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 (standard retained)

August 2011 2013

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

Trends in Key Pollutants: Twin CiPes, 1999-‐2010

0%

20%

40%

60%

80%

100%

120%

140%

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Percen

t of N

aPon

al Ambien

t Air Quality Standard

Standard NO2 Annual (1971) NO2 1-‐HR (2010) SO2 1-‐HR (2010)

O3 8-‐HR (2008) PM2.5 Annual (1997) PM2.5 24-‐HR (2006)

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

Minnesota Ozone Levels

60 59 59 58 62 61

63 60 60

65 63 62

58 54

49

62

0

10

20

30

40

50

60

70

80

Ozone

Con

centraPo

n (ppb

) 2009-‐2011 Standard

Ozone Standard of 70 ppb based on 2008-‐2010 Data

13


14


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

Daily PM2.5 Design Values

31

21 19

30 30 28

27 28

33 34

17

0

5

10

15

20

25

30

35

40 2008-‐2010

2009-‐2011

Standard

PotenPal Standard

Annual PM2.5 Design Values

9.2

6.6 5.8

9.5 9.6 8.8 8.6

9.0 9.6

10.0

5.4

0

2

4

6

8

10

12

14

16

2008-‐2010

2009-‐2011

Standard

PotenPal Std -‐ Low

PotenPal Standard -‐ High

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

Authority

Program Resources

Enforcement

Modeling Data

PermiPng

Voluntary and Non-‐Tradi0onal

Measures Mobile Measures

and Fuels

New Source Review

Emission Limi0ng Rules and Regs

Control Strategy Demonstra0on

Air Quality Monitoring

Adapted from presentation by Tom Helms, EPA, on nonattainment/SIP

Emission inventory due in 2 yrs; requirements for emission statements due in 2 yrs; periodic inventories RACT corrections due in 6 months; I/M corrections, immediately New Source Review (NSR) program due 2 years (corrections to existing, also) Plan for 15% VOC reduction within 6 years is due in 3 years RACT: Existing & future CTG’s & RACT on major sources (existing due in 2 years) Stage II gasoline vapor recovery due in 2 years Basic I/M (if not already required) due immediately Demonstration of attainment in 4 years Plan for 3% annual average reductions due in 4 years Enhanced I/M due in 2 years Clean fuel program due in 4 years (if applicable) VMT demonstration due in 6 years (TCM program if needed) Specific NSR requirements for modifications to existing sources

Measures to offset VMT growth (108(f) measures) due in 2 yrs Contingency measures if miss milestone

Requirement for fee on major sources if fail to attain No waivers from 15% or 3% reduction requirements Clean fuels requirement for boilers (plan in 3 years) Traffic controls during congested periods

Marginal

Moderate

Serious

Severe

Extreme

CAA Requirements for Ozone NA Areas

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

What are area and mobile 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 •  EPA website: hNp://www.epa.gov/ozoneadvance/ •  Basic InformaPon

•  Eligibility •  ParPcipaPon •  Ozone Flex •  Resources •  Frequent QuesPons

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

Rail Partnership

•  Variable operaPons •  MulPple types of vehicles •  Switchers •  Hostlers •  Cranes •  Lius •  Trucks

•  Idling

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 [email protected] Bill Droessler Senior Director of Strategic Project Planning Environmental IniPaPve 612-‐334-‐4488 ext. 103 bdroessler@environmental-‐iniPaPve.org