Tuesday, April 17, 2018

My Comment to the EPA Response to the Designation Recommendation From Texas for the San Antonio Area for the 2015 Ozone National Ambient Air Quality Standards


To whom it may concern:

My name is Mark Langford and I have been studying meteorology and ground level ozone for over twenty years. Although I hold no degree in either subject, I have spent many hours and days researching both sciences and consider myself very knowledgeable on how ground level ozone forms and the many factors that impact high and low ozone readings throughout a region. I am a past member of the Alamo Area Council of Governments (AACOG) Air Advisory Committee and the owner and editor of the website, https://ozoneinformation.com/. I have also written many posts on my ozone blog, https://ozoneinformation.com/my-ozone-blog  . After reading my response, feel free to check out both sites for additional information on this important subject. Lastly, and probably most important, I am a lifelong asthmatic who has been on anti-asthma medications since I was two years old…I just turned sixty at the end of 2017.

As you consider whether San Antonio and surrounding cities should be labeled as “non-attainment” for our three year ozone average, please consider the following points:

       1.   Local (AACOG) and EPA modeling show that when San Antonio has a high ozone event, our local contributions are only between 20-30% of the recorded ozone. This means that unless we were to almost completely shut down our entire city during a high ozone event, there is no way we can keep our ozone from going over 70ppb as an eight hour average. This also means that 70-80% of the ozone being recorded in our area is from other sources. These come from transported anthropogenic sources from Mexico, Asia, nearby states and cities. They also come from biogenic sources like oak trees, pine trees and invasive plant species like Kudzu.

         2. Our local emissions are trending down. Although high ozone events are fairly random, our local emissions are not. San Antonio and other cities in the USA are lowering their NO2 emissions every year, thanks to vehicles and point sources becoming cleaner due to current regulations. In fact, as of 2018, vehicle emissions in San Antonio will now be second to point sources for the first time in our history of studying ground level ozone. I imagine that San Antonio is not alone.
    
3  Health studies on ozone are “iffy” at best. I have read many scientific papers on the impacts of ozone on humans and most do not include very important factors such as daily allergy reports, how long the people were actually outside during a high ozone event and whether they are smokers, etc. I have never been negatively impacted by any of the San Antonio high ozone events. My challenge in breathing comes during high pollen events, smoke from agricultural burning in Mexico and Central America and Saharan dust.Cities in the south are unfairly labeled “non-attainment “, due to our geographic location. 

4.  Since most high ozone events occur during hot days with clear skies, cities in the south should be allowed more high ozone event days than those in the north. There many more days of 80 degrees plus temperatures in southern states than northern states. Our odds of having a high ozone event are greater, even if we have the same emissions as cities to our north.

          5.  There is concern about the accuracy of measurements by all EPA-approved ozone analyzers, for scientific studies by the EPA and others since 1999 have clearly established that conventional ozone analyzers that employ ultraviolet wavelengths to measure ozone are biased by interference from mercury vapor and sulfur dioxide, both of which are emitted by coal burning power plants. See, for example, "Laboratory Study to Explore Potential Interferences to Air Quality Monitors" (United States Office of Air Quality, EPA-454/C-00-002, Environmental Protection Planning and Standards, December 1999.)" This is a very important concern. If our monitors are not giving us the proper readings, how can know whether any cities are really exceeding the eight hour ozone standard?

         6.  Part of the reason we are even discussing this issue is because the EPA has lowered the eight hour
      average ozone standard to a point where almost every city and many national parks will be unable to achieve such a low reading, despite continued lowering of emissions. My research has found that on many days of the year, several national parks in the west and east go over the eight hour ozone average, even though very few people live in these areas. Their problem as well as ours is due to transport. Here is a link to ozone exceedances for our national parks.   https://www.nature.nps.gov/air/monitoring/exceed.cfm  Will the EPA be considering the parks listed on this page as “non-attainment” areas?

        7.  High ozone events are weather driven. In San Antonio, high ozone events (which are rare) only occur under unusual weather conditions. For us, high ozone events almost always occur when late or early season cool fronts (continental air) push into south central Texas, switching our winds and circulation into the NE or east. We never have high ozone events in the middle of summer, despite temperatures reaching or exceeding one hundred degrees. Were it not for low pressure systems in the Gulf or cool fronts switching our winds into the NE and east, we would never have high ozone events in San Antonio. When the same early and late season cool fronts cause clouds and rain to form instead of clearing our skies, we don’t see high ozone. We cannot control the weather, nor can we control high ozone events.

Please consider high ozone events as a weather driven phenomenon that should be treated as we do any impending storm or severe weather.  Continue to issue health alerts on high ozone days just as NOAA would issue a tornado warning, but don’t penalize cities like San Antonio, who’s air quality is normally very good unless impacted by rare weather events.  Unless a city is dramatically increasing their emissions and is clearly causing an increase in high ozone events, they should not be put onto the “non-attainment” list.

Friday, April 27, 2012

Sea Salt and Ozone

Over the next few weeks, I will be posting some interesting ozone studies and information that have received very little press over the past yeas. These will be added to my website, www.ozoneinformation.com.

I am convinced that natural elements are behind a percentage of air quality issues impacting the globe and that even with the strictest emissions reductions, we may still see areas with high ozone.

This article is from 2008:


Sea Salt Worsens Coastal Air Pollution





Friday, January 7, 2011

Thursday, October 28, 2010

Super Dry October

I have not recorded any measurable rainfall in Helotes this month.

This was just posted from our local NOAA office
:

Statement as of 3:47 PM CDT on October 28, 2010


... October 2010 has so far been one of the drier octobers of record...

After the 2nd wettest September at Austin Mabry and the 6th wettest
September at San Antonio... October of 2010 is shaping up to be one
of the drier octobers at Austin... del Rio... and San Antonio.

So far October 2010 through today has been the 3rd driest October at
Austin Bergstrom since October 1942... the 5th driest at Austin Mabry
since 1856... a tie for the 3rd driest October at del Rio since
1906... and a tie for the 8th driest October at San Antonio since 1871.
The forecasts through Sunday the 31st show that no rain is expected
for south central Texas.

The list below shows the driest octobers of record at Austin...
del Rio... and San Antonio.

Austin Mabry has had 0.08 inches of rain from October 1st through
today. This makes October 2010 so far the 5th driest October at
Austin Mabry since 1856. The list below shows the driest octobers
at Austin Mabry.

1. 0.00 October 1893
2. Trace October 1952
3. 0.02 October 1947
4. 0.03 October 1934
5. 0.08 October 1 to 28... 2010

Austin Bergstrom has had 0.06 inches of rain from October 1st through
today. This makes October 2010 so far the 3rd driest October at
Austin Bergstrom since October 1942. The list below shows the driest
octobers at Austin Bergstrom.

1. 0.00 October 1952
2. 0.01 October 1947
3. 0.06 October 1 to 28... 2010
4. 0.21 October 1987
5. 0.33 October 1955

Del Rio has had 0.01 inches of rain from October 1st through today.
This makes October 2010 so far a tie with October of 1915 and
October of 1931 for the 3rd driest October at del Rio since 1906.
The list below shows the driest octobers at del Rio.

1. 0.00 October 1917 and 1979
2. Trace October 1950 and 1952
3. 0.01 October 1915... 1931 and October 1 to 28... 2010
4. 0.04 October 1955
5. 0.06 October 1909... 1970 and 1980

San Antonio has had 0.17 inches of rain from October 1st through
today. This makes October 2010 so far a tie with October of 1943
for the 8th driest October at San Antonio since 1871. The list
below shows the driest octobers at San Antonio.

1. Trace October 1952
2. 0.03 October 1898
3. 0.07 October 1939
4. 0.08 October 1893 and 1950
5. 0.11 October 1979
6. 0.12 October 1901
7. 0.13 October 1938
8. 0.17 October 1943 and October 1 to 28... 2010

Friday, October 1, 2010

Rainfall Totals for September

My 6.54 inches of rain recorded in my backyard seems puny compared with other parts of the area. Here is a statement from NOAA on September rains:

... September 2010 was one of the wetter septembers at
Austin and San Antonio...

September 2010 was one of the wetter septembers at Austin and San Antonio.
Rainfall from a cold front late September 2nd to the early morning hours
of September 3rd was followed by scattered showers the afternoon
of the 6th and rains associated with Hermine the 7th through the
8th. Additional rain came from isolated showers the weekend of
September 11th and 12th to Tuesday the 14th... and more widespread
rain showers from Friday the 17th through Sunday the 19th.
Scattered daytime to early evening showers brought more rain on
Monday the 20th through Saturday the 25th... and isolated early
morning showers came with a cold front the morning of the 26th.
The rest of the month from the 27th to the 30th was dry.

Rainfall for September 2010 was the 2nd wettest September at
Austin Mabry... the 13th wettest at Austin Bergstrom... and the
6th wettest September at San Antonio. September 2010 was not one
of the wetter septembers at del Rio. Rainfall at del Rio was 2.06
inches in September of 2010... equal to the latest 30 year
1971 to 2000 average.

The list below shows the wettest septembers at Austin... del Rio...
and San Antonio.

The wettest septembers at Austin Mabry from 1856 to 2010 are listed below.
The 1971 to 2000 normal at Austin Mabry is 2.91 inches... while the
historical 1856 to 2010 average is 3.51 inches.

1. 20.78 September 1921
2. 13.20 September 2010
3. 12.78 September 1874
4. 12.33 September 1886
5. 10.54 September 1873

The wettest septembers at Austin Bergstrom international Airport from
1943 to 2010 are listed below. The 1971 to 2000 normal at Austin Bergstrom
for September is 2.88 inches... while the historical 1943 to 2010 average
is 3.29 inches.

1. 9.36 September 1986
2. 8.82 September 1957
3. 8.80 September 1958
4. 6.98 September 2009
5. 6.50 September 1967

13. 5.15 September 2010

The wettest septembers at San Antonio International Airport from 1871 to 2010
are listed below. The 1971 to 2000 normal for San Antonio is 3.00 inches...
while the historical 1871 to 2010 average is 3.36 inches.

1. 15.78 September 1946
2. 13.09 September 1973
3. 11.71 September 1874
4. 11.16 September 1967
5. 11.10 September 1957
6. 9.37 September 2010

The wettest septembers at del Rio from 1906 to 2010 are listed below.
At del Rio 2.06 inches of rain fell in September of 2010... equal to the
latest 1971 to 2000 normal. The historical 1906 to 2010 average
rain in September at del Rio is 2.50 inches.

1. 15.79 September 1964
2. 9.95 September 1932
3. 9.87 September 1970
4. 9.74 September 1919
5. 7.07 September 1991

Thursday, September 23, 2010

Tropical this week...more "Fallish" next week!


On this first full day of the Autumnal Equinox, I thought I'd reassure everyone that more fall like temperatures are only a few days away. The persistent tropical air mass and a stubborn jet stream to our north has been keeping us in the "Florida" mode for the past several weeks. On a positive note, we have had a great September as far as rainfall goes. This is important because we will be quickly entering a La Nina winter pattern, which typically is dry. So far, my backyard in Helotes has measured almost 6 inches of rain in September. As the first real cool front nears us on Sunday, look for an increase in rainfall chances, with a few thunderstorms developing along the front. After the front passes, computer models are showing dew points in the 40's and 50's for most of next week. I would not be surprised to see some of our lows drop into the 50's!

Meanwhile, the National Hurricane Center is becoming concerned that Mathew may be about to form in the Caribbean today or tomorrow. This could be trouble for Florida early next week as the cool front pushes the storm in that direction.

Monday, September 20, 2010

September Rain totals from NOAA

So far, in my backyard, we've received 5.52 inches of rain in September. Latest 3 day storm total has been 1.14 inches.

Here is the latest rainfall update from NOAA on 9-19-10:

.. September 2010 has become one of the wetter septembers at
Austin and San Antonio...

the first 19 days of September 2010 has brought one of the wetter
septembers to Austin and San Antonio. Rainfall from a cold front
late September 2nd to the early morning hours of September 3rd
was followed by scattered showers the afternoon of the 6th
and rains associated with Hermine the 7th through the 8th.
Additional rain came from isolated showers the weekend of
September 11th and 12th to Tuesday the 14th... and more widespread
rain showers from Friday the 17th through Sunday the 19th.

Rainfall for the first 19 days of September shows that September 2010
is so far the 4th wettest September at Austin Mabry... the 15th
wettest at Austin Bergstrom... and the 8th wettest at San Antonio.
With 11 more days left in September... the final figures for
September 2010 will change.

The list below shows the wettest septembers from the past compared
to the rain that has come from September 1st to 19th of 2010.

At Austin Mabry so far in September 2010... 12.19 inches of rain
has fallen. The wettest septembers at Austin Mabry from 1856 to
2009 are listed below.

1. 20.78 September 1921
2. 12.78 September 1874
3. 12.33 September 1886
4. 10.54 September 1873
5. 9.70 September 1859

At Austin Bergstrom international Airport so far in September
2010... 4.75 inches of rain has fallen.

The wettest septembers at Austin Bergstrom from 1943 to 2009 are listed
below.

1. 9.36 September 1986
2. 8.82 September 1957
3. 8.80 September 1958
4. 6.98 September 2009
5. 6.50 September 1967

at San Antonio International Airport so far in September 2010... 8.90
inches of rain has fallen.

The wettest septembers at San Antonio from 1885 to 2009 are
listed below.

1. 15.78 September 1946
2. 13.09 September 1973
3. 11.71 September 1874
4. 11.16 September 1967
5. 11.10 September 1957
6. 9.21 September 2003
7. 8.95 September 1882
8. 8.87 September 1896

The scattered showers the past few days have brought brief wind
gusts to the area.

Scattered afternoon showers and thunderstorms moving across south
central Texas today produced brief wind gusts around 30 to 39 mph
in the afternoon.

Peak wind information from a few airports across south central Texas
from the scattered showers and thunderstorms on Sunday
September 19th are listed below.

Pleasanton... ... ... ... ... ... ... ... ... ... .23 mph
New Braunfels Municipal Airport... ... ... .35 mph
Randolph AFB... ... ... ... ... ... ... ... ... ..23 mph
San Antonio Stinson field... ... ... ... ... .26 mph
San Antonio International Airport... ... ..39 mph
Austin Bergstrom international Airport... 33 mph
Austin Camp Mabry... ... ... ... ... ... ... ... 28 mph
del Rio International Airport... ... ... ... 28 mph

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