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The public comment is in, both written and spoken. A state agency is scheduled to vote Dec. 6 on Texas' clean-air plan that could include a proposal adding significantly to the cost of new air conditioning units for most Texans as of 2002.
The air conditioning proposal probably is the most controversial part of the pending Texas clean air plan that will go to the U.S. Environmental Protection Agency.
That is because the proposal to require a catalytic coating to air conditioning unit coils - a coating available now from only one New Jersey-based supplier - will apply to homes and businesses in the most populous side of the state, the areas alongside Interstate 35 and all parts east.
The three commissioners of the Texas Natural Resources Conservation Commission should vote "no" on the air conditioning proposal in December if the staff doesn't kill it first after reviewing the thousands of written comments and those spoken during a recent round of statewide hearings.
The opposition comes from air conditioner manufacturers, consumer groups and homeowners alike, and it is based on sound reasoning. The main objection is that the technology and the science behind it are unproven.
Here is how the catalytic coating is supposed to work: The coils on the outdoor units would be coated with a proprietary metallic material from Engelhard Corp.
When low-level ozone, the kind of air pollution EPA is trying to reduce in Texas, comes in contact with the coating, it supposedly converts ozone molecules to oxygen.
One key objection comes from using air conditioning units for this purpose. Air conditioners are not considered air pollution sources when functioning correctly. The TNRCC proposal, in effect, would put a clean-air tax to reduce pollution that really comes from autos, power plants and other sources.
So that, on its face, is unfair.
It's interesting that Volvo has added Engelhard's coatings to Volvo auto radiators in an effort to reduce ozone pollution in urban areas. That may be more appropriate since auto emissions lead to ozone pollution. But no results have been measured or reported by Volvo or Engelhard.
Beyond that, this approach has not been tested anywhere. In fact, air conditioner manufacturers, including Friedrich Air Conditioning Co. in San Antonio and Goodman Manufacturing Co. in Houston, have announced that Engelhard has refused their requests to receive the coating material for testing on units.
"It is extremely unlikely that the coating is effective," said Brian Campbell, Friedrich marketing vice president, "and nearly impossible for it to be effective on room air conditioners and heat pumps where the condensing coil is typically wet with condensation."
"The technology says the chemistry works," added Allen Kessler, Goodman Manufacturing vice president for technology and government relations. "But does it work to the level touted in the proposal and in real-world conditions? Those are things we don't know."
What is proven, Kessler said, is that higher-efficiency air conditioning units reduce demand on power plants, which reduces pollution coming from the power plants. That is why Goodman asked the TNRCC to make higher-efficiency units an alternative to the units with catalytic coating.
Consumer groups also have attacked the proposal.
"According to industry spokesmen, the unproven coating technology may add as much as $1,000 to the cost of a unit, making it cost-prohibitive to many Texans, and (it) may have unintended consequences, including environmental risks," said Peggy Venable, director of Texas Citizens for a Sound Economy in Austin.
Public Citizen hardly is known for siding with manufacturers, but its Texas office does so with the air conditioner issue.
"Who knows but that these air conditioners with catalytic coatings would leave a toxic legacy in our back yards in 10 years?" said Tom "Smitty" Smith, director of the Texas office.
Smith said Public Citizen plans to propose in the 2001 session of the Texas Legislature a state property tax credit to repay property owners buying new air conditioning units with a Season Energy Efficiency Rating of 14 or higher when replacing units with SEER ratings of below 10, or those manufactured before 1992.
Smith conceded the rebate idea would be opposed by utilities, even in San Antonio, where City Hall gets a large amount of revenue from a percentage of City Public Service bills.
But the cost to San Antonio would be higher if the city is listed as out of compliance with EPA clean-air standards, Smith noted.
Several San Antonians also sent me copies of their letters to TNRCC after this column published information about the proposal Sept. 20.
One was Dr. David Grant, who complained about the bad logic of using air conditioning units to remove ozone.
"If you stay home in your own air-conditioned house, you're helping hold down ozone production. You shouldn't have to pay for cleaning up the ozone that the guy driving all over town produced," Grant wrote to TNRCC.
In short, TNRCC, San Antonio doesn't want catalytic-coated air conditioning units.