Most EPA Pollution Estimates Are Unreliable, So Why Is Everyone Still Using Them?
By Rachel Leven
Engineer Jim Southerland was hired by the U.S. Environmental Protection Agency (EPA) in 1971 to join the nascent war on air pollution. He came to relish the task, investigating orange clouds from an ammunition plant in Tennessee and taking air samples from strip mines in Wyoming. Among his proudest accomplishments: helping the agency develop a set of numbers called emission factors—values that enable regulators to estimate atmospheric discharges from power plants, oil refineries, chemical plants and other industrial operations.
By the time Southerland left the EPA in 1996, he was "frustrated and ticked off," he said, because the numbers he had helped develop were being misused. The original aim had been to paint a broad-brush picture of pollution. Instead, the numbers—meant to represent average emissions from industrial activities—were incorporated into permits stipulating how much pollution individual facilities could release. This happened despite EPA warnings that about half of these sites would discharge more than the models predicted. "These factors were not intended for permits," said Southerland, now retired and living in Cary, North Carolina.
The number of emission factors used by the EPA since Southerland's time has proliferated and stands at 22,693. The agency itself admits most are unreliable: It rates about 62 percent as "below average" or "poor." Nearly 22 percent aren't rated at all. About 17 percent earned grades of "average" or better, and only one in six has ever been updated. There is a slew of common problems, such as poor accounting for emissions from aging equipment.
The upshot: in some cases, major polluters are using flawed numbers to calculate emissions of substances such as benzene, a carcinogen, and methane, a powerful greenhouse gas. Regulators at times are flying blind. The factors color everything we know about air quality and many of the decisions the EPA and state environmental agencies make, from risk assessment to rulemaking.
In an email, an EPA spokeswoman told the Center for Public Integrity that the agency has been working on the problem for a decade. "EPA believes it is important to develop emissions factors that are of high quality and reliable," she wrote.
Some experts, however, say the agency hasn't done enough. The unreliability of the numbers has been flagged over a period of decades by the EPA's own internal watchdog and other government auditors. "This is what tells you what's being put in the air and what you're breathing," said Eric Schaeffer, former head of civil enforcement at the EPA and now executive director of the Environmental Integrity Project, an advocacy group. "You don't want those numbers to be wrong."
Emission factors are based on company and EPA measurements as well as external studies. They are plugged into equations to estimate total emissions from industrial activities, such as the burning of coal in boilers.
As early as the 1950s, regulators in places like Los Angeles were using emission factors to try to pinpoint the origins of dangerous smog episodes. The numbers allowed them to avoid "time-consuming, expensive testing programs and extensive surveys of individual sources," according to a 1960 paper by the Los Angeles County Air Pollution Control District.
In 1965, the U.S. Public Health Service—which regulated air pollution at the time—released its first comprehensive list of factors, a document the agency would label "AP-42" in a 1968 update. The EPA, created two years later, kept revising the estimates as they became more widely used in emission inventories depicting pollution levels and sources around the country.
The EPA knew early on there were problems with the numbers. In 1989, for example, the Office of Technology Assessment—a now-defunct, nonpartisan science adviser to Congress—reported many U.S. metropolitan areas had not met their goals for controlling smog-forming ozone in part because of inaccurate emission inventories. In 1990 amendments to the Clean Air Act, Congress gave the agency six months to make sure all emissions contributing to ozone formation were assigned up-to-date, accurate factors, and directed the EPA to review the numbers every three years thereafter.
The EPA missed both deadlines. It has failed to do at least some of the three-year reviews. It claims to have created all the necessary ozone-related factors, but questions about their accuracy remain.
For decades, government watchdogs, including the EPA's Office of Inspector General, have pointed out deficiencies in the factors, which drive actions ranging from enforcement cases to the drafting of regulations. "We believe the status of emission factor development … is a significant weakness that impedes achievement of major air program goals," the IG wrote in a 1996 report. The EPA's dependence on industry studies because of funding constraints could result in factors that minimized pollution, it warned. The U.S. General Accounting Office—now the Government Accountability Office—reported in 2001 that polluters rely on the estimates even though "facilities' actual emissions can, and do, vary substantially from the published factors." The EPA's IG came back with a targeted reproach in 2014, questioning the validity of factors used to estimate methane emissions from some pipelines.
Still, there was little movement. Whereas emission factors are recognized as crucial tools in understanding air quality and underpinning inventories, they tend to be forgotten. "That foundation is buried to such an extent that it's not often appreciated," said David Mobley, who worked on emission factors in the 1990s. "The urgency is rarely there."
Test Case in Houston
Accurate pollution data matters. Consider what happened in the ozone-plagued city of Houston, a hub of oil refining and chemical manufacturing.
The city had been using emission inventories to guide its ozone-control strategy. Air monitoring by researchers in 2000 found levels of volatile organic compounds—highly reactive ozone precursors, such as benzene, known as VOCs—were 10 to 100 times higher than what had previously been estimated. The study—conducted by what was then the Texas Natural Resource Conservation Commission, the EPA and more than 40 other public, private and academic institutions—singled out as culprits VOCs such as ethylene, a flammable gas used mainly in the production of plastics.
Houston, it turned out, had focused on controlling the wrong emissions from the wrong sources to lower its ozone levels, said Daniel Cohan, an associate professor of environmental engineering at Rice University. The city changed course, expanding VOC monitoring and developing rules to reduce emissions. Ozone production rates dropped by up to 50 percent in six years, Cohan and his colleagues found in a follow-up study. The study showed that reliance on emission factors alone is a bad idea, Cohan said. "We need scientists to measure these pollutants in the air to find out how much is really being emitted," he said.
The underestimation problem surfaced at individual facilities as well, including Shell's 1,500-acre petrochemical complex in the Houston suburb of Deer Park. A study begun by the City of Houston and the EPA in 2010 showed levels of benzene wafting from one Shell tank were 448 times higher than what the relevant emission factor had predicted. The discrepancy led to an EPA enforcement action; in a consent decree, Shell agreed to pay a $2.6 million fine and spend $115 million to control pollution from flaring—the burning of gas for economic or safety reasons—and other activities. Shell did not respond to requests for comment, but a spokeswoman told the Houston Chronicle in 2013 "the provisions of the settlement are consistent with Shell Deer Park's objectives and ongoing activities to reduce emissions at the site and upgrade our flaring infrastructure."
Despite the findings of these studies and others, the EPA didn't update emission factors for the U.S. refinery and petrochemical sector until 2015, seven years after Houston had petitioned the agency to do so and two years after it was sued by environmental justice groups.
Unreliable Methane Estimates
The low-balling of pollution isn't limited to toxic chemicals. Many emission factors used to estimate releases of methane—a potent greenhouse gas associated with oil and natural-gas development—are "far too low," said Robert Howarth, an ecology and environmental biology professor at Cornell University. Identifying how much methane these operations discharge can help scientists calculate the impact of natural gas—which in 2016 displaced coal as the nation's biggest source of electric power generation—on global warming. This is crucial to preventing "runaway climate change," Howarth said.
Much remains unknown. A 2015 study sponsored by the Environmental Defense Fund found methane releases from oil and gas production and processing in the Barnett Shale Formation in northern Texas were 90 percent higher than what the EPA's Inventory of U.S. Greenhouse Gas Emissions had estimated.
About a third of the factors used to estimate pipeline leaks and other natural-gas emissions in the most recent inventory, for 2015, are based on a 1996 study by the EPA and an industry group then known as the Gas Research Institute. The EPA's IG found in 2014 "there was significant uncertainty in the study data," meaning the EPA's assumptions on the amount of methane that spews from pipelines "may not be valid."
The harm caused by faulty estimates extends beyond oil and gas. An emission factor designed to estimate ammonia releases from poultry farms, for example, "is probably far too low" according to a report by the Environmental Integrity Project. These emissions contribute to problems like algae blooms, which can spread rapidly and kill marine life in waterways like the Chesapeake Bay.
'Pandora's Box of Problems'
The EPA, according to its spokeswoman, has begun executing a plan to improve the science that underlies emission factors and review the estimates more frequently. Among the changes: some companies now must report pollution data electronically to the agency.
The Trump administration proposed slashing the EPA's budget by 31 percent for fiscal year 2018, although Congress has so far extended existing funding levels through a series of short-term resolutions. Progress on emission factors will hinge on "available resources," the EPA spokeswoman wrote in an email, declining to specify a deadline for the project.
The agency said it does not intend to limit the use of emission factors to the purpose for which they were originally intended—to inform pollution inventories. That means, for example, that the numbers will still be used in permits.
Many in industry are fine with that. When the EPA asked in a 2009 Federal Register notice for suggestions on how to improve the system, companies from electric power generators to auto manufacturers argued for the status quo, saying emission factors were sometimes their only data option. Trade groups like the American Petroleum Institute and the American Chemistry Council argued their members should not be penalized if the EPA discovered a deficient factor had caused a permit to underestimate pollution. API said it worried that additional industry data supplied to the EPA to help it improve the numbers "could be misused for enforcement or other purposes." Neither group responded to requests for comment.
Public health advocates, on the other hand, want more. Some companies game the system to avoid EPA permitting fees and civil penalties, said Neil Carman, clean air director for the Lone Star Chapter of the Sierra Club in Austin. "We don't know what the emissions really are," he said. "It's a real Pandora's box of problems."
Carman and other advocates say they understand emission factors will have to be used in some circumstances, and that some types of pollution can be estimated with reasonable accuracy. They also maintain, however, that air monitoring should be more widely deployed. "Where you can do direct monitoring of emissions, that should be required," said Schaeffer, of the Environmental Integrity Project.
Schaeffer faults the EPA for giving some companies an out. It allows operators of power plants, for example, to choose between using continuous monitoring to measure fine particles, or a combination of quarterly testing and emission factors. Some of these plants already have monitoring systems installed, Schaeffer said, but "it's easier to mask noncompliance using emission factors."
Shining a 'Bright Light' on Pollution
California's Bay Area Air Quality Management District changed its approach after studies showed leaks from oil refineries in the area—known as fugitive emissions—were likely underrepresented in emission factors. "We decided, based on that information, that we needed additional ways to better identify fugitive emissions and to shine a bright light on those fugitive emissions," said Eric Stevenson, the district's director of meteorology, measurement and rules.
In 2016, the district urged refineries to install "open path" monitoring systems—which use beams of light to detect the presence of gases like benzene—and make the data available to the public in real time. Chevron installed such a system on the perimeter of its refinery in Richmond, California, in 2013.
The company didn't respond to specific questions about the monitoring but said its focus "on running the refinery efficiently and investing in new technologies" has significantly reduced air pollution since the 1970s. Denny Larson, executive director of the Community Science Institute - CSI for Health and Justice, an environmental group that helps the public test for pollution, said the system in Richmond shows levels of chemicals in the air at a given moment and can alert residents to emission spikes that can trigger asthma attacks and other serious health problems.
"It's showing lots of pollution has been flying under the radar that's extremely toxic and problematic," Larson said. "We can prove what we've always known."
Reposted with permission from our media associate The Center for Public Integrity.
EcoWatch Daily Newsletter
By Jeff Masters, Ph.D.
Tropical Storm Josephine Also No Threat to Land<p>Meanwhile, the season's record-earliest tenth named storm, Tropical Storm Josephine, was also struggling with high wind shear as it traced out a path over the open ocean.</p><p>At 5 a.m. EDT Saturday, Josephine was located about 310 miles east of the northern Leeward Islands, moving west-northwest at 15 mph with top sustained winds at 45 mph. Josephine is expected to bring one to three inches of rain over portions of the northern Leeward Islands, the Virgin Islands, and Puerto Rico over the weekend. Josephine will encounter steadily rising wind shear through Monday, peaking at a very high 30 – 35 knots. This high shear is likely to destroy Josephine's circulation by Monday, before the storm can affect any other land areas.</p><p><em>Reposted with permission from <a href="https://yaleclimateconnections.org/2020/08/tropical-storm-kyle-forms-unlikely-to-affect-land/" target="_blank">Yale Climate Connections</a>. </em><em></em></p>
By Ute Eberle
In May 2017, shells started washing up along the Ligurian coast in Italy. They were small and purple and belonged to a snail called Janthina pallida that is rarely seen on land. But the snails kept coming — so many that entire stretches of the beach turned pastel.
The Ligurian coast has been swept by snails turning its color pastel.
A World Between Worlds<p>The neuston comprises a multitude of weird and wonderful creatures. </p><p>Many, like the Portuguese man-of-war, which paralyzes its prey with venomous tentacles up to 30 meters long, are colored an electric shade of blue, possibly to protect themselves against the sun's UV rays, or as camouflages against predators.</p><p>There are also by-the-wind sailors, flattish creatures that raise chitin shields from the water like sails; slugs known as sea dragons that cling to the water's surface from below with webbed appendages; barnacles that build bubble rafts as big as dinner plates; and the world's only marine insects, a relation of the pond skater.</p><p>They live "between the worlds" of the sea and sky, as Federico Betti, a marine biologist at the University of Genoa, puts it. From below, predators lurk. From above, the sun burns. Winds and waves toss them about. Depending on the weather, their environment may be warm or cool, salty or less so.</p>
Sea snails can make up the neuston.
Velella velella jellyfish living on the surface of the ocean.<p>But now, they face another — manmade — threat from nets designed to catch trash. A project called <a href="https://theoceancleanup.com/" target="_blank">The Ocean Cleanup</a>, run by Dutch inventor Boyan Slat, has raised millions of dollars in donations and sponsorship to deploy long barriers with nets that will drift across the ocean in open loops to sweep up floating garbage. </p>
Collecting With the Current<p>"Plastic could outweigh fish in the oceans by 2050. To us, that future is unacceptable," <a href="https://www.dw.com/en/green-entrepreneur-sets-sights-on-great-pacific-garbage-patch/a-38855785" target="_blank">The Ocean Cleanup</a> declares on its website.</p><p>But Rebecca Helm, a marine biologist at the University of North Carolina, and one of the few scientists to study this ecosystem, fears that The Ocean Cleanup's proposal to remove 90% of the plastic trash from the water could also virtually wipe out the neuston.</p><p>One focus of Helm's studies is where these organisms congregate. "There are places that are very, very concentrated and areas of little concentration, and we're trying to figure out why," says Helm.</p><p>One factor is that the neuston floats with ocean currents, and Helm worries that it might collect in the exact same spots as marine plastic pollution. "Our initial data show that regions with high concentrations of plastic are also regions with high concentrations of life."</p>
Waste collection in the Pacific Ocean heralded by The Ocean Cleanup.<p>The Ocean Cleanup says Helm's concerns are based on "misguided assumptions."</p><p>"It's true that neustonic organisms will be trapped in the barriers," says Gerhard Herndl, professor of Aquatic Biology at the University of Vienna and one of project's scientific advisors. "But these organisms have dangerous lives. They're adapted to high losses because they get washed ashore in storms and they have high reproductive rates. If they didn't, they'd already be extinct."</p><p>Helm says they just don't know how quickly these creatures reproduce, and in any case recovering from passing storm is very different from surviving The Ocean Clean Up's systems which could be in place for years.</p>
Communication Breakdown<p>The Ocean Cleanup invited Helm to a symposium on the topic in December, where both sides presented their points of views and didn't seem to find much common ground. Since then, direct communication between them has stopped, says Helm. "They're not interested in talking to me anymore."</p><p>Both sides agree that much is still unknown about the neuston. But one thing that has been established is that most of the oceans' fish spend part of their lifecycle in the neuston. "More than 90% of marine fish species produce floating eggs that persist on the surface until hatching," Betti says.</p><p>The Ocean Cleanup has undertaken one of the few studies into this ecosystem, collecting data on the neuston on the relative abundance of neuston and floating plastic debris in the eastern North Pacific Ocean during a 2019 expedition to the Pacific Garbage Patch, an area where plastic pollution has accumulated on a vast scale. But it is not yet sharing what it has found. The information was being prepared for publication in an as of yet unspecified journal, probably some time next year, an Ocean Cleanup spokesperson said. </p>
Inshore Solution?<p>Helm believes the best way to tackle the marine plastic problem would be to position the barriers closer to land — across river mouths and bays — to catch garbage before it reaches the sea.</p><p>"Stopping the flow of plastic into the ocean is the most cost-effective — and literally effective — way to ensure that it's not entering our environment," she says. </p><p>As for the plastic already floating in open waters, she does not believe it is worth sacrificing parts of neuston and wants to see more research first. </p><p>The Ocean Cleanup has made barriers across rivers a part of its mission. But it is also going ahead with its original vision of pulling trash from the open water. In late 2018, the project deployed a 600-meter, u-shaped prototype net into the <a href="https://www.dw.com/en/environment-conservation-plastic-oceans/a-54436603" target="_blank">Great Pacific Garbage Patch</a>. </p><p>The system ran into difficulties, failing to retain plastic as hoped, and needing to be brought shore for repairs and a design upgrade, after which Ocean Cleanup says it gathered haul of plastic that it will recycle and resell to help fund future operations.</p><p>Over the next two years, the project hopes to deploy up to 60 such barriers to collect drifting flotsam. Helm isn't the only one concerned about these plans.</p><p><span></span>"We should think twice about every action we take in the sea," Betti says. "In nature, nothing is as easy as we think, and often, we've done a lot of damage while trying to do a good thing."</p><p><em>Reposted with permission from <a href="https://www.dw.com/en/environment-conservation-plastic-oceans/a-54436603" target="_blank">Deutsche Welle</a>.<a href="https://www.ecowatch.com/r/entryeditor/2646992655#/" target="_self"></a></em><em></em></p>
By Hope Dickens
Molly Craig's day begins with feeding hungry baby birds at 6 a.m. The birds need to be fed every 15 minutes until 7 at night. If she's not feeding them, other staff at the Fox Valley Wildlife Center in Elburn, Illinois take turns helping the hungry orphans.
By Douglas Broom
"Forests are the lungs of our land, purifying the air and giving fresh strength to our people," said former U.S. president, Franklin Roosevelt.
So the FAO is using Twitter to remind the world of these five hidden benefits of forests.
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