To: Transportation and Environmental manager; Alamo Area Council of Governments.

       Shelly Whitworth

Suggestions on Reducing Ozone Levels in San Antonio.


Because San Antonio has not met the ozone standard between 1997 and 1999, there needs to be policy’s in place that act to reduce the current levels.  There have been five major policies circulating through the regional governmental offices and I will assess each one as to its cost effectiveness and then make my suggestions as to which policy, or variation of the policy, should be adopted.

            The proposed inspection and maintenance program will indeed find cars that pollute more than they are allowed, but at great overall cost.  With an estimated 400,000 cars running in San Antonio, and an additional $14 to $25 per inspection, the marginal cost would be between 5.6 and 10 million dollars annually.  This is not a huge sum to pay if it will clean up our air, but is it the most efficient use of society’s best interests? 

Data from nearby Harris County suggest that the failure rate had dropped to about 5% since they began testing a few years ago.  Using this figure as a comparable failure rate in San Antonio, the price to find each over polluting car will jump 20 fold, between $280 and $500.  To help lower this cost, it would be advantageous to find an age, lets say 10 years old, and only test cars which are older than that.  With the average age of cars sitting around this point, this slight variation would cut down by approximately half, the numbers of cars that have to take the emissions test, and therefore the total cost.  This will not let many cars through the cracks, because it is mainly cars over 10 years old that are the heavy polluters anyway. 

The main Argument that should be raised is what to do once an over-polluter is found.  To have any effect at all, that car has to be repaired or removed from the road.  In the proposed program this is not the case.  There are waivers to the poor car owners (which might be high in number in a city similar to San Antonio) and to any car whose repairs are more than $450.  By giving waivers and allowing these cars to remain in the fleet, between $280 and $500 was wasted.

The second proposal asks gas stations to voluntarily install stage II vapor-recovery nozzles on their pumps.  This will not work at all unless you encourage people to do it the way the mob does.  Vapor-recovery is a very effective way to reduce hydrocarbon emissions, but asking someone to voluntarily pay for something that at best doesn’t make them any money, is just dumb.

The third proposal is a light rail system to theoretically decrease the automobile traffic, but San Antonio is too spread out for this option to be efficient.  I love public transportation when it works as well as it does in several places in Europe, but down yonder in the back 40 sure ain’t Europe.  In other words, our transport would never be as timely as the German’s, as well built as the Swiss’, or as well traveled as anywhere with a public transport system.  San Antonio is just too spread out.  Also at the cost of more than a billion dollars, and at most a 5% decrease in auto travel, this is an expensive option.

The fourth proposal of banning certain activities on high ozone days is great in theory.  It would be almost effortless to implement, but impossible to enforce.  The pollution coming from these sources is small, but any reduction in ozone is a good thing, Right?  Well maybe not when the fella who you ticked-off by telling him that he couldn’t barbeque today has to get in his car and drive out to eat one of Casey’s mesquite grilled sirloins, therefore polluting by grilling and by driving.  Or take the painter who will be really upset when his best painting days in the clear, hot dry Texas summer days are plucked away from him one by one just because great painting weather just happens to be prime days for ozone formation.  And for the leaf blowers and lawn mowers, the rich ass 09ers and the golf course owners will weasel their way out of these regulations just as they did when there was a water crunch.  For everyone else, your neighbors will just complain even more since you took out your xeriscape front lawn (because it was “unsightly”) and now cannot even keep your St. Augustine in line.   Also looking into the future, as San Antonio grows, and has more Ozone Health Days, we cannot ban activities such as construction work, otherwise out streets would never ever EVER get fixed.

The fifth proposal is to require all sources of VOC’s and NOx to meet the same technology based performance standards.  This spells inefficiency considering technology-based performance standards are a code name for prescriptive standards, and economists will agree that most prescriptive standards have more than their share of drawbacks.  The new sources are under new regulations for a reason.  It would be relatively easy for them to change the way they do things in order to be less polluting.  An existing source may have to go through several expensive facelifts and rearrangements to meet the new standard.  The goal in efficiency is to have the marginal treatment costs the same for the old and the new firms.  By requiring the old firms be competitive with the pollution controls of the new firms, there are going to be massive inefficiencies, which translate into big bucks.

The word of the day is PERMITS and FEES.  Although all of the proposed actions should reduce emissions and ozone levels, they are not all efficient.  Because money matters, there are a few twists to add in order to improve efficiency.  For the I/M program to work properly, the over-polluting car has to be repaired or removed from the road.  To encourage the people with cleaner cars to keep them clean and running well, there could be a grade system that places cars on a scale according to their emissions.  This grade then could be used at the pump to vary the price that vehicle has to pay.  This would be a monetary incentive for people to keep their cars in good health.  Another less expensive method which would have similar effects with less fancy gas pump gizmos would be to find the emissions per mile and multiply this by the mileage from the last inspection to determine how much pollution (grams) that car produced.  When the pollution amount was found, there would be a fee chart in place to determine how much that car had to pay for that certain amount of pollution.  The proceeds from this fee could go to research on how to get further emission reduction in all areas.

The second proposal would have to require all gas pumps to be equipped with vapor-recovery nozzles if the city wants any at all.  The cost of this raise the price of the gas, but the higher gas prices would just cause people to drive less.  It is a win/win situation.  On the subject of gas prices, there could be a county or regional tax on the gasoline.  This would cause people to drive less and amass a sum of money to use to study the economics of air pollution or bribe the EPA to get us out of non-attainment.  Even more relevant would be to have a variable scale.  This could be used to put a higher tax on gas prices during times when ozone is high and a lower tax when it is low.  This would discourage people from driving (or at least refueling) on Ozone Health Alert Days.  Drawing from European customs again, maybe we should charge what gas is really worth and put it at about $4 per gallon.  This would surely decrease the mileage people are willing to drive.

The only rail system that might work is a longer-range system that would connect San Antonio with Austin, Houston And Dallas, but this doesn’t help much with local emissions.  The rail system might decrease local pollution to a degree, but it is the most costly option.  Also the banning of certain activities on Ozone Health Alert Days would decrease the levels of pollution to some extent, but if cannot be reasonably enforced, people will not listen.  A law that is not enforced or obeyed is worse than no law at all.  This would also be externally costly because it cuts directly into several forms of business that are vital for the normal functioning of this city.

One of the best options for San Antonio would be a statewide program of pollution credit trading.  Because a large percentage of San Antonio’s pollution problem comes from outside the city jurisdiction, if there were a way to get our neighbors to clean up their acts, we would reap some of the benefits.  The marketable permits work by actually putting a competitive price on any work a city does to decrease emissions.  When there is an incentive to “clean up”, it will happen.  This could however backfire, if several cities decide it is cheaper to buy permits than to clean up their pollution, the excess pollution localized at one source could potentially float over our skies.  One sure fire way to reduce air pollution in San Antonio is to change the fuel we burn in the power plant from coal to something cleaner burning.  CPS has already experimented with renewable sources such as the wind generation project that brings almost pollution free energy from West Texas and to San Antonio to power our city without an once of pollution entering our atmosphere. “Renewable is the wave of the future.”      Bryan Hummel.