Thornton & Droessler - Upcoming NAAQS Changes and Challenges
David Thornton Up in the Air: Rochester May 9, 2012
Agenda • Federal View • Minnesota’s View • Ground-‐level Ozone and PM2.5 • Impacts of NonaNainment • State ImplementaPon Plan • History of MN Voluntary AcPons • AddiPonal Voluntary OpPons?
CAA and NAAQS • EPA uses its Clean Air Act (CAA) authority to regulate air quality • SecPon 109 speciﬁes EPA s responsibility for prescribing NaPonal Ambient Air Quality Standards (NAAQS) requisite to protect public health • SecPon 107 provides that implementaPon falls primarily to the states • NAAQS set for six pollutants • Carbon monoxide, lead, NOX, SO2, ozone, and parPculate maNer (PM10 and PM2.5)
NAAQS Reviews • NAAQS are supposed to be reviewed every ﬁve years and revised as needed • Account for new informaPon on health impacts • Clean Air Science Advisory CommiNee reviews data and makes recommendaPons to the Administrator • Reviews have not always occurred – or new informaPon has shown that standard is protecPve • Recent ﬂurry of review and revision of standards • Between 2008 and 2013, EPA will review ALL
EPA’s NAAQS Revisions Pollutant NAAQS Promulga0on Date Designa0ons Eﬀec0ve Ozone March 2008 2012 Lead October 2008 December 2010 NO2 January 2010 February 2012 SO2 June 2010 2012 Carbon Monoxide August 2011 2013 (standard retained) PM2.5 2013 2015 Ozone July 2014 2016 (9/20/2011)
ImplemenPng a New NAAQS • Make aNainment/nonaNainment designaPons • States review air quality monitoring and other informaPon • Does the air quality meet the standard? (ANainment) • Is air quality worse than prescribed by the standard? (NonaNainment) • EPA reviews state informaPon and makes oﬃcial designaPon • DesignaPon is a federal rulemaking
ANainment/NonaNainment • ANainment is consistent with protecPng human health • New, lowered standards makes nonaNainment likely • NonaNainment brings speciﬁc requirements • NonaNainment permijng – oﬀsets and “lowest achievable emission rate” for new or modifying sources • State ImplementaPon Plan with control measures • Reasonably Available Control Technology/Reasonably Available Control Measures – Apply reasonable controls to exisPng sources • Reasonable Further Progress – DemonstraPng progress in emission reducPons
Ozone and Fine ParPculate MaNer (PM2.5) • Components formed from atmospheric reacPons of emissions of other pollutants • Create larger nonaNainment areas • Not single source based • Many sources contribute • ParPcularly combusPon sources • Including smaller sources – less controlled • Where Minnesota is closest to the standard
Ozone NAAQS • Standard set in 2008: 75 ppb standard • EPA is implemenPng this standard • SPll under legal challenge • EPA began but dropped a potenPal reconsideraPon of this standard • Looking at a range of 60 – 70 ppb • Ozone standard will be reviewed in 2013
Ozone Standard of 70 ppb based on 2008-‐2010 Data 13
Ozone Standard of 65 ppb based on 2008-‐2010 Data 14
Ozone Standard of 60 ppb based on 2008-‐2010 Data 15
PM2.5 NAAQS Review • Schedule • June 2012 proposal, June 2013 promulgaPon • 2015 designaPon • Based on 2012 – 2014 data • Likely 2018 SIP due date • Standard likely to become more stringent • Annual standard range:11 –13 µg/m3 • Daily standard range: 30 – 35 µg/m3 • Likely pairing: 11 with 35, 13 with 30
Consequences of NonaNainment • Signiﬁcant for businesses, government and ciPzens • Air permijng, increased monitoring and modeling, State ImplementaPon Plan • Adverse health impacts of not meePng standard • Economic Impact of NonaNainment • 1999 MN Chamber of Commerce Report esPmated at $189 -‐ $266 million annually • Major health beneﬁts to reducing ﬁne parPcle and ozone polluPon • EPA esPmates $2 trillion annually by 2020 from the 1990 Clean Air Act Amendments
State ImplementaPon Plan • If in nonaNainment, states must submit an implementaPon plan (SIP) • To demonstrate how NAAQS will be aNained • Include control measures to bring areas into aNainment • EPA must review and approve the SIP
SIP Components Legal Air Quality Authority Monitoring Program Control Strategy Resources Demonstra0on Emission Limi0ng Rules and Regs Modeling Data New Source Review Enforcement Voluntary and Non-‐Tradi0onal Mobile Measures Measures and Fuels PermiPng Adapted from presentation by Tom Helms, EPA, on nonattainment/SIP
CAA Requirements for Ozone NA Areas Extreme Severe Serious Traffic controls during congested periods Clean fuels requirement for boilers (plan in 3 years) No waivers from 15% or 3% reduction requirements Requirement for fee on major sources if fail to attain Measures to offset VMT growth (108(f) measures) due in 2 yrs Contingency measures if miss milestone Specific NSR requirements for modifications to existing sources Moderate VMT demonstration due in 6 years (TCM program if needed) Clean fuel program due in 4 years (if applicable) Enhanced I/M due in 2 years Plan for 3% annual average reductions due in 4 yearsMarginal Demonstration of attainment in 4 years Basic I/M (if not already required) due immediately Stage II gasoline vapor recovery due in 2 years RACT: Existing & future CTG s & RACT on major sources (existing due in 2 years) Plan for 15% VOC reduction within 6 years is due in 3 years New Source Review (NSR) program due 2 years (corrections to existing, also) RACT corrections due in 6 months; I/M corrections, immediatelyEmission inventory due in 2 yrs; requirements for emission statements due in 2 yrs; periodic inventories
CAA Requirements for Ozone Areas • Requirements for all nonaNainment areas • NonaNainment New Source Review • Emissions oﬀsets • Lowest Achievable Control Technology • AddiPonal requirements for moderate NA areas are the ones you really want to avoid • InspecPon/maintenance of vehicles • 15% reducPon in inventory • Stage 2 vapor recovery at gasoline dispensing staPons
Sources of Urban Air PolluPon • Mobile Sources (Vehicles) • On road • Oﬀ road • Small engines • Small staPonary sources • ResidenPal burning • Small commercial/Industrial • Large staPonary sources
Voluntary Measures • AcPon Trajectory: • Clean Air MN • Project Green Fleet • MPCA through DERA and CMAQ • Minnesota’s Clean Air Dialogue • Addressing mobile and area sources
Clean Air Minnesota and Project Green Fleet 2003 -‐ MN Chamber of Commerce Study; MCEA; MPCA; RPU 2006 -‐ PGF ﬁrst in Rochester with RPU, Mayo, City of Rochester, First Student, and the Hoover Hornets
Voluntary Measures • Ozone Advance (PM2.5 prototype?) • State, tribal, and/or local governments can parPcipate in Ozone Advance if they meet the basic program eligibility criteria: • The area(s) designated is/are not designated nonaNainment for either the 1997 8-‐hour or the 2008 ozone NAAQS. • IdenPfy and report on the air monitor(s) that reﬂect the air quality in the area(s). • Emissions inventory reporPng must have occurred prior to parPcipaPon in Ozone Advance.
Voluntary Measures • Ozone Advance • Promotes local acPons in aNainment areas to help these areas conPnue to meet the ozone NAAQS. • To apply for parPcipaPon, an area must submit a sign-‐up leNer • Expressing area’s willingness to coordinate with EPA, state, tribal and/or local stakeholders and to quickly implement measures to reduce ozone • Does not need to idenPfy speciﬁc control measures • Should be signed by the appropriate state, tribal and/or local oﬃcials with the authority to implement the program
Chicago Clean Diesel ConstrucPon Provisions • Score requirements • Fleet average • Self-‐reporPng by contractor
Voluntary Measures • EPA’s Voluntary ResidenPal Wood Smoke ReducPon IniPaPve • Great American Woodstove Changeout Campaign (Main focus) • Outdoor Wood-‐ﬁred hydronic heaters • Voluntary Fireplace Emission Standard • “Burn Wise” NaPonal EducaPon and Outreach Campaign
Voluntary Measures • Wood Stove Change out • Voluntary, incenPve-‐based (e.g., cash rebates, vouchers) eﬀort to encourage owners of old, ineﬃcient woodstoves to replace with a cleaner burning hearth appliance, like: • Gas stoves • Wood pellet stoves • EPA-‐cerPﬁed wood stoves
Thank You -‐ QuesPons? David Thornton Assistant Commissioner for Air Policy Minnesota PolluPon Control Agency 651-‐757-‐2018 firstname.lastname@example.org Bill Droessler Senior Director of Strategic Project Planning Environmental IniPaPve 612-‐334-‐4488 ext. 103 bdroessler@environmental-‐iniPaPve.org
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