Design in a Time of Uncertainty
By Rives Taylor, Principal, Global Resilience Research Lead
The last issue of HARC Newsletter reported that Harris County and federal officials had approved funding for further work on a new computer model developed by the Houston Advanced Research Center to simulate and investigate air pollution from industrial facilities.
That effort had not even started before two industry groups attacked HARC’s model in blog articles on their websites and an industry-funded organization published an op-ed column in the Austin American-Statesman that also strongly criticized it.
Eduardo (Jay) Olaguer, HARC’s director of air quality research, quickly issued detailed rebuttals of each critique, including his own op-ed column in the American-Statesman. In it, he said the HARC model is a first-of-its-kind effort to simulate air quality conditions in a close-up, neighborhood-scale fashion, which models used by state regulators can’t do.
The context for this spirited public exchange was the continuing controversy over the environmental impacts in North Texas of expanded drilling for natural gas in the Barnett Shale, an underground formation.
Olaguer authored a technical paper on the HARC model, which was selected for publication in the prestigious Journal of the Air & Waste Management Association and posted on its website on July 18.
In the article, “The potential near-source ozone impacts of upstream oil and gas industry emissions,” Olaguer described the model’s simulation of the formation of ozone — a respiratory hazard created in reactions of other pollutants – near a hypothetical natural gas processing facility.
The model indicated emissions of air pollutants from such a facility would yield what Olaguer described as “significant” increases in ozone. Like Houston, the Dallas-Fort Worth region is a “non-attainment area”for ozone, meaning it does not comply with the federal health standard for that pollutant and must further reduce ozone-forming emissions.
“Major metropolitan areas in or near shale formations will be hard pressed to demonstrate future attainment of the federal ozone standard, unless significant controls are placed on emissions from increased oil and gas exploration and production,” Olaguer wrote in the journal article.
Dallas City Council has been considering a possible ordinance to regulate gas drilling within the city. On Sept. 4, the Dallas Morning News reported that a longtime air-quality activist in the region, director Jim Schermbeck of the Downwinders at Risk group, had sent Olaguer's study to local reporters.
In an accompanying note, Schermbeck asserted that state and federal regulatory agencies were “not doing enough,” so more local action was needed. Dallas officials, he wrote, have “a chance to react positively to this new evidence [in Olaguer’s study] by adopting the nation’s first policy aimed at mitigating the tons of new pollution caused by gas mining. That would be a very large step forward in advancing regional clean air goals.”
The next day, Sept. 5, an article assailing the study was posted on the blog of Energy in Depth, a project launched in 2009 by the Independent Petroleum Association of America, which said it would “combat new environmental regulations, especially with regard to hydraulic fracturing,” an increasingly common drilling technique in North Texas and elsewhere. Another blog article criticizing the study was posted by the Barnett Shale Energy Education Council, an industry coalition, on Sept. 18. And on Nov. 4, Kathleen Hartnett White of the Texas Public Policy Foundation, an influential conservative think tank in Austin that has reported receiving major funding from oil and gas companies and other corporations, had a column criticizing Olaguer’s study in the Austin newspaper.
Besides countering numerous technical arguments in those critiques, Olaguer responded to non-technical comments about his study.
The second paragraph of Energy in Depth’s article asserted, for instance, that “the ‘ozone/smog issue’ is a central plank in the anti-shale crowd’s agenda,” which prompted Olaguer to note that “HARC was founded by George Mitchell, who pioneered the horizontal drilling and hydrofracturing techniques in the Barnett Shale, so HARC does not have an anti-drilling agenda.”
The Barnett Shale Energy Education Council article, based on an“initial evaluation” of Olaguer’s study by the Texas Pipeline Association, said it was “unknown if the [HARC] model has been peer-reviewed.” Olaguer responded:“The model has in fact been peer-reviewed in three publications.” (The Journal of the Air & Waste Management Association, which published his study, is described by that organization as “the oldest continuously published, peer-reviewed, technical environmental journal in the world”)
A common refrain in the three critical articles was that pollution-monitoring data gathered by the Texas Commission on Environmental Quality (TCEQ) provide a better way to assess air quality than a computer model’s simulations and that those data around the DFW region refute Olaguer's projections using the HARC model.
Olaguer – a scientist who has managed more than $8 million worth of air-quality field studies, many under contract to the TCEQ – has a different view, however. He believes that “the monitoring network in the Barnett Shale is too sparse and does not have the most up-to-date instruments to be able to rule out significant air-quality impacts due to oil and gas exploration and production activities.”
The HARC model was designed to address issues that such a “sparse network” of monitors cannot settle, including the effects of "large combustion sources at oil and gas sites on ozone and toxic formaldehyde very near the sources” and those impacts’ significance in comparison to "the kinds of ozone reductions that typical control strategies achieve.”
His study’s modeling of a hypothetical situation is “a legitimate way to initially probe issues that cannot be addressed by the current observation network,” Olaguer said, because not enough is known yet about key subjects, including combustion emissions at drilling sites, for the HARC model to assess past pollution readings.
“The HARC model was designed to take advantage of the latest in remote-sensing and real-time monitoring technology to extract detailed information about emissions from oil and gas sites,” he added, but until there is “the political will to live by the results,” it will be hard to find funding to collect pollution measurements for the model.