Texas Conference of Urban Counties
500 West 13th Street
Austin, TX 78701
Phone: 512/476-6174

Attaining the federal ozone standard is a significant challenge for Texas. Nonattainment areas, including Houston/Galveston, Dallas/Fort Worth, Beaumont/Port Arthur and El Paso represent 49% of the state population and 62% of the state gross area product for 1999. When the near nonattainment areas of San Antonio, Austin and Tyler/Longview are included, 67% of the population of the State is directly affected. In an effort to ensure that the TCEQ and local areas are working in partnership and that critical information is available upon which the most effective plans to attain and maintain compliance are developed, the following issues should be addressed:

1. Regional stakeholders, including both public and private sector leaders, must take an active role in developing an appropriate attainment strategy for their region. TCEQ should utilize the regional stakeholders as a resource to facilitate information gathering, community education and consensus building.

2. TCEQ should clearly define opportunities for ongoing local participation in SIP development, and within the confines of the regulatory requirements, TCEQ should incorporate input to the greatest extent possible.

3. In order for TCEQ and the regional stakeholders in each non-attainment area to work in partnership, information must be made readily available, on a timely basis, to all involved participants.

4. TCEQ should conduct the SIP development process, in consultation with regional stakeholders, to ensure to the greatest extent possible that regions are not subject to EPA sanctions or found in violation of transportation conformity requirements.

5. In order to ensure the development of the most effective attainment plans, it is critical that modeling be based on exceedance days that represent the typical conditions under which ozone exceedances occur in each region. TCEQ should work with regional stakeholders to model more typical exceedance episodes and incorporate the findings into the current SIP development process.

6. Additional monitors should be put in place to ensure that monitoring is conducted throughout all counties within non-attainment areas and areas adjacent to non-attainment areas. Widespread monitoring will improve the understanding of air chemistry and factors that contribute to the formation of ozone.