State Perspectives on Regulating Background Ozone

On June 21, the Environment Subcommittee of the House Science, Space, and Technology Committee held a hearing on State Perspectives on Regulating Background Ozone. Among those called to testify was Diane Rath, executive director of the Alamo Area Council of Governments (AACOG) in San Antonio, Texas. She provided background on the great progress the San Antonio-New Braunfels Metropolitan Statistical Area (MSA) has made over the years in reducing ozone, and explained some of the complicated factors used to calculate the region’s ozone levels.

For AACOG and other regions facing variables outside of their control, federal ozone standards should be flexible enough to account for background ozone in trying to maintain healthy air quality for their citizens.

Regional Success in Reducing Ozone Levels

“The San Antonio-New Braunfels MSA has experienced significant improvement in its ozone levels in the last several years, with nearly a 20 percent decline in design value from 91 parts per billion (ppb) in 2004 to 73 ppb in 2016,” Ms. Rath noted in her testimony. “These improvements occurred despite a population increase of over 568,000 across the eight-county MSA during that period.”

When discussing what led to this drastic reduction in ozone levels, Ms. Rath stated that “the region’s success in improving ozone levels is due in large part to local voluntary public and private partnerships.” Some of the efforts noted in her written testimony included:

  • Bexar County and Cities of San Antonio, Leon Valley, and Seguin Anti-Idling Ordinances;
  • Participating in the Texas Emission Reduction Program (TERP) to facilitate turnover of older and dirtier diesel engines and engaging in community outreach to spread awareness of TERP among local industry and business leaders;
  • VIA Metropolitan Transit (VIA) began converting its diesel bus fleet to compressed natural gas (CNG) in April 2017 (VIA’s new CNG fueling facility is the largest in North America); and
  • Investments in the latest technology by both the energy industry in the Eagle Ford shale and the cement industry to reduce emissions.
Outside Influences on AACOG’s Ozone Levels

Improving the region’s ozone levels were complicated by multiple variables outside of AACOG’s control. According to Ms. Rath, tropical cyclones landfalling in the southeastern U.S. can cause spikes in local ozone levels, citing the example of Hurricane Irma as an instance where landfall in Florida triggered a high ozone event in San Antonio.

She also stated that “79.5 percent of San Antonio’s ozone is caused by emissions and transport from outside the San Antonio-New Braunfels MSA, that is, outside of local control.” The pie chart below used du

ring Ms. Rath’s opening testimony breaks down the contribution to San Antonio area ozone by geographic region.

background ozone

Questions from Congress

In response to questions from the Committee, Ms. Rath noted that San Antonio has taken aggressive actions to remain in attainment with the 2008 NAAQS. CPS Energy (a municipally-owned electric utility company) implemented cost-saving programs that resulted in savings equal to shutting down a medium-sized coal plant. CPS Energy produced 1500 megawatts of renewable energy capacity two years ahead of schedule, and are shutting down the Deely plant the region’s largest and oldest coal-powered plant.

The AACOG region faces a low estimate of over $117 million annually, and the high estimate is over $1 billion annually in economic consequences of a nonattainment designation. For every year we are in nonattainment, there is the potential for our eight-county MSA to incur over $1 billion in costs.

In addition, the impact of international ozone be taken into consideration when applying NAAQS to various regions in the U.S. How can you hold a community or region responsible for what is totally and completely outside of its control? Ms. Rath noted. If international transport was considered in measuring ozone levels, the region would be well under the limit.

Ms. Rath’s testimony and answers acknowledged the importance of the Environmental Protection Agency’s (EPA) National Ambient Air Quality Standards (NAAQS) for ozone but emphasized the adverse impacts of overly broad standards on regions, especially the San Antonio area. She urged Congress to “take advantage of the flexibility in the Clean Air Act to evaluate and actively consider during NAAQS designation the impact of background ozone levels and all foreign transport on a region.” This would be a step closer to ensuring that regional projects and economies don’t shoulder the full burden of nonattainment from factors outside their control.

Texas Regional Council Preparation and Recovery Efforts for Hurricane Harvey

If you watched any of the coverage for Hurricane Harvey at the end of August, you have an idea of the devastation it caused. Hundreds of images filled our television sets and computer screens, from totally submerged apartment buildings to water-filled streets that looked more like canals, not to mention the hundreds of people displaced to shelters. Some areas of Texas received more than 50 inches of rain from the storm. The Houston Chronicle reported that the hurricane broke the record for heaviest rainfall ever logged in the United States during a tropical storm, totaling 64.58 inches in Nederland, Texas. Local, state, and federal officials all agree on one thing: it will take Southeast Texas months, if not years, to fully recover.

Local officials and regional councils had pivotal roles to play in the preparation and recovery efforts for Hurricane Harvey. The following sections highlight just some of the actions our members carried out, whether they were directly affected, neighbored the affected, or just took the initiative to help other regions and the state bounce back from the record-breaking hurricane.

Texas Association of Regional Councils, Statewide

 The impact of Hurricane Harvey was felt by more than 60 counties within nine of the state’s 24 regional councils. The Federal Emergency Management Agency estimates that more than 792,000 households have applied for federal assistance in Texas alone because of this event. As the state and the nation were looking for ways to assist in the storm’s aftermath, the Texas Association of Regional Councils (TARC) began its efforts by offering a forum to the impacted regions in which they could discuss possible opportunities for collaboration with state and federal agencies.

In its role as a liaison between its members and agencies taking a lead in disaster response and recovery efforts, TARC initiated calls with the impacted regions to ensure all were speaking with one voice and benefiting from the same information. TARC is continuing to follow up with its members as state and federal programs are activated. Because of the partnerships with state agencies created by TARC and its members, the association was also able to quickly build a framework allowing their impacted member regions to provide technical assistance and coordination to their communities and lead recovery agencies. Disasters are local, but with an event of this magnitude, it was and remains important for the regional councils in Texas to continue serving as a steady, reliable, and transparent partner with local, state, and federal government entities.

Houston-Galveston Area Council, Houston, Texas

The Houston-Galveston Area Council (H-GAC) serves 13 counties that are continuing to grow and become more diverse over time. Houston was the largest city to be impacted by the hurricane, and the effects were severe. The Texas Tribune reported that parts of the city received more than four feet of rain. Dozens of Houstonians lost their lives, and thousands of homes and vehicles were damaged or destroyed. According to the Texas Tribune, Houston officials estimate that the first responders’ overtime, debris collection, and other expenses associated with response and recovery will cost more than $250 million.

One of H-GAC’s initial actions was to create a Hurricane Harvey Recovery Resources page on their website, to provide easy access to information for residents, organizations, and local governments that sought updates, assistance, or next steps for recovery. The webpage offers updated information on disaster recovery centers, recovery efforts, and post-disaster reports, as well as recorded webinars on disaster preparedness and economic recovery. H-GAC highlighted pertinent programs they manage that provide services for recovery efforts and shared disaster-related material for each, including HGACBuy Disaster Debris Clearance and Removal Services, disaster debris resources, workforce solutions, and the Houston-Galveston Area Agency on Aging.

After Hurricane Harvey, the H-GAC Board of Directors approved the acceptance of $10,531,000 in workforce disaster assistance funds from the Texas Workforce Commission. H-GAC has planned to use this funding in a variety of ways, including providing temporary jobs for clean-up and repair of government facilities, financial assistance for dislocated workers, and training for individuals who need it to return to work. H-GAC estimated that the funds would create a minimum of 400 temporary jobs and serve at least 1,000 dislocated workers – 85 percent of this budget is earmarked for wages, benefits, and assistance to temporary workers.

Lastly, the H-GAC GIS team has acquired over 10,000 square miles of post-Hurricane Harvey aerial imagery of the major flooding in their region. The resolution of the imagery is one foot and the images are available in natural color and color-infrared. This GIS imagery will help those involved in the recovery efforts understand the impact of the storms and where the flooding was most prevalent. Those that are interested in participating in the cost-sharing effort of this project should reach out to the Data Services GIS team at

Brazos Valley Council of Governments, Bryan-College Station, Texas

The Brazos Valley Council of Governments (BVCOG) serves seven counties in the eastern part of the state. According to their local newspaper The Eagle, some areas of the region expected anywhere from 3-25 inches of rainfall and wind gusts up to 30-40 miles per hour. This area of Texas is mostly rural, so severe flooding was a major concern for local officials. When the hurricane finally came onshore, the small city of Bedis received 30 inches of rainfall, while other cities in the region garnered 10-20 inches.

BVCOG supported the “whole community approach” that local governments and stakeholders in the region took to help the areas most impacted by the hurricane. Despite some of the areas in the region suffering from flooding themselves, they still supported their neighbors like Houston and Beaumont in the following ways:

  • The City of Bryan and Texas A&M University provided personnel and ambulances to the Emergency Medical Task Force-7 (EMTF-7) to those on the coastline and in the mega-shelter George R. Brown Convention Center in Houston for patient transportation and medical treatment;
  • The fire departments in the cities of College Station and Bryan deployed engines with personnel and swift water rescue assets to the heavily flooded areas;
  • The Navasota Fire Department responded as a Texas Intrastate Fire Mutual Aid System (TIFMAS) water strike team and sent a boat with personnel to impacted areas along the coast (despite being one of the hardest hit counties in the BVCOG region);
  • Temporary evacuation centers were created for displaced families;
  • A large animal shelter was opened at the Brazos County Export Center;
  • Ambulance services from CHI St. Joseph EMS, PHI Air Medical, and Allegiance transported hospital patients and nursing home residents out of harm’s way to designated safe areas; and
  • Regional hospitals, such as CHI St. Joseph Regional Hospital, took in patients from hurricane impacted areas.

The region also served as a major state staging area, providing skilled services, shelter, and medical assistance for those most impacted. Texas A&M University’s RELLIS Campus was a staging area for the Texas A&M Forest Service (TFS) TIFMAS assets, the Texas Department of Transportation (TXDOT), Texas Task Force-1, and the Texas Military Department assets, relief supplies, and equipment. The cities of Brenham and Bryan also staged Texas Military personnel. The BVCOG region’s local governments and stakeholders also provided these personnel groups shelter and meeting space to make sure they were well prepared to enter the hardest-hit areas of the storm.

The local government officials that made these major decisions sit on BVCOG’s Board of Directors. Looking beyond their own communities, they realized that they needed to help the more flooded counties in their region and the areas with the heaviest rainfall in the state of Texas. The BVCOG region’s collective efforts provided support and relief to its citizens and served a greater role as a state team player helping neighboring regions in need.

Deep East Texas Council of Governments, Jasper, Texas

Deep East Texas Council of Governments (DETCOG) covers 9,790 square miles in the eastern part of the state. The region, which sits right above Houston, Texas, saw six of its 12 counties included in the Presidential Disaster Declaration. A map provided by Longview News-Journal showed that the region was going to avoid the heavy rainfall expected in Houston and on the Gulf of Mexico. However, the rural region still expected anywhere from 3-15 inches of rain with the heaviest concentration of rain in the south.

During the storm, DETCOG was an important source of information for those that were impacted by Hurricane Harvey. DETCOG is one of 25 Area Information Centers for 211 Texas, a program designed to connect Texans that call 2-1-1 to state and local health and human services programs 24/7. Before Hurricane Harvey hit, DETCOG’s office received an average of 104 calls a day. In the 15 days following the hurricane, the DETCOG office received 3,172 calls – an average of 212 calls each day. Numbers from their online inquiries were not immediately available, but DETCOG expected that those numbers were higher than normal as well. Their call center even served as a shelter for those that needed it. DETCOG offered vital disaster-related information and resources to thousands in their region, assisting with initial recovery efforts.

DETCOG has also been offered an opportunity to help oversee some of the immediate assistance in some of its more impacted counties in the region. The Alabama-Coushatta Tribe, located in DETCOG’s region, donated $500,000 to various organizations in the 11 counties surrounding them for Hurricane Harvey relief. They asked DETCOG to oversee this assistance in Jasper and Newton counties, each receiving $25,000 from the Alabama-Coushatta Tribe. With this generous donation, DETCOG has been able to help provide emergency assistance with housing, transportation, groceries, cleaning supplies, and building materials to those most affected by the hurricane in Jasper and Newton.

Alamo Area Council of Governments, San Antonio, Texas

The Alamo Area Council of Governments (AACOG) serves a 13-county region. Early hurricane models showed that Hurricane Harvey was going to head towards San Antonio after it left the Gulf of Mexico, but it doubled back to the coast before making landfall. The city, according to a San Antonio Express News article, only received a total of 1.94 inches from the hurricane.

In the face of earlier predictions, AACOG took precautionary measures to ensure the safety of citizens in the region. In a press release disseminated the same day that Hurricane Harvey hit Texas, AACOG said that they were carrying out the following preparations to help their membership counties in South Central Texas:

  • The AACOG team took the lead in activating emergency operations centers and preparedness measures in their region;
  • Their Homeland Security Program served “as a liaison between smaller jurisdictions in the region and the City of San Antonio and Bexar County;”
  • The Alamo Regional Transit system, a low-cost public transportation bus service run by AACOG in 12 rural counties, was prepared to assist with regional evacuations if necessary;
  • Employees from the Bexar Area Agency on Aging and Alamo Area Agency on Aging were ready to conduct case management work at designated shelters, much like they did during Hurricane Ike in 2008;
  • Through AACOG’s Long-term Care Ombudsman Program, AACOG staff members planned on conducting on-site visits to dozens of nursing homes and assisted living centers in the region. If the residents were being moved to a safer location, AACOG staffers would make sure that they would still receive the proper care and medication they need.

AACOG took a multi-faceted approach to preparation efforts that readied the region for the worst-case scenario. They were a leader and a liaison for various cities and counties in their region, and they prioritized putting procedures in place for the most vulnerable populations.

After the hurricane made landfall in other areas, San Antonio became a huge hub for hurricane evacuees. The San Antonio Food Bank, which has a regional reach of 16 counties in South Central Texas, provided food to evacuees. The AT&T Center in AACOG’s home city became a command center for more than 300 first responders from around the state. AACOG and the local officials that make up their Board of Directors were quick to turn their preparation efforts at home to disaster relief and response for their neighbors.

NARC would like to thank H-GAC, BVCOG, DETCOG, and AACOG for the information they provided and for their efforts during Hurricane Harvey. Stay tuned for our next blog, which will cover regional efforts in response to Hurricane Irma.