On Tuesday your San Antonio Chamber of Commerce President and CEO Richard Perez testified at the Texas Commission on Environmental Quality (TCEQ) Public Hearing for the proposed
179B Demonstration State Implementation Plan (SIP) Revision. The purpose of this SIP Revision is to demonstrate that Bexar County would attain the
2015 National Ambient Air Quality Standard (NAAQS) for ozone by the required attainment date if it were not for emissions emanating from outside the United States (Federal Clean Air Act, Section 179B).
The Clean Air Act is the federal law designed to control air pollution on a national level. Under the Act, the Environmental Protection Agency (EPA) designates geographical areas in one of three categories for air pollution:
- “Attainment” (meeting the standards),
- “Nonattainment” (not meeting the standards), or
- “Unclassifiable” (insufficient data to classify).
In July 2018, Bexar County’s air quality was designated “marginal nonattainment,” which is the lowest level of designation by the EPA and requires additional review related to transportation and industrial emissions. Each level of the designation brings about more regulation, and such red tape is burdensome for businesses.
Since Bexar County has been designated a nonattainment community, the TCEQ has conducted a comprehensive emissions inventory of all sources within Bexar County and has developed a State Implementation Plan (SIP). The SIP is the state’s comprehensive plan to clean the air and meet federal air quality standards. TCEQ’s SIP includes a proposed revision that would waive international emissions (anthropogenic contributions) from the photochemical modeling and other technical analyses. If approved by EPA, Bexar County would avoid being bumped up to moderate nonattainment, the next level of designation.
The Chamber believes the San Antonio’s nonattainment designation was unjust considering only 20% of the ozone emissions in Bexar County are from local sources and 36% are from foreign sources. This top-down approach has created unwarranted regulatory intervention that negatively impacts the bottom line of our 2100 member businesses. According to a 2017 study regarding the “Potential Cost of a Nonattainment Designation for the San Antonio Region” conducted by the Alamo Area Council of Governments, the economic loss to the San Antonio-New Braunfels MSA could range from $3.2 billion to $27.5 billion under marginal nonattainment and could increase from $7.1 billion to $36.2 billion if the region is given a moderate nonattainment classification.
The San Antonio Chamber of Commerce is grateful to the TCEQ for acknowledging the work that our local air quality partners have undertaken to help reduce Bexar County’s design value over the years. Bexar County has a proven history as a community of lowering emissions into compliance through voluntary and local measures. Twice before, Bexar County has been in danger of running afoul of National Ambient Air Quality Standards (NAAQS) for ozone when such standards were set at 80 and 75 ppb respectively, and each time, Bexar County has brought ozone levels into compliance in a timely fashion. Despite the region’s population increasing by 1 million, San Antonio’s ozone levels have gone down from 93 ppb in 2003, to 73 ppb in 2016.
We are hopeful that Bexar County will be back in attainment by the end of 2020. Click
here to view the comments your Chamber submitted to TCEQ. Count on your Chamber to keep you updated.
For more information about the 179B SIP revision contact Stephanie Reyes, VP of Public Policy at 210-229-2162 or by email
sreyes@sachamber.org.
