 per litter, once it scaled up.

DAC Carbon Removal Case Study: Climeworks

Direct air capture unit along with the cooling towers of the geothermal power plant in Hellisheidi, Iceland. (Climeworks/Zev Starr-Tambor)

Swiss firm Climeworks recently launched the world’s first “commercial” direct CO2 capture plant at Hinwil, Zurich. Climeworks has been working on CO2 for carbonated drinks and renewable fuels project through the partnership with CarbFix which working on the project of dissolving CO2 into drinking water. Also, the Gebrüder Maier fruit and vegetable company uses the captured CO2 to boost the growth of cucumbers, tomatoes, and aubergines in its large greenhouses. However, the most interesting project which is designed to be a carbon removal project is happening right now! Climeworks recently launched a pilot project in Iceland which is a geothermal power plant with direct air capture technology. The facility is capturing 50 metric tons CO2 from the air each year, which is equivalent to a single U.S household or 10 Indian households. The CO2 captured in order to convert the emissions into stone. Thus, they’re making sure that CO2 doesn’t escape back into the atmosphere for the next millions of years.

Climeworks / Julia Dunlop Carbon capture from ambient air goes commercial

Pros of DAC:

  • Full-scale operations are able to absorb significant amounts of carbon, is equivalent to the annual emissions of 250,000 average cars
  • DAC system can be sited anywhere which reduce the cost of transporting CO2 to the sequestration sites
  • DAC can be scaled easily and has a relatively small land footprint in comparison to other carbon removal technologies such as Bioenergy Carbon Capture Storage (BECCS)
  • DAC system produces fuels with 100x less land use footprint and less water use than biofuels.

Cons of DAC:

  • Energy Intensive: Direct air capture is a fairly energy intensive process because the concentration of CO2 in ambient air is relatively low. Separating CO2 from the air is challenging since it takes a significant amount of energy and air to separate and concentrate CO2 in the atmosphere. Thus, large volumes of air must be processed in order to collect meaningful amounts of CO2
  • Very Expensive: Currently, it is not a financially viable option because it is very expensive. The cost of CO2 captured from the atmosphere ranges between $94 and $232 per ton according to Carbon Engineering estimate
  • Water consumption concern: One study estimates for removing 3.3 gigatons of carbon per year, DAC could expect to use around 7.925e+13 gallons of water per year (assuming current amine technology, which is what Climeworks uses). This is equivalent to 4% of the water used for crop cultivation each year. Carbon Engineering using sodium hydroxide that would use far less, but this, in turn, is a highly caustic and dangerous substance
  • Revenue Opportunities: Revenue opportunities for DAC carbon removal systems depend on carbon markets and regulations. Without high enough carbon prices, DAC systems are likely to find the largest revenue opportunities by providing CO2 for manufacturing fuels, enhanced oil recovery, greenhouses and carbonated beverages, as DAC systems can be sited anywhere.

Climeworks direct air capture plant founders Christoph Gebald and Jan Wurzbacher onsite. Climeworks / Julia Dunlop

Policy Approach:

There have been some policies that provided a shift toward greater development and deployment of carbon dioxide removal and recycling. In February 2018, the U.S budget bill passed by Congress which extends and reforms the federal Section 45Q tax credit. 45Q provides credits for businesses that use CO2 for enhanced oil recovery (EOR) and for CO2 injection into underground geologic formations. Mostly, the 45Q tax credits benefits fossil fuels industry. Based on the bill, any new fossil-fuel power plant or carbon-dioxide producing industry that commences construction before 2024 is eligible for tax credits for up to 12 years. The tax credits offered up to $35 per metric ton of carbon dioxide captured if the CO2 is put to use (pushing out oil from depleting fields is the most popular use) or up to $50 if it is simply buried in underground storage. Hence, the bill benefits fossil fuels companies at a lower cost of carbon capture and help fossil fuels companies expand oil production, and continue to build coal plants. Thus, the carbon removal companies are not willing to sequestrate carbon when there is a market for selling it. The only way to make money off sequestration is if the government is directly subsidizing it or if there is an extremely high carbon price. Currently, there is no carbon price anywhere in the world great enough to make sequestration profitable. At present, carbon is trading at a low price in the global market compared to the cost of storing it underground.

However, tax credits could make negative emission projects more financially attractive and more economically viable. Based on the incentives provided by 45Q bill, direct air capture could be a critical tool for CO2 removal since it has a countless potential for removing carbon and reuse it. Since the high cost of the technology in pilot projects has been an obstacle to a large-scale implementation, hopefully, new regulations and tax credits such as 45Q bill ease the process and lower the costs. Although the tax credit will not cover the full cost of these technologies, it will make a noticeable reduction in the operating cost.

Tax credits and regulations mean greater opportunities for developers and suggest positive movement in wider efforts to stem climate change, as carbon capture and storage is widely considered to be a significant element of addressing climate change. Recently, several private investors and fossil fuels companies have started investments in DAC technology. Especially, the oil and coal industry since the captured CO2 can be used for Enhanced Oil Recovery (EOR). However, utilizing DAC technology to develop EOR would neutralize any efforts regarding climate mitigation actions.

Direct air capture could hold the promise of capturing CO2 from the atmosphere. However, since there is an economic benefit of using CO2 to make fuels or for enhanced oil recovery, fossil fuels industry are making money off the technology. In a time that there is relatively little carbon budget left to keep the world temperature below 1.5C or 2C, nations need to focus on cutting CO2 emissions rapidly by shifting their reliance away from fossil fuels to the renewable energy, in particular. (more…)

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The Texas Hill Country is 18,000 square miles of natural wonders, economic resources, and a cherished way of life. In this unique place, the boom of construction and growth is sweeping in. In fact, Comal County is now the second fastest growing county in the United States.

Unfortunately, the Hill Country’s natural resources and beauty are endangered by the aggressive aggregate industry seeking air quality permits for quarries and cement plants throughout the region. The aggregate industry includes concrete batch plants, rock crushing operations, and hot mix asphalt plants. The 17-county expanse of the Hill Country is located just to the north and west of fast-growing San Antonio, Austin, and the rapidly urbanizing Interstate Highway 35 corridor connecting these cities. Many unincorporated areas of the Hill Country are now in the crosshairs of the demands of the aggregate and concrete industry, putting public health and natural resources at risk.  

In 2017, Vulcan Construction Materials (VCM) submitted a permit application to the Texas Commission on Environmental Quality (TCEQ) to convert Comal County’s “White Ranch”, a 1500-acre parcel of pristine ranchland between Bulverde and New Braunfels, into a limestone rock crushing plant.

(The proposed site will reside amongst 6,000 properties and have about 12,000 residents within a 5-mile radius. Vulcan Quarry -center)


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It is never comforting to see the words “lost” and “radioactive material” appear in the same sentence. But, somewhere in West Texas, a seven-inch steel rod containing a mixture of americium-241 and beryllium is rolling around lost among the purple sage.  Halliburton misplaced the radioactive rod somewhere between Pecos and Odessa on September 11, 2013 and we have not seen any reports that it was ever recovered.

But wait, there is more.

A transport carrying 22 tons of low-level radioactive waste in route to the WCS low level radioactive waste site just outside of Andrews, Texas was lost for nearly a month in 2001. This waste was later found abandoned on a north Texas cattle ranch covered over with dirt. The driver of the transport was nowhere to be found.

And more . . .

Two security experts from the Department of Energy’s Idaho National Laboratory drove to San Antonio, Texas, in March 2017 with a sensitive mission: to retrieve dangerous nuclear materials from a nonprofit research lab there and ensure that it didn’t fall into the wrong hands. While in Texas, their car was broken into and the radioactive chemical elements were stolen. The experts, brought the samples of plutonium and cesium to compare with the material they had come to recover. After spending the night in a hotel off of Loop 410 in San Antonio, they awoke to find their car window had been smashed and the testing material was gone. More than a year after the incident, the material is still missing. No public notice was made after the substances disappeared, and officials still are not commenting on the missing radioactive material. In fact the public knew nothing about this incident until the Houston Chronicle and the Center for Public Integrity reported on the story earlier this week on Monday.

So why are we writing about these incidents?  These are terrifying because they were probably not a carefully planned terrorist attack, but rather more likely a comedy of errors.  What you should find even more terrifying is the speed at which the license permitting process for not one, but two “interim” high-level radioactive waste storage sites is progressing.

Holtec is seeking a permit for “interim” storage of the nation’s deadly high-level radioactive waste in Southeast New Mexico, just outside of Hobbs.  The permit is for temporary storage which it defines as 120 years.  But looking past the license parameters, a commercial, unsafe, and de facto permanent dump site could be created, where the waste might remain forever if there is no political will to move it or if there is inadequate funding to do so.

WCS, Waste Control Specialists, in Andrews, Texas is also seeking a similar permit to store high-level radioactive waste at their site, since their successful bid to store low-level radioactive waste turned out to be not as lucrative as they had hoped.

The two companies plan to transport around 14,000 canisters of irradiated reactor fuel rods from around the country and store them slightly below or on the surface in these two states a mere 60 miles apart, inviting disaster and creating massive risks. This is more deadly waste than has been created by all U.S. nuclear reactors to date and many New Mexicans and Texans would be affected by its relocation and transport, not to mention the communities around the country along the transport routes from the 104 nuclear power plants throughout the United States.

Holtec’s permit application is a bit further along than WCS’s (who pulled their permit from consideration during negotiations to sell the company back in the Spring) and you will have one last chance to submit comments to the Nuclear Regulatory Commission (NRC) regarding the Holtec application.  Comments are due by July 30, 2018, and can be made online at NoNuclearWaste.org or https://action.citizen.org/p/dia/action4/common/public/?action_KEY=13813

We expect the NRC will begin public hearings and take public comments for the WCS application in the next couple of months and will let you know how to submit those comments at that time.

In the meantime, Congressman Joaquin Castro, D-San Antonio, has written a letter to U.S. Secretary of Energy Rick Perry demanding answers about the undisclosed amounts of plutonium and cesium stolen from the backseat of the vehicle in San Antonio.  Castro also asked for a list detailing all incidents in the past five years of missing radioactive materials in Texas. He asked for written answers to his questions, as well as an in-person briefing for himself and other members of Congress. So we may be hearing about additional incidents in the coming months.

So if you find the three incidents of missing radioactive waste disturbing, when there is currently little transportation of such materials, just think about what could go wrong with thousands of metric tons of high-level radioactive waste crossing the country.  Whether you live in New Mexico, Texas, near a nuclear plant or anywhere along a highway or rail line that could be transporting this waste, you should have a say in this plan.  Your only opportunities are upon us now.

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Dallas Needs A Stand Alone Climate Plan

Taking a Stand

On Friday, June 2, 2017, Mayor Mike Rawlings released a statement in response to the United States’ withdrawal from the Paris Climate Agreement regarding reducing global warming emissions. Under the title of “Dallas will continue to be a leader on climate action,” the Dallas Mayor noted:

“Climate change should not be a partisan issue.  I disagree with any decision that undermines our nation’s leadership role in the fight to mitigate the effects of climate change.  Dallas is a leader in emissions reduction efforts, and we have had significant success in reducing our carbon footprint. I am asking our staff to continue to develop and maintain programs that improve regional air quality, reduce carbon emissions and otherwise address climate change.  This is a common-sense approach that is good for our citizens, our businesses and our planet.”

The Dallas Mayor’s statement came on the heels of 406 Mayors, representing 70 million Americans across the country, as they committed to adopt, honor and uphold the Paris Climate Agreement goals.  These Mayors all made a commitment to intensify efforts to push for new action to meet the 1.5 degree Celsius (2.7 degrees Fahrenheit) reduction target, and work together to create a 21st century clean energy economy.

Other Texas Mayors that signed onto the 2017 Climate Mayors agreement included Mayor Steve Adler of Austin, Mayor Ron Nirenberg of San Antonio, Mayor Sylvester Turner of Houston, Mayor John Thormaides of San Marcos, and Mayor Scott Saunders of Smithville.


Texas Cities at Work

Today, San Antonio is in the midst of working on their first climate plan.   Austin was ahead of the curve, having started working on a climate plan in 2014, long before the Paris Agreement, setting a goal of achieving net-zero community wide emissions by 2050.


Dallas Needs to Develop a Stand Alone Climate Plan with a Net Zero Goal

Dallas is in the midst of finishing its third global warming emissions inventory.  The first inventory the city conducted was an assessment for the years 1990 through 2005.  Dallas’ second inventory, which was taken from 2006 to 2010, illustrated a 7% reduction in community-wide greenhouse gas emissions from 1990 levels, meeting the Mayors Climate Protection Agreement signed in 2006.

When Dallas completes its latest and third inventory, it will determine if the city met its goal of a 39% reduction by 2017.   From there a new “stand alone climate plan” with a “net zero” goal should be adopted by the Mayor and City Council; and Dallas should take the necessary steps to meet that goal.


Dallas Can Take Credit for Recent Initiatives in a Climate Plan

Dallas can take credit for its latest inventory along with projects recently put forward such as its Resiliency plan, its adoption of new building codes, green procurement and energy efficient programs and its commitment to purchase electric vehicles when the City decides to take on designing its “stand alone climate plan.”  Dallas has also purchased 100% renewable energy credits, but purchasing actual renewable energy would be even better.

Now is the time, as the City finishes its most recent emissions inventory, to put these recent measures and others into a plan that will help Dallas achieve net zero emissions by 2050 or some other date certain.


Advancing Dallas As a Leader – Leaving a Legacy for the Future

Without a stated net zero goal set with a projected date for achieving that goal and supported with a detailed action plan, Dallas cannot be certain it is doing all it can to achieve to combat climate change.  

Mayor Rawlings did the right thing by signing onto the Mayors Climate agreement. As he enters his last year in office, we have the opportunity to make his goal to advance Dallas as a leader in mitigating the effects of climate change a reality and an important part of his legacy.  Now is the time for Dallas to take the next step with a “net zero” plan to show it is doing all it can to secure a cleaner, brighter future for its citizens and generations to come.


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As if the relentless heat wasn’t enough this summer, Austin is experiencing hazy skies due to an African dust cloud originating in the Saharan desert. The dust was most noticeable on Sunday, July 1. The technical term for this dust is “fine particulate matter,” particles that are so small they can travel from our lungs into our blood stream, causing health problems. An individual particle is 1/20th the width of a human hair. 

The Clean Air Act establishes standards for fine particulate matter (also known as “PM2.5” because it is 2.5 microns in diameter) in the air we breathe. PM2.5 is measured in micrograms per meter cubed, a measurement of how much material is found in a given volume of air. The Environmental Protection Agency has established limits of PM2.5 at 35 μg/m³ in a 24 hour period and 12 μg/m³ in an annual average. If an air monitor exceeds that level of PM2.5, then the region it monitors risks being designated in “nonattainment” of the federal standard. There are currently no areas in Texas in nonattainment of the PM2.5 standard, though there are several areas in nonattainment of the ozone pollution standard.

Unfortunately, the Austin area got very close to violating the PM2.5 standard on Sunday. The table below lists hourly monitor values at the Zavala air monitor in Austin (you can see a map of all the air monitors in Texas here). As you can see, the 24-hour average of monitor values at Zavala on July 1 was 32.5 μg/m³, very close to the EPA’s standard of 35 μg/m³.

Data available from TCEQ

This does not mean, though, that Austin risks falling out of attainment of the fine particulate matter standard. There are a few reasons for this. First, measuring compliance with the standard is a complex calculation that involves averaging three years of air monitoring data. Second–and more importantly for air quality this week–African dust is considered an “exceptional event” that would be excluded from the data anyway.

An exceptional event is an air pollution event that is excluded from the data because it meets certain criteria. The EPA establishes the criteria for an air pollution event to be considered exceptional. These criteria include that “the event is associated with a measured concentration in excess of normal historical fluctuations, including background.” 40 CFR § 50.14(c)(3)(iv) (emphasis added).

African dust has been reaching Texas since time immemorial, and the impact of these events on air quality in Texas is absolutely part of the normal historical fluctuations of weather and air quality. In fact, the phenomenon was first identified by a noted historical figure, Charles Darwin, during his famous trip aboard the H.M.S. Beagle in 1833.

You might think that the considerable historical record on African dust events would cause EPA to reject their exclusion from the data on the basis that they are, after all, well within “normal historical fluctuations.” You would be wrong. The truth is that Texas has a long history of claiming exceptional events that include African dust storms. Other typical exceptional events in Texas include agricultural fires in Mexico (as old as agriculture) and ozone pollution blowing in from other countries (also Mexico, also old).

Why does this matter? Most importantly, air pollution is linked to public health. Children, the elderly, and people with respiratory ailments such as asthma and COPD are particularly vulnerable to air pollution. We have to keep our air clean to keep ourselves healthy. But nonattainment designations have consequences for a region that can last for decades and cost billions of dollars. Houston and Dallas, for example, have been trying to get into attainment of the ozone standard for decade. It’s why we have emissions tests for our cars, and why we can’t build a new factory without reducing pollution from an existing one. The consequences are so great precisely because the impact on human health is so serious. Asthma is the number one cause of school absences. Globally 7 million people die each year from air pollution.

So the purpose of a nonattainment designation is to make our air healthier and protect ourselves and our children. Unfortunately, in Texas, the focus is on avoiding nonattainment designations and their consequences to big business. Several times in the last few years, Texas has used the exceptional events rule to keep areas artificially in attainment of air pollution standards. In 2013, the Texas Commission on Environmental Quality plainly stated that it was excluding enough exceptional events from Houston’s data to keep the area from being desingated under the fine particulate matter standard. Several air quality advocates (including myself) objected to this move. We even pointed to Charles Darwin’s observations as evidence that Texas could not exclude African dust events from its data.

Our objections were ignored by Texas and EPA. The result today is that thousands of people are breathing air that does not meet federal pollution standards. Their health will suffer as a result. Some people will even die. There are quantifiable consequences to these decisions, and they are measured in human lives.

Since the 2013 move to avoid designating Houston as not meeting the PM2.5 standard, several other exception event exclusions have kept areas of Texas artificially in attainment of pollution standards. El Paso doesn’t meet the ozone standard, but exceptional events blamed on Mexico in 2015 have helped the area to avoid a nonattainment designation. More recently, the failure to designate San Antonio as not meeting the ozone pollution standard was blamed on ozone transport from other regions.

In some cases, Texas is using the law correctly to exclude exceptional events. (Houston’s lack of a PM2.5 designation is not one of these cases. We still maintain that it was done improperly and in violation of the exceptional events rule and the spirit of the Clean Air Act.) But even if the state is legally correct in its maneuvers, it’s doing so at the cost of human health. When the Texas Commission on Environmental Quality relies on tricks of data manipulation to avoid federal scrutiny, it is prioritizing business interests over people. A nonattainment designation has consequences for business and industry: old plants have to clean up, new plants have to invest in clean tech. These consequences do reach into the billions of dollars. The total cost of compliance with the Clean Air Act in 2020 is estimated to be $65 billion. But the health benefits of cleaner air in 2020 is estimated at $2 trillion. That’s a return on investment of more than 30 to 1.

Notably, more and more of our air pollution is coming from vehicles. When you register your vehicle, you pay a fee that is used in part to reduce vehicle pollution. When you get your car inspected and make any improvements needed to meet emissions standards, you are investing in clean air. Texas makes sure that you pay your fair share of the cost of reducing air pollution, and you should be happy to do so. After all, it is an investment in your health and your children’s future.

So why does Texas keeping fighting against Clean Air Act regulation? It’s a question of priorities. Much of the cost of compliance is born by industry, especially the oil and gas industry. That’s a powerful lobby in Texas, far more powerful than children who can’t go to school because of chronic asthma attacks. Texas is willing to skirt some regulations in order to save money for industry. It isn’t willing to invest in environmental improvements that pay huge dividends to its people in the long term.

Industry profits today, or public health tomorrow. Texas has made its choice. What’s yours?

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