EPA-450/4-74-006
DECEMBER 1974
(OAQPS NO. 1.2-024)
GUIDELINES FOR AIR QUALITY
MAINTENANCE PLANNING AND ANALYSIS
VOLUME 5 :
CASE STUDIES IN PLAN DEVELOPMENT
SBBSfW S&tffJFr
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EPA-450/4-74-006
(OAQPS NO. 1.2-024)
GUIDELINES FOR AIR QUALITY
MAINTENANCE PLANNING AND ANALYSIS
VOLUME 5 :
CASE STUDIES IN PLAN DEVELOPMENT
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1974
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OAQPS GUIDFLINE SERIES
This report is one of the guideline series of reports issued by the
Environmental Protection Agency, Office of Air Quality Planning and
Standards (OSOPS), to provide information on air quality maintenance
to state and local air pollution control agencies. Copies are avail-
able free of charge to Federal employees, current contractors, grantees,
and nonprofit organizations, as supplies permit, from the Air Pollution
Technical Information Center, Environmental Protection Agency, Research
Triangle Park, North Carolina 27711, or at a nominal cost from the
National Technical Information Service, 5285 Port Royal Road, Spring-
field, Virginia 22161.
This report was furnished to the Environmental Protection Agency by
the Research Triangle Institute, Research Triangle Park, N.C., in
fulfillment of Task Order No. 9, Contract No. 68-02-1386. The contents
are reproduced herein as received form the contractor. Prior to
final preparation the report underwent review and editing by the
Environmental Protection Agency. The report constitutes digests of
trial Air Quality Maintenance Plans developed by four contractors
for Baltimore, Denver, St. Louis, and San Diego. These trial Air
Quality Maintenance Plans were developed prior to the issuance of all
of the guideline documents and, accordingly, practices and procedures
used are not necessarily those now advocated by the Environmental Pro-
tection Agency. Schedules published in Federal regulations take
precedence over schedules aiven in the trial plans.
Publication Mo. EPA-450/4-74-006
(OAQPS Guideline No. 1.2-024)
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FOREWORD
This document is the fifth in a series comprising Guidelines for Air
Quality Maintenance Planning and Analysis. The intent of the series is to
provide State and local agencies with information and guidance for the prepa-
ration of Air Quality Maintenance Plans required under 40 CFR 51. The volumes
in this series are:
Volume ]j_ Designation of Air Quality Maintenance Areas
Volume 2j_ Plan Preparation
Volume 3j_ Control Strategies
Volume 4j_ Land Use and Transportation Consideration
Volume 5: Case Studies in Pfan Development
Volume 6^ Overview of Air Quality Maintenance Area Analysis
Volume 7j_ Projecting County Emissions
Volume 8: Computer -Assisted^\rea Source Emissions Gridding
Procedure
Volume 9_ Evaluating Indirect Sources
Volume 1 0: Reviewing New Stationary Sources
Volume IJ: Air Quality Monitoring and Data Analysis
Volume 12: Applying Atmospheric Simulation Models to Air Quality
Maintenance Areas
Volume 13: Allocating Projected Emissions to Sub-County Areas
Additional volumes may be issued.
All references to 40 CFR Part 51 in this document arc to the regulations
as amended through July I974.
v>
III
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TABLE OF CONTENTS
Chapter page
LIST OF FIGURES vii
LIST OF TABLES vii
I INTRODUCTION 1
II SAN DIEGO TRIAL AIR QUALITY MAINTENANCE PLAN 5
I. Characterization of the San Diego Air Quality
Maintenance Study Area 5
II. Intergovernmental Cooperation 6
III. Baseline Emissions Inventory 14
IV. Emission Projections 17
V. Establishment of Baseline Air Quality 18
VI. Air Quality Projections to 1985 22
VII. Selection of Maintenance Strategies 23
VIII. Legal Authority ' 33
Summary of San Diego AQMSA 35
III ST. LOUIS TRIAL AIR QUALITY MAINTENANCE PLAN 41
I. AQMSA Description 41
II. Intergovernmental Cooperation . 41
III. Baseline Emissions Inventory 52
IV. Emission Projections 55
V. Establishment of Baseline Air Quality 59
VI. Air Quality Projections 61
VII. Selection of Maintenance Strategies 67
VIII. Legal Authority 74
Summary of St. Louis AQMSA 76
IV BALTIMORE TRIAL AIR QUALITY MAINTENANCE PLAN • 81
I. Characteristics of Baltimore AQMSA 81
II. Intergovernmental Cooperation 85
III. Baseline Emissions Inventory 97
IV. Emission Projections 99
V. Establishment of Baseline Air Quality 102
VI. Air Quality Projections to 1985 103
VII. Selection of Maintenance Strategies 104
VIII. Legal Authority 108
Summary of Baltimore AQMSA 109
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TABLE OF CONTENTS (continued)
Chapter Page
V DENVER TRIAL AIR QUALITY MAINTENANCE PLAN 115
I. Denver AQMA Characteristics 115
II. Intergovernmental Cooperation 117
III. Baseline Emissions Inventory 129
IV. Emission Projections 132
V. Establishment of Baseline Air Quality 136
VI. Air Quality Projections to 1985 138
VII. Selection of Maintenance Strategies 141
VIII. Legal Authority 144
Summary of Denver AQMSA 146
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LIST OF FIGURES
Figure Page
II-l Alternative "A"—AQMP Process Carried Out by CPO 9
II-2 Alternative "B"--AQMP Process Carried Out By APCD 11
II1-1 St. Louis Air Quality Maintenance Study Area > 42
111-2 Existing AQMSA Responsibilities 44
III-3 Missouri Air Conservation Commission Advisory
Committee on Transportation Control 47
III-4 St. Louis AQMP Development and Coordination 51
III-5 St. Louis AQMP Development Timetable 73
IV-1 Baltimore Air Quality Control Region 82
IV-2 Projected Effectiveness of SIP and AQMP 84
IV-3 Existing Institutional Relationships—Baltimore
Air Quality Maintenance Planning 96
IV-4 Sample Matrix Showing Evaluation Data for Control Measures
Affecting Domestic and Commercial Heating and Cooling as
a Suspended Particulate Source Category 106
LIST OF TABLES
Table P_a£§
II-l TECHNICAL ASSUMPTIONS 16
II-2 SAN DIEGO COUNTY AIR QUALITY, 1972 20
II-3 ORGANIZATION OF DELPHI STUDY 30
II-4 REGIONAL COMPREHENSIVE PLAN POLICIES AND TRANSPORTATION
PLANNING GUIDES 32
III-l ST. LOUIS AIR QUALITY MAINTENANCE STUDY AREA
EMISSION PROJECTION - SUMMARY 58
III-2 ST. LOUIS AQMSA - SUMMARY OF AIR QUALITY PROJECTIONS 64
111-3 PROPOSED ATTAINMENT/MAINTENANCE PLAN 71
V-1 AQMP PREPARATION INPUT 126
VI1
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Chapter I
INTRODUCTION
This guideline is the fifth in a series issued by the Environmental
Protection Agency (EPA) to assist the states in the preparation of Air
Quality Maintenance Plans (AQMPs) required under 40 CFR 51. While this
series of documents was in preparation, a concurrent effort was made to
provide EPA with experience in the actual preparation of AQMPs by
developing trial maintenance plans for Baltimore, Denver, St. Louis,
and San Diego. Each of these trial AQMPs was summarized, for inclusion in
this guideline document, by the contractor who prepared the plan.
The contractors selected to prepare trial AQMPs were experienced
in the technical phases of air pollution control planning and implementation.
This experience was essential since both the contractors and EPA were
engaged in developing the techniques for Air Quality Maintenance Area (AQMA)
analysis and in exploring new relationships for intergovernmental coopera-
tion.
The trial AQMPs prepared during this study represent exercises to
demonstrate administrative and technical procedures available and do not
necessarily constitute final, acceptable plans. Because no precedents
were available while these trial AQMPs were in preparation, analysis
procedures used do not always conform to the procedures subsequently
published in the guidelines. The time available and the resources that
could be committed to these studies were too limited to permit thorough
exploration of all aspects of air quality maintenance planning. Never-
theless, the interpretation of analyses, the intergovernmental relation-
ships, and the maintenance strategies developed for these examples will
be useful to, but are not binding on, the officials responsible for
developing AQMPs for the areas considered. Whenever dates given in the
trial plans are inconsistent with dates in EPA regulations, EPA dates
govern.
For each of the four cities selected for trial AQMP preparation, an
associated area having the potential for violating the National Ambient
*
Allen M. Voorhees and Associates, Inc.; Engineering-Sciences, Inc.;
GCA Corporation; and TRW, Transportation and Environmental Operations.
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Air Quality Standards during the period 1975 to 1985 was identified;
for the purposes of the trial plans, these areas were designated as Air
Quality Maintenance Study Areas (AQMSAs). These AQMSAs have many of the
problems that can be expected to be encountered in the preparation of
AQMPs for the AQMAs designated by the Administrator. The digests of AQMPs
presented in this volume provide an opportunity for reviewing the high-
lights of plan preparation experience, including solutions to problems
experienced. The full text versions of the four trial AQMPs will be
available from the National Technical Information Service (NTIS). The
full titles, EPA report number and the NTIS number of the full text
trial AQMPs are:
Development of a Trial Air Quality Maintenance Plan Using the
Baltimore Air Quality Control Region. EPA-450/3-74-050
NTIS PB 416/AS
Development of an Example 10-Year Air Quality Maintenance Plan
for the Denver AQMSA. EPA-450/3-74-053
NTIS PB 237-414/AS
Development of a Trial Air Quality Maintenance Plan for the
St. Louis AQMSA. EPA-450/3-74-052
NTIS Not assigned
Development of a Sample Air Quality Maintenance Plan for
San Diego. EPA-450/3-74-051
NTIS PB 236-932/AS
The characteristics of the AQMPs for which trial plans were prepared
range from single county to two-state, multi-county political jurisdiction,
from three to four criteria pollutants of concern, through existing control
agency activity varying over a wide range, from minimum to intense popular
concern for environmental quality, and from virtually no assigned respon-
sibility or authority, to well-coordinated interagency cooperative activity.
The four digests of the full text trial AQMPs have been prepared in
identical format to facilitate comparison of the problems encountered and
solutions proposed. The subjects covered in each of the trial AQMP digests
are:
• Characteristics of the AQMSA
Intergovernmental cooperation
• Baseline emissions inventory
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• Emissions projections
Baseline air quality
• Air quality projections
• Selection of maintenance strategies
• Legal authority
Appended to each trial AQMP digest is a summary for each pollutant of
concern giving the baseline year air quality, the anticipated air quality
for the year of scheduled attainment, the percentage reduction required to
reduce baseline year air quality to NAAQS, and the control strategies
and date of implementation required to attain NAAQS.
Throughout the preparation of these trial AQMPs, invaluable
assistance was provided by State, regional, and local air pollution
control officials, staff members of planning agencies, highway or trans-
portation departments and councils of government, and EPA regional rep-
resentatives. Full acknowledgement of this cooperation is made in the
several individual full text trial AQMPs.
The preparation of these digests of the four trial AQMPs has been
under the direction of Mr. Thomas M. Donaldson, EPA Project Officer,
assisted by other members of the staff of the Plans and Guidelines Section,
Standards and Implementation Branch, Control Programs Development Division
of the Office of Air Quality Planning and Standards.
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Chapter II
SAN DIEGO TRIAL AIR QUALITY MAINTENANCE PLAN
I. Characterization of the San Diego Air Quality Maintenance Study Area
The San Diego Intrastate AQCR, also known as the San Diego Air Basin, is
located in the southwest corner of the State of California and consists of the
western two-thirds of San Diego County. It is bounded on the east by the summit
of the peninsular range, on the north by Orange County, on the south and west
by Mexico and the Pacific Ocean, respectively. The airshed has a land area of
approximately 3040 square miles and, as of 1970, a population of some 1.36
million people and 790,000 motor vehicles. The population is concentrated
primarily in the City of San Diego and the incorporated areas along the coast.
Analysis of air quality and air quality trends indicates that the San Diego
Intrastate AQCR will have attainment/maintenance problems with regard to
meeting National Ambient Air Quality Standards (NAAQS) with regard to CO,
particulate matter (TSP), and photochemical oxidants (0 ) during the period
X
1975-1985. Peak measurements of 0.32 ppm for oxidant (hourly average), 19
3
ppm for CO (8-hour average), and 97 yg/m for particulates (annual geometric
mean) in 1972 indicate that emission reductions of 75% for reactive hydro-
carbons, 53% for carbon monoxide, and 55% for particulate matter will be
required in order to meet the national standards for air quality. Oxides of
nitrogen and sulfur dioxide are not a problem at present, nor are they
projected to become a problem through 1985.
Air pollution control in the region is primarily the responsibility
of the San Diego County APCD. Since the airshed is contained within one
county, no additional regional coordinating council is required for emissions
control, as in some of the other multi-county airsheds within the state.
Overall, the data bases in San Diego are quite good. More often than
not, the problem is not the lack of available data but attempting to reconcile
the differences between several different data sets. Frequently, this
problem is as sensitive to the political environment as it is to technical
judgements.
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II. Intergovernmental Cooperation
The agencies that would be involved in the development and imple-
mentation of an air quality maintenance plan are listed below:
State of California Air Resources Board(ARB)
San Diego County Air Pollution Control District (APCD)
Comprehensive Planning Organization of the San Diego Region (CPO)
Local Planning Agencies *
County Office of Environmental Management
City of San Diego Dept. of Environmental Quality
City of San Diego Planning Commission
City of Carlsbad Planning Commission
City of Chula Vista Planning Commission
City of Coronado Planning Commission
City of Del Mar Planning Commission
City of El Cajon Planning Commission
City of Escondido Planning Commission
City of Imperial Beach Planning Commission
City of La Mesa Planning Commission
City of Vista Planning Commission
City of National City Planning Commission
City of Oceanside Planning Commission
City of San Marcos Planning Commission
City of Vista Planning Commission
Regional Special Purpose Agencies:
San Diego Port Authority
Regional Water Quality Control Board
Regional Coastline Development Commission
California Department of Transportation (CalTrans)
Air Pollution control responsibility is divided between the State ARB
and the County APCD. The APCD has permit review authority for stationary
sources of air pollution, while the State ARB has taken on the responsibility
for mobile source control.
Land-use and transportation planning activities are centered in the
CPO, which includes housing and open space elements. CPO has the A-95
review authority for federal grants, is the HUD 701 planning agency,
and also is the 3C transportation planning agency under Section 109 (J)
of the Federal Highway Act of 1972. The CPO's Transportation Board must
prepare its' transportation plans such that they are consistent with the
State air quality implementation plan. This requirement was not appropriately
addressed in initial transportation plans that were rejected by the ARB.
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CalTrans has subsequently made a substantial commitment to include air
quality considerations in future planning efforts. Water quality planning
is the function of the Regional Water Quality Control Board, while con-
ventional zoning, subdivision regulations, building code and housing code
variances are administered by the local planning commissions for each of
the incorporated cities and the county.
The approach to be taken in developing and implementing air quality
maintenance procedures into San Diego's land-use decision-making process
must meet two constraints mandated by the Clean Air Act. First, the
approach should provide for a comprehensive review of any future growth
and development significantly affecting AQMSA air quality. Second, the
State of California Air Resources Board is charged with the responsibility
for complying with the Clean Air Act, although the ARB can delegate some
of this responsibility to local APCDs if it so chooses. In cases where
the state has failed to take appropriate action, the Clean Air Act requires
that the federal government must intervene.
Except in cases where a region's resources are shared by and vital
to the public sector of a larger community, it would be presumption for
either the state or the federal government to attempt to externally im-
pose land-use controls on a given AQMSA. "Outsiders" cannot be expected
to make the trade-offs necessary to the formulation of an AQMP tailored
to the unique needs and goals of the populace within a specific region.
Thus, it is appropriate that regional and local agencies assume the respon-
sibility for development and implementation of the air quality maintenance
plan for San Diego. In order to deal effectively with a regional problem
like air pollution, such an agency must have a regional perspective on
the problem and the expertise necessary to deal with it.
Unfortunately in San Diego, no single agency has the expertise
required for both the air pollution control and land use planning
functions. These skills reside with the Comprehensive Planning
Organization (CPO) and the County Air Pollution Control District
(APCD). Thus, two basic alternatives are identified as possible
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institutional arrangements for incorporating air quality management
into the San Diego land-use decision-making process. It should be
noted that regardless of which institutional arrangement is eventu-
ally selected, the lead agency must rely,heavily on the other agencies
in the region in order for the maintenance plan to be truly effective.
A. Alternative "A"--AQMP Process Carried Out by CPO
This alternative would require the ARB to recognize CPO as the
lead local agency in charge of developing an AQMP. The AQMP would
become part of the regional comprehensive plan. The APCD would lend
technical assistance in plan development; however, CPO would assume
the stronger position in developing the AQMP through their role in land
use and transportation planning on matters of a regional significance
(see figure II-l).
Alternative "A" should provide some regulatory power to CPO for
enforcing elements of the general plan pertaining to regional air
quality so that their plan is no longer viewed as being purely advisory.
The intent would be to develop a combined land use/transportation
plan that contains the balance necessary for minimizing VMT while
also presenting a more unified and consolidated approach for state,
regional and local government coordination. Most land use decisions
would continue to be made by the local, general purpose governments;
however, CPO should be in a position to exercise limited veto authority
and to review all transportation projects and new developments of
regional significance by being vested with review of indirect sources,
parking management and parking facility planning, in addition to its
A-95 review power.
Representatives from federal military installations in the San Diego
region and the Environmental Protection Agency might assume a regular
ex-officio role on the CPO board so that their respective activities
could be made known further in advance.
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B. Alternative "B"--AQMP Process Carried Out by the APCD
Under this alternative the County APCD would be responsible for
preparation of and insuring local compliance with the San Diego AQMP.
Since the CPO Board of Directors consists essentially of representatives
from each of the incorporated cities within the county as well as the
county itself, it seems appropriate that CPO should fulfill the role of
coordinator of the planning of the land-use control element of the AQMP.
Thus, under this institutional arrangement the APCD avoids entering
directly into the land use planning arena while still retaining the
local responsibility for compliance with the mandate of the Clean
Air Act (see figure II-.2). CPO retains its role of planning coordi-
nator as well as its other responsibilities with regard to parking
management plans and A-95 review.
C. Discussion
The essential difference between the two organization schemes
presented lies in the delegation of the indirect source review responsi-
bility. Clearly, the agency that has this responsibility holds the key
to enforcement of a long-term air quality maintenance plan. On that
basis, the same agency should also logically have the lead responsibility
for the preparation of the AQMP.
In order for Alternative A to become a reality, CPO must be granted
the power of indirect source review, either by its member governments
through a joint exercise of power agreement, or by EPA or the State
Air Resources Board under the authority and responsibility mandated in
the Clean Air Act.*
Alternative B currently suffers from uncertainties in the legal
interpretation of the nature of indirect sources. The Attorney General
of the State of California has written an opinion that states that local
air pollution control districts currently have the authority to implement
*40 CFR 52.22 (b) and Appendix A, thereto.
10
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Fiqure 1 1-2. Alternative B - AQMP
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-------
indirect source review. Conversely, a recent court decision (State Court
of Appeals, Western Oil and Gas Association vs. Orange County Air Pol-
lution Control District) reaffirmed the jurisdiction of the State Air
Resources Board over motor vehicle emission control and in so doing
raised the question of whether indirect source review should be considered
stationary or mobile source control.
The uncertainty appears to center on the interpretation of the
nature of the powers of the APCDs. If it is interpreted that the
APCDs have only those power specifically designated in the State Health
and Safety Code, then serious questions are raised as to the validity
of the Attorney General's opinion. Conversely, if it is interpreted
that the APCDs have authority over all realms of air pollution control
except those specifically pre-empted by higher authority, then it is
likely that the Attorney General's opinion would hold. The court ruled
that the APCD could not regulate the fuel composition for automobiles
since this constituted a control over automobile emissions that should
properly be the jurisdiction of the State Air Resources Board. The
problem is that this decision may be considered to apply to indirect
source review by analogy. It is conceivable that indirect source review
may be considered regulation of automobile emissions, since it is
precisely auto emissions that such review procedures are designed to
minimize. The situation is further complicated by the fact that indirect
source review may also be considered a form of land-use control--an area
that has always been the domain of local government.
If it is resolved that the APCDs do not currently have authority to
implement indirect source review, responsibility for the delegation
of that authority would revert back to the State Air Resources Board
or, if the ARB does not act, to EPA, under the mandate of the Clean
Air Act.
On the other hand, it seems proper that indirect sources should
be classified as stationary sources and the Attorney General's office
has asked for a clarification of the ruling with regard to this point.
12
-------
Assuming that the court rules in favor of APCDs on this point,
there remains but one potential drawback to Alternative B. The problem
is that the County Board of Supervisors must fulfill a dual role--
one role as administrators of the unincorporated areas of the county,
and another as reviewers of the activities of the Air Pollution Control
District, which has county-wide jurisdiction. Such a dual role could
potentially lead to a conflict of interest on such development projects
as the construction of county roads. This is not an insurmountable
problem, although it is one that must be recognized and dealt with
openly. It is not likely that the Board of Supervisors would attempt
to usurp the authority of either the Air Pollution Control Officer or
the Air Pollution Control Board. However, if such an unwritten rela-
tionship is unacceptable, the State Air Resources Board could serve
as official review agency for county-sponsored indirect sources in
order to prevent potential conflicts of interest.
A third option exists apart from the two alternatives just described.
Under this option CPO and the APCD would share the indirect source
review authority through the formation of a joint governing body.
This option is attractive from the standpoint that it ensures a high
degree of participation on the part of both CPO and APCD to ensure
that there was a responsible entity for each portion of the plan pre-
paration and of the plan enforcement.
D. Problems
• The present government structure for land-use decision-making
is fragmented, and not oriented toward addressing regional problems
such as air pollution.
An important prerequisite to the development of an air quality
maintenance plan is the construction of an appropriate scheme for
integrating the multiple jurisdictions for air pollution, transportation,
and land-use decision-making. In areas where mobile source pollution
problems predominate, the designation of indirect source review authority
is the key decision that must be made.
13
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III. Baseline Emissions Inventory
A. Baseyear Selection
The baseline year for all pollutants was 1972 since the latest complete
inventory could be obtained for that year, and because the latest
complete air quality data were for that year. In addition the air quality
data for 1972 were comparable to the data obtained for the four previous
years.
B. Emission Data Sources
There were two emission data sources in San Diego: the Air Pollution
Control District provided data concerning both point and area source
emissions for all pollutants, while the local office of the California
Department of Transportation provided data concerning present and projected
vehicle miles traveled (VMT).
C. Geographic Location of Sources
The coordinate system utilized in San Diego was the California
State Plan coordinate system. This system was used instead of the UTM
(Universal Transverse Mercator) system because the software used for the
emissions gridding procedure was based on the use of a State-Plane grid.
The NEDS data coded for input to this software package were coded in both
UTM and State Plane coordinates in order to satisfy EPA requirements,
and the input requirements of the software.
D. Technical Assumptions
The bulk of the technical assumptions used in determining emission
factors, emission source control efficiency, and the reactive fraction
of total hydrocarbon emissions was obtained from a meeting between
EPA, State Air Resources Board, and local agency representatives. The
specific purpose of the meeting was to develop a single set .of assumptions
to be used in subsequent transportation control planning efforts. Assumptions
used are summarized in Table II-l. Where agreement could not be reached,
EPA-sanctioned assumptions were used. In addition a 90% reduction in
reactive hydrocarbon emissions from gasoline marketing operations as
prescribed by recent County APCD regulations was assumed.
14
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E. Problems
There remains a controversy concerning the most proper set of
emission factors, and the fraction of those emissions that should be
considered reactive for several source categories including autos, air-
craft, diesels, and wild fires.
In San Diego, the meeting between representatives of EPA, the State
Air Resources Board, the APCD, and other local agencies was quite
valuable and necessary to the successful implementation of a meaningful
control program. Ultimately, it is the effective implementation of the
control measure that determines the success of a control program, rather
than bickering over the proper set of technical assumptions to be used
for planning purposes. Such effective implementation can only come
through cooperative attitudes on the part of everyone involved. The
technical assumptions meeting was a big step toward this ultimate goal.
• The discovery of previously neglected sources can drastically
alter control requirements for both attainment and maintenance.
In San Diego, reactive hydrocarbon emissions due to wild fires and
certain uncontrolled engines (lawnmowers, chain saws, dunebuggies, compe-
tition vehicles, etc.) were not accounted for in the promulgated transpor-
tation control plan. A recent study by Automotive Environmental Systems, Inc.
for the State ARB was used to estimate both baseline and projected emissions.
Since these sources are expected to remain uncontrolled, the resulting effect
is to increase control requirements for other components of the emission
inventory. Further, by 1985, the full impact of the federal motor vehicle
control program for new automobiles will be felt. Therefore any further
reductions in emissions must come from either VMT reductions or from
other source categories such as heavy duty vehicles, motorcycles, and
aircraft.
15
-------
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16
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IV. Emission Projections
A. General Methodology
Emissions for all pollutants were projected according to
projected changes in either employment or population. Industrial
emissions were projected from the baseyear inventory by assuming that
changes in emissions were proportional to changes in employment. Employ-
ment projections for 22 broad industrial categories (essentially corre-
sponding to a two-digit SIC code level of disaggregation) made by the
Comprehensive Planning Organization to the year 1995, with an intermediate
*
projection to 1985 were used. In the special case of power plant
emissions, projections of emissions from power plants in the AQMA were
obtained indirectly from the local electric power utility, San Diego
Gas and Electric Company. (The APCD obtained the information and
forwarded it to us after we made an unsuccessful attempt to obtain the
data ourselves.) Residential and commercial fuel combustion emissions
were projected on the basis of CPO population projections, since natural
gas demand in these categories is expected to be satisfied by SDG&E,
with no switch to fuel oil or other fuel anticipated.
Although air quality considerations were not adequately addressed
in the regional transportation plan as required under Section 109 (J) of
the Federal Highway Act of 1972, the VMT projected under this plan (which
is integrated with the regional comprehensive plan) was utilized for the
purpose of projecting motor vehicle emissions for the San Diego region.
The APCD had attempted to estimate motor vehicle VMT on the basis of
registration data for various vehicle types and assumptions concerning
average annual mileage per vehicle. The percentage split of the total
VMT between the various vehicle types under this methodology was combined
*
The federal OBERS projections for industrial activity in standard
metropolitan statistical areas were rejected since they were based on
outdated population projections.
17
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with the total VMT projections of CPO to provide estimates of light and
heavy duty vehicle VMT as well as diesel and motorcycle VMT. These VMT
estimates were then combined with the appropriate emission factors to
obtain emission estimates. In the case of LDV emissions, emission and
deterioration factors developed by the RAND Corporation in a previous study
of the San Diego air quality problem were used. EPA emission and deteriora-
tion factors were used for heavy duty vehicles, diesels, and motorcycles.
B. Problems
• Conflicting projections of population and economic activity were
available for the San Diego area.
The local COG in San Diego (The Comprehensive Planning Organization)
had obviously devoted much more time and effort to their projections
of population and employment than had either the state or the federal
government agencies. The fact that their projection matched well with the
projection performed by the State Department of Finance reinforced the
conclusion that the local projections were the most appropriate set. The
Series C projections of the U.S. Department of Commerce, which form the
basis of the OBERS projection? , were found to diverge significantly from
both the state and local projections.
Air Quality Maintenance Planning requires long term emission
projections that are not commonly made in most emission producing industries.
The approach taken in San Diego of keying the emission projection
for industrial categories to employment projections for the same categories
is admittedly crude, yet when dealing with such long term projections it
is questionable that increased sophistication will yield more definitive
results.
V. Establishment of Baseline Air Quality
A. Baseyear Selection
The baseyear for air quality was 1972, as mentioned previously.
This was due to the fact that 1973 was considered an unusual year
meteorologically, while air quality in 1972 was at least as bad as any
18
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of the previous years in the cases of oxidant and carbon monoxide and
worse than any previous year in the case of particulate matter. Air
quality for 1972 is summarized in Table II-2.
B. Time Compatibility of Baseline Air Quality and Emissions
The baseline air qualtiy and emissions data were for the same
period. Had there been a conflict in the data bases, the most appro-
priate course of action would have been to adjust the emission inven-
tory either forward, following the projection methodology outlined,
or backward according to historical trends.
C. Sources of Air Quality Data
Three sources of air quality data were consulted: the EPA SAROAD
data bank of NASN (National Air Sampling Network) station data (one
station in San Diego), the State Air Resources Board quarterly air
quality summaries, and the Air Pollution Control District air quality
data file.
D. Accuracy and Representativeness of data
In the case of oxidants, six stations in the San Diego region
reported oxidant concentrations. Since oxidant is a regional scale
pollutant, the fact that data from all of the stations indicated
that comparable levels of oxidant were being experienced from time
to time at all locations indicated that the monitoring network was
probably adequate for this pollutant. In the case of carbon monox-
ide and particulate matter, only two stations in the region were
equipped to monitor these pollutants. In both cases it is recom-
mended that additional monitoring stations be deployed, however,
since both pollutants are generated such that large variations
(local hot spots) may occur, it is debatable whether any network
could be devised that would be judged adequate (e.g., one properly
should have CO monitors at every busy intersection to adequately
monitor for potential violations of CO air quality standards). In
addition, in the case of particulate matter, the particulate samples
19
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Table II-2. SAN DIEGO COUNTY AIR QUALITY, 1972
Pollutant
Oxidant
Carbon
Monoxide
Suspended
Particulate
Matter
Nitrogen
Dioxide
Sulfur
Dioxide
Current
Level
0.32 ppm
(1-hour maximum)
19 ppm
(8-hour average)
97 yg/m3
(annual geometric
mean)
.04 ppm
(annual average)
.005 ppm
(annual average)
Applicable
Standard
.08 ppm
9 ppm
60 yg/m3
.05 ppm
.03 ppm
Rollback
Required
75%
53%
55% *
0
0
* 3
Assumes an uncontrollable background of 30 yg/m . Emissions of parti-
culate matter must be rolled back to the secondard standard due to the
fact that the originally approved state implementation plan indicated
that the secondard standard for particulate matter would be met in San
Diego.
20
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should be subjected to chemical analysis in order to identify the sources
and hence air in the specification of the appropriate control strategy.
E. Estimation of Air Quality.from Monitoring Data
For particulate matter and carbon monoxide, the peak concentrations
measured were taken to indicate air quality with regard to those pol-
lutants. In the case of oxidant, a Larsen analysis* of the air quality
data was facilitated by the availability of cumulative frequency summaries
of the hourly data. In addition, since there had been much controversy
in previous studies of the San Diego air pollution problem concerning the
validity of the peak concentrations used, it was felt that a Larsen analysis
to determine statistically the expected maximum concentration would
serve to establish the baseline air quality on a firmer footing.
F. Problems
• Monitoring data for particulate matter were sufficient for indi-
cating that a problem existed, but insufficient to define the extent
of the problem and the relative contribution of each source type to the
high concentrations measured.
Two recommendations were made in San Diego: first, to increase the
number of "hi-vol" sampling stations, and second to begin performing
chemical analyses of the particulate samples collected. In the mean-
time, plume computations under worst case assumptions were utilized to
identify potential source contributions to the high levels measured.
The point source emission inventory of particulate matter emissions was
displayed on a grid. A cursory examination of the gridded inventory
indicated that the most likely contributor to high particulate measure-
ments in El Cajon was the rather extensive mineral extraction activity
in the Mission Valley area, generally upwind from the El Cajon monitoring
site. A simple Gaussian plane model was applied, assuming that the plume
centerline passed directly over the El Cajon site at an annual average
windspeed of 2 m/sec and "D" class stability. The resulting computed
concentration was compared with a similar computation for line source
emissions from a nearby freeway, also generally upwind from the El Cajon
site, although much closer than any significant point source emissions.
*
Larsen, R.I. A Mathematical Model for Relating Air Quality Measurements
to Air Quality Standards. U.S. EPA AP-89. November 1971.
21
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These computations indicated that motor vehicles are most likely the
major source of particulates of the El Cajon sites. Thus, a likely
candidate for control was identified, while still reserving final
judgment until more definitive data could be obtained. Motor vehicles
were suspected of contributing significantly to particle concentrations
at El Cajon because of the proximity of the freeway and relatively high
concentrations of lead in the collected particles.
VI. Air Quality Projections to 1985
A. General Methodology
Projections of oxidant and carbon monoxide air quality were handled
through proportional relationships to emissions. More sophisticated
modeling techniques were rejected from consideration due to the complexity
of the San Diego meteorology and topography.
Since particulate matter is a potentially localized problem, a
proportional rollback of regional emissions of particulate matter
was not advocated. Instead, simple Gaussian plume computations were
made to identify the most likely sources of the high particulate loadings,
with the recommendation that chemical analysis of the particulate
samples be used to confirm or deny the results of the plume computations.
B. Problems
• A fundamental weakness of emission allocation procedures is
the inadequate state-of-the-art for relating a given emission pattern
to the resulting air quality.
The state-of-the-art of oxidant modeling is sophisticated on the
scale of smog chamber experiments, yet is inadequate for atmospheric
work since detailed data on the reactants, their relative concentra-
tions and the reaction time constraints are not available. The situa-
tion is not much better in the case of particulate matter due to the
complicated topography and land/sea breeze circulation pattern in
San Diego.
The ultimate goal of emission allocation procedures is to help to
channel growth and development into areas in which increased emissions will
impact the regional air pollution picture the least. Thus, this goal is
22
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frustrated by the modeling for addressing this problem in complicated
meteorological domains.
VII. Selection of Maintenance Strategies
An air quality maintenance plan may be .visualized to consist of a
technological control element and a land use and transportation control
element. As a region grows in population, per capita consumption, and
hence emissions, technological controls must become increasingly stringent
in order for the region to accommodate the growth and yet maintain air
quality. The converse may also be considered to hold—if technological
controls cannot alone serve to maintain air quality, land use controls
must bear an increasing portion of the burden as growth progresses. Thus
we see that a very delicate balance must be maintained between the
two control elements and that this balance will become increasingly
difficult to maintain as time passes.
Prior to developing potential maintenance strategies for considera-
tion, five previously completed studies of the air pollution problems
of the San Diego area were examined. Each of these was concerned with
the photochemical oxidant problem. These studies are:
• Rand Corporation study of attainment strategies for photochemical
oxidants
• California Air Resources Board Implementation Plan for the San
Diego Air Quality Control Region
EPA technical support document for the attainment of the oxidant
air quality standard by 1977
• California Air Resources Board study for the designation of air
quality maintenance areas within the state
• Local task force study of attainment strategies for San Diego
None of these studies included in their inventories emissions from
uncontrolled engines (except motorcycles in the Rand and EPA studies).
Failure to include sources over which no control is anticipated increases
the burden of control placed on the remaining sources.
The Rand study, using a 1970 base year, proposed a strategy believed
to provide for attainment of hydrocarbon (oxidant) and carbon monoxide
23
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standards by 1975 and maintenance of standards through 1995. The strategy
proposed comprised strict control of organic solvents; motor vehicle
inspection/maintenance program; retrofit of all 1955-74 light duty motor
vehicles with catalytic exhaust systems; stringent modification of aircraft
ground operations procedures; retrofit of all 1955-1969 light duty motor
vehicles with additional evaporation controls; and a VMT reduction through
a mileage surcharge.
The State of California ARB study for the implementation plan also
was based on a 1970 emissions inventory and proposed measures including
95% reduction of aircraft and ship emissions; retrofit of 1966-74 light
duty and 1962-74 heavy duty vehicles with catalytic exhaust systems;
inspection/maintenance program for light duty vehicles; gasoline marketing
controls; and reduction of vehicle miles travelled.
The plan promulgated by EPA for the attainment of oxidant standards
by 1977 included control of substitution of reactive solvents; control of
gasoline evaporative emissions in marketing operations; inspection/
maintenance of light duty vehicles; retrofit of 1966-70 light duty vehicles
with the California vacuum spark advance disconnect; anticipated federal
aircraft and motorcycle emission controls; and 11% reduction in light duty
vehicle miles travelled; and other reductions in vehicle miles travelled, as
necessary. This last measure indicates awareness of the uncertainty of
attaining oxidant standards through the more definitive measures proposed.
The Local Agency Task Force Plan was proposed by an ad hoc committee
as an alternative to the EPA transportation control plan. The study by this
committee called for a 10% reduction in vehicle miles travelled to be
accomplished by improving the road system; improving bus service; instituting
a 4-day work week; and discouraging auto use through a combination of
tax incentives and disincentives. The study assumed federal control of
aircraft and ships.
In their study for the designation of maintenance areas, the California
ARB proposed no measures for control of emissions. There appears to be
some inconsistency in their selection of projection factors for various
categories of emission sources; the emissions projected for future years
are considerably higher than those used for this trial plan.
24
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It was felt, from the inception of this study, that the selection of
land use control measures was best accomplished by local planners and
decision makers. Furthermore, it was felt that any measures selected for
purposes of an AQMP could only be implemented if they had the support and
endorsement of local institutions and governmental agencies. This section
presents a discussion of local inputs concerning which land use control
measures appear attractive and effective for use in the San Diego region.
It is clearly recognized that the reduction of air pollutant emissions can be
accomplished by means other than land use and transportation control measures.
Crucial elements of the AQMP, for example, are maintaining vigorous controls
on stationary point sources and successfully implementing and enforcing an
aggressive transportation control plan to reduce vehicular emissions.
Implicitly, the assumption of presently available technological controls
has been made. Although this assumption has been made, it is certainly
felt to be unrealistic and an optimistic estimate of control measure
effectiveness. The rationale for such an assumption is more from satis-
fying the legal requirements of developing a demonstrably effective AQMP
than from any technical considerations. From a technical perspective, it
is difficult to foresee remaining static in the availability of additional
hardware, process modification, product changes, etc.-, that will reduce
industrial emissions, especially given more stringent control requirements.
Indeed, if past experience in pollution control is any indicator, it may
be that the tighter emission limits will provide the necessary impetus
to advance the state-of-the-art-control techniques.
The Delphi Panel
There are a number of ways to solicit local inputs into a planning
process. Traditionally, the most frequently used mechanisms are to con-
duct surveys of one kind or another, hold seminars, symposia, and con-
ferences, or to conduct public hearings. Depending on the planning
objectives, various combinations of the above procedures are also used.
As mentioned, it was decided local inputs—city, county, regional, and
25
-------
state—were essential to the selection of any land use control measures
to be incorporated into the AQMP. The vehicle used in this study to
solicit such inputs was the Delphi technique—a structured and controlled
questionnaire with feedback.
A good description of Delphi is given by Dal key: „
"In general, the Delphi procedures have three features: 1)
anonymity, 2) controlled feedback, and 3) statistical group
response. Anonymity effected by the use of questionnaires
... is a way of reducing the effect of dominant individuals.
Controlled feedback—conducting the exercise in a sequency
of rounds between which a summary of the results of the pre-
vious round is communicated to the participants--is a
device for reducing noise. Use of statistical definition of
the group response is a way of reducing group pressure for
conformity; at the end of the exercise there may still be a
significant spread of individual opinions. Probably more
important, the statistical group response is a device to
assure that the opinion of every member of the group is repre-
sented in the final response."
In addition to and preceding the Delphi questionnaire, a series of
interviews was conducted locally and over the telephone to gather both
base data and agency attitudes concerning land use control alternatives
for air pollution control. In part, these interviews set the stage for
conducting the Delphi questionnaire.
There were several reasons for selecting this procedure for gauging
local attitudes towards development of an AQMP. It became quite apparent
that air quality was a critical issue in San Diego and that most agencies
(as well as individuals) were strongly opinionated concerning the ultimate
solution to the problem. In this sense, then, achieving and maintaining
clean air was a controversial issue locally. Because of this, it was
felt desirable to avoid any direct agency confrontations. On the other
hand, it was also felt broad representation from all sectors of the commu-
nity was needed to add credibility to the planning process. Explicit attempts
were made to insure representation from the public and private sectors,
*
Dalkey, N.C., "The Delphi Method: An Experimental Study for Group
Opinion," The RAND Corporation, RM-5888-PR, April 1969.
26
-------
city, county, regional, and state agencies, business community and citizens'
groups. As a means of accomplishing both objectives as well as incorporating
local inputs within the time frame allowed by the study, a one-day (after-
noon session) Delphi questionnaire session was planned.
It should be emphasized that the results of the questionnaire are
intended only to serve as an indicator of local thinking on potential
control measures to be implemented. While the overall administration of
the questionnaire was accomplished with no major difficulties, a number of
points need to be raised concerning the limitations involved in interpreting
the results. While every attempt was made to seek "balanced" representation
within the group, it is virtually impossible to avoid individual complaints
that the group was "stacked" with planners or governmental officials or
some other group. Specifically, during the San Diego session, a number of
incidents occurred that may have influenced the final results.
• As expected, not all of the individuals who had agreed to attend
did in fact participate. Consequently, the "balance" originally sought
never materialized.
• A number of "experts" scheduled to participate sent representatives
in their stead. Since this Delphi was structured to solicit "expert"
opinion, it is difficult to gauge whether or not the level of expertise
originally solicited was as good, better, or worse than the final
group of particicants.
• Concurrent to the Delphi, two other important meetings were
"A"
being conducted in San Diego , which accounted for a portion of the
absenteeism cited above. Since these meetings were scheduled after our
meeting had been set up, it was essentially impossible to reschedule.
Of significance was the fact that a number of respondents who started
the Delphi session were unable to complete it due to other commitments.
Thus, the mixture of the group as a whole experienced some change during
the afternoon.
*
The other meetings taking place concurrently were a County Board of
Supervisors meeting to discuss indirect source review requirements of
EPA, and a CPO monthly board meeting.
27
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Despite the above mentioned nuances, sufficient consensus was reached
by the group on a number of issues that it was generally felt the exercise
was very useful. The group initially assembled numbered twenty, with
fourteen representatives completing the full seven rounds of interrogation.
Organizationally, the structure of the survey was aimed at addressing
three issues with regard to land use control measures:
• Overall attractiveness—From a shopping list of measures, the
participants were asked to select the measures viewed to be "most
attractive" in terms of implementability, effectiveness, minimum adverse
socioeconomic impacts and public acceptance. This phase of the exercise
was completed first, since it was felt regardless of how effective a
particular measure might be, if it was not implementable and acceptable,
it would never receive serious planning consideration.
Implementation obstacles—Once it was determined which control
measures were viewed as the most attractive, an assessment of the most
critical implementation obstacles was solicited. The respondents were
asked to consider the relative importance of six potential implementation
obstacles—lack of funding, existing governmental structure, lack of enabling
legislation, inadequate state-of-the-art technology, public acceptance,
and a lack of precedences or a hesitance to be innovative.
• Effectiveness—A number of specific and general objectives were
cited and the respondents were asked to assess (by rank ordering) the
relative effectiveness of the control measures for achieving the various
objectives. Since the objectives dealt with the need for auto travel and
growth and development issues, inferences can be drawn regarding the air
quality implications of these measures.
Table II-3 presents a summary of the chronological sequencing of
issues addressed by the questionnaire. In addition to the actual survey
form, a supplemental set of miscellaneous "fact sheets" was provided to
each participant. This handout contained descriptive information on
what each of the control measures was and a summary of the air pol-
28
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lution situation, i.e., recent emission inventory and air quality data.
The intent of the handout was merely to provide backup information to
the respondents to assist them in their decisions.
The measures put before the Delphi Panel for consideration are
listed below:
Environmental Impact Statement as required by California Environment
Quality Act (CEQA)
Recreation Land Regulation*
Taxation Policy to Preserve Non-Developed Areas*
SB 1543 (or Similar Regional Development Plans)*
A-95 Review Process
Direct Source Review ^
Emission Density Zoning
Open Space Planning
Regional Water Quality Control Board (Permit Review)
"3-C" Review Process
San Diego Coast Regional Commission (General Plan)
Capital Facility Ordinances
General Plan
Zoning Ordinances (Existing)
Planned Unit Development Ordinance
Capital Improvements Programming
Indirect Source Review
Protection of Critical Environmental Areas
Development Timing Controls
The set of measures selected by the panel as the most attractive are
as follows:
Environmental Impact Statement (CEQA)
Capital Facility Ordinances
Direct Source Review
General Plan
Taxation Policy to Preserve Non-Developed Areas*
SB 1543 (or Similar Regional Development Plans)*
Capital Improvements Programming
Indirect Source Review*
Development Timing Controls
*
Potential Control Measures Not Currently in Use
29
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As mentioned previously, an air quality maintenance plan consists of
two distinct yet interacting elements—a land use control element and
a technological control element. The Delphi panel served to identify the
most promising measures for the land use control element. A cursory examina-
tion of the projected emission inventory for San Diego in 1985 reveals that
the most significant sources of reactive hydrocarbon emissions are ntotor-
cycles, heavy-duty vehicles, aircraft, and light-duty vehicles. Since light-
duty vehicles will be stringently controlled by that time, equity, as
well as the technological limitations of deriving further reductions
from source categories already under stringent control, argue in favor
of attacking those sources that have not previously been subject to
comparable control programs.
Therefore, the recommended maintenance strategy is summarized below:
Recommended Maintenance Strategy
Technological Control Element Land Use Control Element
• 90% reduction in heavy duty • Emission allocation procedure
vehicle emissions (SB 1543 or equivalent)
• 90% reduction in motorcycle • Direct and indirect source
emissions review as well as EIS review
(CEQA)
• 90% reduction in aircraft • Capital facility ordinances and
emissions development timing controls
• Taxation policy to preserve
undeveloped areas
The land use control element must be implemented in a fashion that
ensures that the Regional Comprehensive Plan policies (Table II-4) are
observed over the next 10 to 20 years. Simultaneously, control programs
must be designed to produce the emission reductions outlined. Should there
be a failure in the technological control element to obtain the reductions
needed, the burden of control will be shifted to the land use control element.
The implication is clear: land use controls would then have to be enforced
to limit growth in San Diego in order to maintain air quality.
31
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Table 11-4. REGIONAL COMPREHENSIVE PLAN POLICIES
AND TRANSPORTATION PLANNING GUIDES
I The Regional Comprehensive Plan and local plans and programs should
be directed specifically toward development and enhancement of
existing urban communities and the maintenance and enhancement of
rural communities within the region.
II New employment opportunities should be located in employment centers
developed as an integral part of both existing communities and
newly developing suburban communities. The size and number of the
employment centers would depend on the size and character of the
community within which they are located; the types of employment
in each community employment center should be consistent with the
availability and price range of housing in the surrounding community.
Ill Those activities that require Regional market or service areas
should concentrate in employment and service centers. These
centers should be located at the focal points of the Regional
Transportation System.
IV Local jurisdiction should use the location of regional transit
facilities as a focal point for local development plans for
activities providing employment opportunities and for higher
density residential development.
Transportation Planning Guides
• to emphasize consistency and coordination of overall regional
growth and development policies with regional and local
transit services
• to recognize the importance of multi-modal systems to serve
the different travel requirements of the population
• to recommend a transportation plan that will minimize the region's
energy requirements and maximize improvements in the air quality
• to provide transit services to low-mobility population segments,
e.g., the elderly, the young
• to maximize opportunities for pedestrian and local feeder access
to regional transit terminals and stations
• to make maximum advantage of the most advanced and proven
automation equipment available
• to recommend that the regional transit system be an intermediate
capacity, fixed guideway, transit network that operates on
exclusive right-of-way, e.g., light rail, advanced technology transit
• to recommend an express bus network that provides high levels of
transit services in medium level demand travel corridors.
32
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VIII. Legal Authority
Existing legal authority for the implementation of the control
measures is summarized in the table below:
Summary of Legal Authority
Measure
Heavy duty vehicle control
Motorcycle control
Aircraft control
Emission Allocation
Direct source review
Indirect source review
Implementation Agency Authority
Environmental Impact Statement
Review
Capital facility ordinances
Development Timing Controls
Taxation policy to preserve
undeveloped areas
EPA
ARB
EPA
ARB
EPA
local agency
EPA
ARB
APCD
EPA
ARB
local agency
ARB
regional special
purpose agencies
local agencies
local agencies
local agencies
Clean Air Act , ,
Mulford-Carroll Act-7
Clean Air Act
Mulford-Carroll Act
Clean Air Act
to be acquired
Clean Air Act
Mulford-Carroll Act
State Health & Safety Code
Clean Air Act
Clean Air Act
delegated from EPA or ARB,
pending legal clarification
of present law
California
Quality Act£-
Various
nvironmental
Zoning & building permit
authority
to be acquired
Williamson Land
Conservation Act!/
-A 1967 act that created the California Air Resources Board provides for
retention at the state level, or delegation to Air Pollution Control
Districts, of enforcement of controls.
o /
— Enacted in 1970 and enhanced through subsequent California Supreme Court rulings,
this act established procedural requirements for environmental impact reporting.
3/
— A 1965 act designed to alleviate pressure for conversion of agricultural
land and to preserve open space by preferential tax assessment based on the pro-
ductive value of the land. Initiative for holding land for open space lies with the
land owner. State pays a subvention to local government for a portion of foregone
taxes. 33
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Legal authority currently exists in one form or another for the
implementation of each of the measures outlined, with the exception of the
emission allocation procedure and the development timing controls. A
bill (SB 1543) to provide the authority for emission allocation is currently
before the State Senate, and it is conceivable that development timing
control could be implemented through the building permit authority of
local agencies.
34
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SUMMARY OF SAN DIEGO AQMSA
POLLUTANT: TSP
NAAQ STANDARD: 60 ugm/m3
CURRENT AIR QUALITY, 1972: 97 yg/m3
EXPECTED AIR QUALITY IN 1975: 100 yug/m3
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD BY 1975: 55% (assuming an
uncontrolable background of 30 Ajg/rn3)
PROPOSED ATTAIIiMENT/KAItrTENAIlCE MEASURES AND DATE THEY MUST BE IN EFFECT:
Removal of sulfur from gasoline (eliminating sulfuric acid aerosol)
should be in effect by 1977.
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
Coordination between EPA, ARB and APCD.
35
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SUMMARY OF SAN DIEGO AQMSA
POLLUTANT: CO
NAAQ STANDARD: 9 ppm (8-hr, average)
CURRENT AIR QUALITY, 1972: 19 ppm (8-hr, average)
EXPECTED AIR QUALITY IN 1977: 9 ppm (8-hr, average)
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD BY 1977: 53%
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
The promulgated EPA transportation control plan must be in effect
by 1977:
o inspection/maintenance program
• Vacuum spark-advance disconnect (VSAD) retrofit for 1966-70 model year LDV
• oxidizing catalyst retrofit for 1966-74 model year LDV
• federal motor vehicle control program for new cars must proceed
on schedule
• 11% VMT reduction due to exclusive bus/carpool lanes, carpool
matching programs, and parking management plans
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
Coordination of overall program implementation between EPA, the
State Air Resources Board and Department of Transportation, the San Diego
County Air Pollution Control District, and the Comprehensive Planning
Organization of the San Diego region. The State ARB must implement the
inspection/maintenance program, the VSAD retrofit program, and the
oxidizing catalyst retrofit program. EPA must ensure that the timetable
for "clean" cars does not slip again. Finally, the California Department
of Transportation (CalTrans) and the Comprehensive Planning Organization
must plan and implement the exclusive bus/carpool lane program and the
parking management program, respectively.
36
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SUMMARY OF SAN DIEGO AQMSA
POLLUTANT: SOV
A
NAAQ STANDARD: 365 yg/m3 (24-hr, average)
CURRENT AIR QUALITY, 1972: 75 pg/mj (24-hr, average)
EXPECTED AIR QUALITY IN 1975: 114 yg/m3 (24-hr, average)
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD BY 1975: none required
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE
IN EFFECT: NONE
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED: NONE
37
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SUMMARY OF SAN DIEGO AQMSA
POLLUTANT:
O
NAAQ STANDARD: 60 yg/m (annual arithmetic mean)
CURRENT AIR QUALITY (GIVE YEAR): 50 yg/m3 (annual arithmetic mean)
EXPECTED AIR QUALITY IN 1975: 40 yg/m3 (annual arithmetic mean)
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD BY 1975: none
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
Maintenance will be assured by the federal motor vehicle control program.
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
None
-------
SUMMARY OF SAN DIEGO AQMSA
POLLUTANT: HC/ Photochemical Oxidants
NAAQ STANDARD: .08 ppm HC (1-hr, average)
CURRENT AIR QUALITY, 1972: .32 ppm HC (1-hr, average)
EXPECTED AIR QUALITY IN 1977: -.15 - .20 ppm HC (1-hr, average)
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD BY 1977: 75%
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AMD DATE THEY MUST BE IN EFFECT:
© The promulgated EPA transportation control plan (see the summary
sheet for CO) (1977)
© 90% reduction in motorcycle reactive hydrocarbons (RHC) emissions (1985)
e 90% reduction in heavy-duty vehicle RHC emissions (1985)
© 90% reduction in aircraft (both civilian and military) RHC
emissions (1985)
o Land-use controls to ensure that the Controlled Trends Regional
Comprehensive Plan policies are followed (1975)
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
Three alternative organizational structures have been identified as
having the best potential for planning and implementation of the AQMP. One
alternative has the Comprehensive Planning Organization (the local COG)
taking the lead responsibility, while a second alternative has the County
Air Pollution Control District taking the lead responsibility. A third
alternative would have the CPO and the APCD share the lead role through
the formation of a joint governing body. The key determinant of the
structure to be employed is the delegation of indirect source review
authority.
-------
Chapter III
ST. LOUIS TRIAL AIR QUALITY MAINTENANCE PLAN*
I. AQMSA Description
St. Louis was chosen as an example Air Quality Maintenance Study Area
(AQMSA) because it is an interstate, interregional Air Quality Control Region
(AQCR) with a diversity of pollution sources and problems, and has an
anticipated maintenance problem for particulates (TSP), sulfur oxides (SCO,
carbon monoxide (CO), and photochemical oxidants (0 ).
A
The St. Louis SMSA, which initially is considered to be coincident
with the AQMSA, covers portions of Missouri and Illinois and comprises
seven counties and one independent city (see Figure III-l). The majority
of industrial pollution sources are located along the rivers that separate
the two states. The prevailing winds (northwest in the winter, southwest
in the summer) tend to transport the pollutants across the river boundary,
from Missouri into Illinois.
II. Intergovernmental Cooperation
A. Agencies, Governments, and Groups Contacted in Preparation
of the Example AQMP
The following agencies were contacted during the preparation
of the sample plan.
1. Federal Agencies
EPA, Region VII, Region V
Interagency Work Group on Air Quality Maintenance
2. State Agencies
Missouri Department of Natural Resources
Missouri Air Conservation Commission (MACC)
Missouri Department of Highways
Illinois Environmental Protection Agency (IEPA)
*Tne bulk of the trial plan on which this digest is based was prepared
by a contractor prior to the establishment by EPA of firm guidelines
concerning the reauirements for and acceptability of multi-phase mainte-
nance or attainment/maintenance plans. Further, dates of compliance
suggested in this trial plan are not concurred in by EPA, and do not
comply with the reauirements of 40 CFR 51.
41
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-^v
WOOD RIVER
COMPLEX
MADISON
COUNTY
ST. LOUIS METROPOLITAN AREA
UNITED STATES
Figure III-l. St. Louis Air Quality Maintenance Study Area
42
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3- Reg i onal Agencies
East-West Gateway Coordinating Council
Southwest Illinois Metropolitan Area Planning Commission
Bi-State Development Agency
4. Local Agencies
St. Louis County Air Pollution Control
St. Louis Division of Air Pollution Control (city)
St. Charles County Planning Commission
St. Louis City Planning Commission
Franklin County Planning Commission
St. Louis County Planning Commission
B. Existing Institutional Framework
The Air Quality Maintenance Plan consists of a set of goals, policies,
and actions needed to preserve air quality. To be successful, this AQMP
must be carefully integrated into the plan for the region and reflect
the institutional framework for the area. In order to determine the most
effective framework for intergovernmental cooperation, the existing insti-
tutional framework and coordination mechanisms were reviewed. The issues
and constraints in the evaluation of alternative arrangements were examined,
and a mechanism for coordinating AQMP implementation was selected as
described below.
1. Existing Agency Responsibilities
The Air Quality Maintenance Plan can be considered to have three
elements: source control, land use policies, and transportation policies.
As shown in Figure III-2, the existing responsibility for these various
elements is widely dispersed throughout the various jurisdictions involved,
including the State and Federal government.
In the area of planning for source controls, the States, of course,
have prime responsibility. In the case of land use, the primary respon-
sibility lies with the city or county, while in the transportation field,
it rests with the East-West Gateway Coordinating Council.
In the area of implementation, the primary responsibility for source
control rests with the two states, although in Missouri, because of the
competence available at the City of St. Louis and St. Louis County levels,
43
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the State has assigned this responsibility to the air pollution agencies
in those jurisdictions. In the area of land use, the primary responsibility
for enforcing and controlling development rests with the city or the
county, except the county does not have jurisdiction over incorporated
areas within its boundaries. In the transportation field, the highways are
primarily developed by the State for the major facilities, while minor
facilities are provided by the city or county. In the transit area,
major improvements are primarily developed by the Bi-State Development
Agency, which is an interstate agency created some time ago primarily to
develop a transit system. It operates the existing metropolitan (but
interstate) area bus service.
In connection with the control or enforcement related to these trans-
portation fields, the authority in the highway area rests with the State,
the city, or the county. In the transit area, it primarily rests with the
Bi-State Development Agency, although the East-West Gateway Coordinating
Council is often consulted in connection with policy issues related to
the operation of the system.
2. Existing Coordinating Mechanisms
The primary coordinating mechanism in the St. Louis metropolitan
area is the East-West Gateway Coordinating Council. This Council was
established about 10 years ago, primarily to respond to the highway
requirement to set up a continuing, comprehensive, and cooperative
planning process in the metropolitan area. Another responsibility that has
been delegated to the East-West Gateway Coordinating Council is the so-
called A-95 review. It requires that all Federal projects be reviewed
by appropriate agencies that might be impacted by such projects.
Key political leaders in the metropolitan area are represented on the
Council, and it is because of this representation that this Council can
be influential. It seeks to get things done by review and persuasion.
In an effort to further involve more people in the planning process, the
Council has set up a series of committees, such as the Transportation
Technical Committee, made up of the technical experts from various agencies
and jurisdictions. In addition, there are citizen task forces, including
transportation, solid waste, environment, criminal justice, and education.
45
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In August 1974, the Missouri Air Conservation Commission established
an Advisory Committee on Transportation Control. Figure III-3 shows the
membership of this committee, which is responsible for advising the
Commission on the development of a transportation control plan. It
includes representatives of transportation agencies at the State and
local levels, as well as certain planning and air pollution agencies. It
also includes representatives from industry and from the public sector.
C. Alternative Arrangements for AQMP Development and Implementation
In developing an Air Quality Maintenance Plan, many issues and
constraints related to its development must be resolved before an effective
planning process can get underway. There are questions of who will be
responsible for the technical work, how various elements will be related, and
what roles the citizen and political leaders should play in the develop-
ment of the plan. Alternative approaches to these issues are discussed
in the following sections.
1. Technical Leadership
In the development of an Air Quality Maintenance Plan, the legal
responsibility for the technical phase of the plan rests with the States.
The Federal, regional, and local governments play an advisory role in
plan development and the Federal government must approve the completed
plan. Present patterns of responsibility in the St. Louis area indicate
that the technical planning responsibilities could be moved toward the
East-West Gateway Coordinating Council so that the Air Quality Maintenance
Plan can be coordinated with other plans and goals for the region. For
the long-range maintenance plan, implementation of transportation and land
use measures could rest with the East-West Gateway Coordinating Council and
the local jurisdictions, under the guidance of the State air pollution agency.
2. Participation
Participation in the long-term maintenance plan development and
implementation must be looked at from three sectors—technical , political
and public. Each is critical in developing intergovernmental cooperation.
Technical--The State air pollution agencies are responsible for
the development of the Air Quality Maintenance Plan and are responsible for
the implementation of it, although authority for implementation may be
46
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delegated to the local level, as has been done for the City of St. Louis
and St. Louis County. However, if the plan is going to be successful,
it should have considerable input from the local and regional agencies, not
only in plan development, but in implementation as well.
At the present time, there is no machinery to involve the East-West
Gateway Coordinating Council in AQMP development. The Missouri Air
Conservation Commission Transportation Control Plan Task Force could be
expanded to cover all elements of the Air Quality Maintenance Plan.
Participation in plan implementation, of course, is a very important
issue, particularly in the land use area where the local jurisdiction is
the only authority that can regulate land. It is not very likely that this
power will be relinquished to a regional agency or to the State, although
a State program of regional planning jurisdictions is an alternative.
Political--Political participation is very critical, since the
implementation of the plan may not agree with local jurisdictional objectives,
This political participation can be accomplished through the East-West
Gateway Coordinating Council. A special task force of political leaders
under the EWGCC might be set up to study air quality maintenance for the
area. This task force could develop the regulations that will be needed
for long-term plan implementation.
Public—It is becoming more and more apparent that any plan or
program that has an impact upon the citizens should be developed through
a public participation process. The earlier these kinds of programs are
initiated, the better, even before any alternatives are developed.
Certainly, the public should have a role in the development and evaluation
of alternatives, and in making recommendations to the political leaders.
At the present time, the East-West Gateway Coordinating Council has moved
ahead in this direction by establishing public participation in its
planning process. They now have a citizen task force on environment, and
other appropriate groups could be formed.
D. Constraints to Intergovernmental Cooperation and Coordination
In discussing the issues related to coordination, it is quite clear
that there are serious constraints to the development of a plan and the
implementation of such a plan in the St. Louis area. These constraints
48
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include: time availability, funding, legal authority, and jurisdictional
complexity.
1. Time
The June 1975 deadline for preparation of the AQMP makes diffi-
cult the development of adequate information, appropriate analyses of
the data, and proper technical, public, and political participation.
2. Funding
Adequate funding is critical. No new source of funds is available
to the air pollution control agencies for development or implementation
of a long-term comprehensive plan. Furthermore, to have the greatest
impact, some funds should be made available to the local jurisdictions,
and particularly to the East-West Gateway Coordinating Council so that
they can provide the staff to properly carry out their role in the planning
process.
3. Legal Authority and Jurisdictional Complexity
At the present time, adequate legal authority exists to implement
stationary source control and some transportation measures, although all
such authority is not fully implemented or enforced. However, land use
control authority has been delegated to the local governments. There is
no area in the United States, and certainly not in St. Louis, that can be
controlled by a regional authority. Therefore during the early stages—
up to 1977 and 1980--the St. Louis area is going to have to depend upon
persuasion to implement any regional land use program aimed at maintaining
air quality.
If these persuasion approaches are done well, with thorough public
and political participation, a great deal should be possible. While this
is being implemented, the kinds of mandatory enforcement required to
properly maintain the necessary air quality should be explored and
investigated.
The jurisdictional complexity in the St. Louis area that has been
discussed at several points in this presentation is similar to many areas
throughout the country. Only a few areas, like Minneapolis-St. Paul
and Nashville, Tennessee, have moved significantly toward ameliorating
this problem by giving more and more powers to the regional agency. In the
49
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St. Louis area it is recommended that more powers be given directly to
the East-West Gateway Coordinating Council. Cooperative arrangements will
be the cornerstone for regional improvements in the St. Louis area, and
every effort will have to be made to find out how to use these cooperative
agreements most effectively in dealing with air quality considerations.
This will call for considerable public participation as well as political
involvement. So, in effect, any sound program for air quality maintenance
will depend on cooperative participation of the public, the political,
and the technical leaders of the metropolitan area.
E. Recommended Arrangement for AQMP Development and Implementation
The significant conclusions from the St. Louis Study are as
follows:
• Plan development and implementation must be phased
Coordination mechanisms may vary with each phase to reflect
significant changes in responsibility or new program developments
Coordination mechanisms must reflect jurisdictional framework,
legal authority, and time and funding constraints
• Special mechanisms are needed for coordination
The recommended responsibility of different agencies for the various
phases is shown in Figure III-4. The timeframe and funding constraints
for example AQMP preparation did not provide for the active parti-
cipation of agencies other than the State and local air pollution
agencies. Because land use planning and transportation planning agencies
will not be able to actively participate at this stage, it is doubt-
ful that appropriate control measures in these areas can be proposed
in Phase 1.
The Transportation Control Plan Advisory Committee to the MACC has
just been established after approximately one year of effort. This
advisory committee can be expanded in membership and scope to initiate
AQMP preparation or it can be replaced by an AQMP advisory committee
appointed to be responsible for preparing alternative approaches for long-
term AQMP plan development.
Phase 2 includes the timeframe from proposed AQMP submittal in
June 1975 to the first AQMP review period in 1980. This time period
50
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includes revisions to the SIPs due to failure to attain any of the
primary standards by the proposed attainment dates and incorporation of
the Transportation Control Plan. The State air pollution control agencies
will provide the primary technical leadership for SIP revisions during
this phase.
During this phase, the AQMP should be revised to include the land
use and transportation considerations. Therefore the EWGCC is recommended
as the agency responsible for this first major revision of the AQMP and
for subsequent revisions and updates of the AQMP required as a continuing
process. Within this framework, the two states would retain approval
authority and State and local air pollution agencies would provide
expert assistance during the planning process. Responsibility for
implementation and enforcement would remain with the two states and
authority could be delegated to lower jurisdictions in accordance with
policy.
Phase 3 represents the ongoing 5-year review and revision cycle.
At this point, it is assumed that all available source control technology
will have been implemented and the emphasis in air quality maintenance
will be on land use and transportation alternatives. Therefore with
EWGCC performing as the technical coordinator for AQMP revisions, the
State Air Pollution Control Agencies could then concentrate efforts on
new technology and source control programs, and enforcement of existing
programs.
III. Baseline Emissions Inventory
A. Baseline Year
Existing inventory data in the St. Louis Air Quality Maintenance Study
Area were found to vary both in the year-of-record for a particular source
type and in completeness of information. To overcome the variation in
year-of-record, existing 1970, 1972, or 1974 inventories were projected
to 1975 (year of attainment) for each pollutant. This procedure aligns
all emissions data to a baseline year (1975) and assumes that all sources
will be in compliance with existing controls by the 1975 attainment date.
To eliminate discontinuities in information, existing data were supplemented
52
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by special analyses, as listed in the following section, to provide a
complete data base.
B. Sources of Emissions Data
The information used in the development of the baseline emission
inventory was extracted from the following sources:
Illinois State Implementation Plan
• Missouri State Implementation Plan
• Environmental Protection Agency—National Emissions Data System (NEDS)
• East-West Gateway Coordinating Council 1970 and 1995 Traffic
Assignment Data
• "Study of Attainment of National Air Quality Standards for Carbon
Monoxide and Oxidants in the St. Louis Air Quality Control Region,"
prepared by PEDCo Environmental Specialists, (cited hereafter as the
Attainment Study)
Union Electric Company and Illinois Power Company
Bureau of Economic Analysis (BEA) statistics
• St. Louis Standard Metropolitan Statistical Area (SMSA) statistics
The special analyses undertaken were:
• Primary Source Emissions at Compliance (TSP, SCO
• Point and area source distribution (for TSP and SO,, only)
• Subcorridor-VMT emission analysis (for CO and HC only)
The primary source emissions at compliance for TSP and S0? were
supplied by the MACC and IEPA. Emissions at compliance for CO and HC
primary sources were taken from the Attainment Study (as corrected by
IEPA).
C. Geographic Location of Sources
The NEDS inventory lists the location of point sources in UTM
coordinates. Area source data has been gridded in previous studies of the
St. Louis area using Illinois State Plane Coordinates. The detailed land
use data provided by the EWGCC are also maintained in a grid based on
the Illinois State Plane System.
A UTM-based grid network prepared by the CAASE procedure for area
source emission distribution was available from EPA for the St. Louis
Interstate AQCR and was used as an analysis base. In order to reduce the
53
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number of area source grid squares used in computations, the smallest
of the grid squares (1 km x 1 km) were combined into larger area sources.
The area of each grid square occupied by various categories of land use was
determined by overlaying the grid on land use maps, and these were used
to disaggregate NEDS county total area source data to the grid squares.
Since the point source coordinates were already UTM, they were easily
transferred to the grid location.
D. Technical Assumptions about Existing and Future Source Control
It was assumed that all primary point sources would meet their
compliance schedules. It was further assumed that these sources would
not emit less than the stated emissions at compliance in 1975. This was
considered a conservative estimate. No additional controls were applied
beyond those already in the SIP.
Many new controls or regulations are currently under study or are
proposed. These include: Indirect Sources Review, New Source Performance
Standards, significant deterioration regulations, fine-particle regulations,
and changes or delays in the Federal Motor Vehicle Control Program. As
these programs and their specific application to sources are defined, their
impact on emissions reduction can be quantified. However, at present,
it was felt that it would be most conservative to assume no additional
reduction from those programs.* Such programs can then be examined for
application as maintenance measures.
E. Problems and Suggested Solutions
Several detailed studies of air pollution in the St. Louis area have
been completed over the last ten years. However, a review of available
emissions data showed that there exists no consistent, current emissions
data for all sources in the AQMSA that are suitable for modeling purposes.
For example, the year-of-record varied for point source data and
the 1972 NEDS listing was considered inaccurate or incomplete for point
and area sources in both Missouri and Illinois. All area source data are on
a county-wide level, which is too gross for models that show spatial
While this is indeed a conservative assumption with regard to possible
but not certain improvements in air quality, EPA policy accepts and
encourages realistic appraisal and consideration of the effects of all
programs now in force for tie prevention of emissions from new or modified
sources.--Editor.
54
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variations. Gridded area source emissions were available from older
studies, but had not been updated and did not agree with the data in NEDS.
It is recommended that data be collected in a format suitable for
modeling. The RAPS program will provide data on a subcounty basis.
It is expected that these data will be distributed into the CAASE grid.
It is recommended that the subcounty level of detail be maintained in
updating the emissions inventory. This will provide a spatially detailed
data base sufficient for modeling purposes.
The MACC is currently coordinating efforts to update the point source
inventory for modeling purposes. The IEPA is working on a program to
convert their inventory to NEDS format.
IV. Emission Projections
A. General Methodology
The general approach to projecting emissions for all four pollutants
applied the following procedure:
1. Estimate a 1975 baseline inventory of all sources assuming
the sources are in compliance with existing regulations
2. Develop growth factors for each source category from available
growth data
3. Apply the growth factors to the 1975 baseline inventory to
obtain projected emissions from each source category.
Emissions were projected for four source categories: point, area,
power plants, and mobile sources. The specific methodology applied to
each source category is discussed in the following sections.
1. Point Sources
The 1975 point source emissions data were broken down, into primary
(sources greater than 100 tons/year) and non-primary (sources identifiable
as points, but less than 100 tons/year) sources for each pollutant. For
the primary point sources for TSP and SO , summaries of source emissions at
X
compliance, prepared by the Illinois Environmental Protection Agency and
the Missouri Air Conservation Commission, were used. For the non-primary
source emissions, the emissions were assumed to be uncontrolled (except as
stated in the SIP) and were taken from NEDS. The CO and HC 1975 point
55
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source emissions were taken from the Attainment Study (as corrected by
Illinois EPA).
The method for projecting point source emissions for 1980 and 1985
was to obtain growth rates for each company, power plant, and industry
that represents a primary point source. BEA industrial growth statistics
were used for non-primary point sources. Accordingly, a survey was
conducted of the primary point sources to gather information on growth
rates, productivity increase estimates, and expected increases in capacity.
Where actual growth rates could not be obtained for a point source,
projections were made using BEA statistics on growth in industrial
earnings and SMSA statistics on growth in employment and population.
2. Area Sources
1970, 1972, and 1974 area source emissions data were gathered and
projected to 1975 by applying a) the percent emission control as required
by the State Implementation Plan and b) growth factors from BEA statistics
for each area source category. 1980 and 1985 growth rates were calculated
from BEA growth statistics and local population estimates.
3. Power Plants
Individual plant data were provided by Union Electric Company,
Illinois Power Company, Missouri Air Conservation Commission, and the
Illinois Environmental Protection Agency. To project power plant emissions
for 1980 and 1985, the growth factors and the scheduled changes in new
and old plants were applied to 1975 baseline controlled emissions.
4. Mobile Sources
Mobile source emissions were divided into two categories:
highway and off-highway vehicles. Highway vehicles include both light-
and heavy-duty vehicles; off-highway vehicles include railroads, vessels,
aircraft, and other vehicles not operated on roads. For highway vehicles,
mobile source emissions data were taken from the Attainment Study for the
baseline year of 1975. For off-highway vehicles, mobile source emissions
data were taken from NEDS and the Missouri and Illinois State Implementation
Plans. Off-highway emissions were projected using a 3 percent average
growth rate.
56
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Highway emissions for TSP and SO were generated by applying TSP
/\
and SO emissions factors to projected annual VMT. Highway mobile source
s\
CO and HC emissions for 1980 were taken from the Attainment Study for the
Air Quality Control Region and adjusted to the Air Quality Maintenance Study
Area. The 1985 emissions were calculated in a special analysis (sub-
corridor VMT Emission Analysis) for the St. Louis urban-in*fact area by
interpolating the 1970 and 1995 traffic network data for each subcorridor
and link type. These emissions were adjusted to account for the entire Air
Quality Maintenance Study Area by the ratio of the projected VMT in the AQMSA
to the projected VMT in the urban-in-fact area. A summary of projected
emissions is shown on table III-l.
B. Problems and Recommendations for Solutions
In order to obtain a consistent controlled data base from which to
project 1980 and 1985 emissions and air quality, the available data on
emissions sources were first projected to 1975 to obtain the inventory
at full compliance with SIP regulations. This assumes that all sources
will be in compliance by 1975. The "controlled inventory" was then
projected to 1980 and 1985 using available growth and trend data.
The growth factors were based on population trends, employment and
industrial earnings projections, and traffic projections. Land use and
distribution trends were used to distribute the projected growth in
emissions. The use of such trend data as growth factors first assumes
that growth in emissions is directly proportional to these growth factors.
Although new and more efficient manufacturing techniques and control
equipment may make this assumption inaccurate, the procedure was deemed
appropriate for use in this pilot study.
Population forecasts served as growth and distribution factors.
The latest (unpublished) estimates show a marked decrease in population
growth compared to previously available projections for the urban area.
Since the land use plans do not as yet reflect this change, this repre-
sents a source of error that should be considered in the future applica-
tion of this report. The land use plans also represent projected
patterns of industrial and commercial growth and development.
There are four studies currently under way that could significantly
alter the growth patterns in the area. They are:
57
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Table III-l
ST. LOUIS AIR QUALITY MAINTENANCE STUDY AREA
EMISSION PROJECTION - SUMMARY
Source Category
Point Sources
Area Sources
Power Plants
Mobile Sources:
Point Sources
Area Sources
Power Plants
Mobile Sources
Point Sources
Area Sources
Power Plants
Mobile Sources:
Point Sources
Area Sources
Power Plants
Emissions, Tons per year
1975 1980 1985"
Total Suspended Particulate
Highway
Off -highway
TOTALS
50,329
18,955
20,348
8,383
3,647
101,662
57,972
20,404
34,064
9,622
4,228
126,290
71,617
23,563
34,863
10,823
4,902
145,768
Sulfur Dioxide
Highway
Off -highway
TOTALS
194,046
40,155
577,190
2,065
3,624
797,080
204,013
44,510
864,748
2,371
4,202
1,119*844
218,452
50,063
873,000
2,666
4,872
1149,053
Carbon Monoxide
Highway
Off -highway
TOTALS
Highway
Off-highway
TOTALS
46,821
28,808
1,641
476,242
31,891
585,403
40,208
30,389
1,191
82,502
11,217
165,507
50,870 59,734
27,565 27,799
1,641 1,700
241,459 146,070
36,972 42,859
358,507 278,162
Hydrocarbons
50,330 55,009
32,153 35,370
1,395 1,666
39,217 25,956
13,004 15,076
136,009 133,085
58
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• A railroad relocation study
• An airport study
• A port feasibility study
• A mass transportation plan
These plans will not be complete within the time frame for initial
AQMP submittal. This represents a potential inaccuracy in the projections.
It is recommended that the impact studies on current major projects
be used to update the projections of emissions as they become available.
The population projections will be reflected in the update of the regional
comprehensive plan and the HUD 701 Plan updates, and should be used to
revise the estimated projections and distribution of emissions.
The industrial survey technique was recommended as the best approach
for obtaining short-term growth estimates for existing primary sources.
The growth factors such as population trends, employment, industrial
growth and distribution data are available on a detailed spatial scale
in the regional land use plans. However, the format and frequency for
updating these data is not currently compatible with emissions inventories.
It is recommended that the EWGCC, MACC, and IEPA cooperate to obtain growth
data in a format useful for projecting emissions. EWGCC attempts to
evaluate alternative comprehensive plans for air quality impact may
provide a means of coordinating these data bases.
V. Establishment of Baseline Air Quality
A. Baseline Year and Sources of Data
1972 was used as the baseline year for air quality because 1973
SAROAD summaries were not available at the start of this study. Monitoring
data from 11 stations in the AQMSA were reviewed. Trend calculations were
available from selected sites from the Plan Revision Management System
Summary Report.
B. Compatibility of Baseline Emissions and Air Quality Data
The emissions inventory used as a baseline was determined from
activity projections to 1975 and assumed all sources to be in compliance
with now existing regulations of the appropriate state. These data, of
course, are not compatible with the 1972 air quality data. However, some
59
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air quality models for non-reactive pollutants had been calibrated using
concurrent emissions and air quality data. These calibrated models
were applied to the 1975 projected emissions to estimate expected air
quality. Since oxidants result from reactions in the atmosphere, modeling
is not possible. Therefore, Appendix J was applied to 1972 emissions data to
determine the HC emission reduction required, and the maximum allowable emissions,
C. Accuracy and Representativeness of Data
The Illinois monitoring data were not in the SAROAD data bank in 1972.
The IEPA considers the 1973 data to be more reliable due to improved
monitoring capabilities and techniques. The 1973 data will be entered
into SAROAD.
The 1972 monitoring network on the Missouri side is extensive for
TSP and S0?. However, it cannot be considered representative of the AQMA
because of the more significant source problem in the East St. Louis and
Wood River areas.
The Missouri Carbon Monoxide Monitoring Network has recently been
expanded to provide more data. Sites were selected to be representative
of areas that are expected to show maximum concentrations due to mobile
sources.
D. Estimation of Air Quality from Monitoring Data
Existing air quality data and initial air quality projections were
reviewed by the Missouri Air Conservation Commission (MACC) and by the
Illinois Environmental Protection Agency (IEPA) in order to designate
the St. Louis Air Quality Maintenance Study Area.
Trend calculations from selected sites were available for total sus-
pended particulates, sulfur dioxide, carbon monoxide, and oxidants from
the Plant Revision Management System (PRMS) Summary reports. Results of
the trend analysis indicate that most of the TSP problems are related to
the 24 hour standard. Three sites were identified as "potential problems."
One major "potential problem" with respect to CO was identified near
downtown St. Louis. An oxidant problem appeared at four sites distributed
throughout the AQMSA.
The following statements summarize the conclusions from the review
of all existing air quality data for the St. Louis AQMSA:
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ISP, SCL, CO, and oxidants all currently exceed the primary
standards at some point in the AQMSA
• TSP and oxidants exceed the criteria for designation of a
maintenance problem
• SOp currently exceeds the standards in isolated areas in both
the Illinois and Missouri portions of the AQMSA.
• CO does not exceed the criteria for designation of a maintenance
area.
E. Problems and Suggested Solutions
Monitoring data from 11 stations in the AQMSA were reviewed. The
Regional Air Pollution Study (RAPS) will add 25 new monitoring stations
to this network during the next two years. It is recommended that
priority be given to analyzing data from the sites in the vicinity of
Wood River and East St. Louis to verify the short-term S0? problems.
VI. Air Quality Projections
A. Methodology
Certain general considerations guided the selection of projection
techniques. These considerations included the availability of techniques
recently applied to St. Louis where forecasts need only be extended to
longer time intervals, the availability of a calibrated model for St. Louis
based on current data, the availability of data to facilitate the appli-
cation of a specific technique, and the time constraints posed by this
particular study.
Those techniques selected for projecting air quality for total suspended
particulates, sulfur dioxide, carbon monoxide, and photochemical oxidants
are discussed in the following sections.
1. Total Suspended Particulates
The estimation of annual concentrations for TSP was accomplished
through application of statistical relationships between TSP emission
*
density and concentration. The relationship is displayed as a curve
(where 1964 TSP sampling data are plotted against emissions densities for
various land areas larger than 20 square miles).
*
U.S. Department of Health, Education, and Welfare, Interstate Air
Pollution Study: Phase II Project Report, December 1966.
61
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The air quality estimation method required the summary of emissions
from all sources within selected subareas (36 square miles or greater) of the
St. Louis AQMA and then, determination of emissions density values for
each subarea. The estimated annual concentration was then found from
the curve and recorded at the center of each selected subarea in the AQMA.
Isopleths were drawn between subarea centers. These isopleths display
the mean annual TSP concentration distribution in the St. Louis AQMA.
This procedure was applied to projected emissions for 1975, 1980, and 1985.
2. Sulfur Dioxide
The estimation of air quality concentrations for S0? was accomplished
by applying two air quality diffusion models: Miller-Holzworth for the
St. Louis central urban area and Wood River Complex Area, and Pasquill-
Gifford Plume Dispersion for four significant point sources.
These two methods required calculation of concentrations from given
equations. The Miller-Holzworth equation calculates annual average
areawide concentrations of SC^ from emissions density, mixing depth, urban
size, and mean annual wind speed. The Pasquill-Gifford Plume Dispersion
calculates a maximum 24-hour average concentration of S0? from wind speed,
plume rise, emissions rate, stack parameters, meteorological stability,
and assumes a Gaussian plume. The resulting concentrations, tabulated
for 1975, 1980, and 1985, obtained by applying the models to the projected
emissions for those years, are included in the full text report.
3. Carbon Monoxide
As recently as March 1974, the APRAC 1A Diffusion Model had been
applied to projected carbon monoxide emissions for the St. Louis AQCR (the
Attainment Study). However, estimates of 8-hour CO concentrations were
only calculated for 1975. CO concentrations in 1980 and 1985 were extrapo-
lated from the 1975 estimates using the following procedure:
• Assume worst case meteorological conditions; do not vary
• Assume concentrations of CO are directly proportional to emissions
of CO under constant worst-case meteorological conditions
• Calculate 1975, 1980, and 1985 CO emissions in the vicinity of
the selected 9 receptors using the subcorridor VMT analysis
• Calculate the change in emissions in the vicinity of each receptor
from 1975 to 1980, and 1980 to 1985 by subtraction.
62
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Apply the corresponding percent change in emissions to the 1975 con-
centrations at each receptor to obtain 1980 and 1985 concentrations.
This procedure is equivalent to a "rol 1-foward" type of calculation using
the results of a calibrated diffusion model to represent baseline air quality.
4. P h o toe h em i c a 1 Oxidants
1972 second highest 1-hour oxidant concentration of 300 micro-
grams per cubic meter was used with Appendix J of Regulations on Preparing
Implementation Plans (40 CFR 51) to determine the percent reduction in hydro-
carbon emissions needed to reduce photochemical oxidant concentrations to the
NAAQS. This percentage reduction was applied to the 1972 total hydrocarbon
emissions to determine the amount of emissions that must be prevented. Sub-
tracting this amount from the 1972 total gave the maximum hydrocarbon emis-
sions allowable if the photochemical oxidant standards are to be maintained.
The maximum allowable total hydrocarbon emissions value applies to any
year. This reduced hydrocarbon emissions value was then used to determine
the reduction required in projected emissions for 1975, 1980, and 1985 to
maintain NAAQS. A summary of the air quality projections for 1975, 1980,
and 1985 is shown in table 1 1 1-2.
B. Summary and Conclusions of the AWMSA Analyses
The conclusions of the air quality and emissions analyses follow for
each pollutant considered.
1 . Total Suspended Particulates (TSP)
Air Quality—Ambient concentrations currently exceed the
primary standards at several monitoring stations. The projected concentration
distribution pattern changes very little over the 10-year period. "Hot-spot"
areas can be identified that have the potential to exceed the standards
during the 1975 to 1985 period.
Source Contribution— Point sources and power plants are the
primary contributors to the existing problem. However, increases are
projected in all source categories. Growth in emissions is expected to
be concentrated at existing sources or in the vicinity of existing sources.
Growth between 1974 and 1985 accounts for less than 20 percent of projected
total emissions in 1985. The contribution of fugitive dust to ambient
concentrations is not known at this time.
Attainment and Maintenance of Standards—The primary standards
are projected to be attained by 1975 and maintained throughout the following
10-year period in most of the AQMSA. However, "hot-spot" areas are identified
63
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Table III-2
ST. LOUIS AOMSA
SUMMARY OF AIR QUALITY PROJECTIONS
Averaging Peak Concentrations
Pollutant Time ' 1975 1980 1985
TSP (//g/m ) Annual 120 120 120
(std. = 75)
S0? (jig/m ) 24-hr. 322 *00 400
(std. = 365)
CO (ppm) 8-hr. 12.8 6.95 4.30
(std. - 9)
0 Wm3) 1-hr. 240 190 180
x
64
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where the primary standards are projected to be exceeded beyond the 1975
compliance schedule. Because the growth in emissions is projected to be
concentrated in these "hot-spot" areas, maintenance of the standards will
be a problem. Secondary standards are projected to be exceeded throughout
the 10-year period in large portions of 3 counties and the city of
St. Louis surrounding the "hot-spot" areas.
Actions Required—An attainment and maintenance strategy is
required for the "hot-spot" areas. A strategy is needed to maintain the
secondary standard for TSP in the area immediately surrounding the "hot-
spots" .
2. Sulfur Dioxide (S02)
Air Qual ity—Ambient concentrations of SCL at isolated sites
in both the Illinois and Missouri portions of the AQMSA currently exceed the
primary standard. Air quality projections are highly dependent on the
sulfur oxide emissions from isolated sources and indicate that a
"potential" to exceed the standards exists only in the vicinity of
these sources.
Attainment and Maintenance of Standards--SCL standards are
being exceeded in the vicinity of major power plants or specific point
sources.
Actions Required—More extensive monitoring and surveillance
of major sources is required to ensure maintenance of the short-term
standards in the vicinity of these sources. Strict enforcement of existing
regulations is required to prevent increases in SCL emissions from
existing sources or prevention of new sources in the "hot-spot" areas.
3. Carbon Monoxide (CO)
Air Quality--Eight-hour standards are currently exceeded at
several monitoring stations throughout the AQMSA. Projected concentrations
indicate several areas will exceed the eight-hour standard in 1975. All
selected receptor sites are projected to be well below the standards by
1980. Maximum concentrations are associated with major highways and
intersections.
Source Contribution—Mobile sources are the primary contributors
to CO emissions in the AQMSA and will still account for more than 50 percent
of total emissions by 1985.
65
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Attainment and Maintenance of Standards—Once the 8-hour CO
standards are attained, the continued decline in mobile source emissions
will assure maintenance to at least 1985.
Actions Required—A Transportation Control Plan (TCP) is
currently in preparation to provide attainment of the CO standards.
This will be incorporated in the AQMP.
4. Photochemical Oxidants (Ox)
Air Qua!ity—Peak-hour oxidant concentrations currently exceed
the standard and limited air quality trend data indicate increasing values.
Oxidant values are projected to decrease due to decreases in total hydro-
carbon emissions. However, the decreases are projected to be insufficient
to attain the standard through 1985.
Source Contribution—Mobile sources are currently the most
significant contributor to total regional hydrocarbon emissions. However,
stationary point and area sources become more significant by 1985 as
mobile source controls become more effective.
Attainment and Maintenance of Standards—The oxidant standard
cannot be attained or maintained with the existing SIP control measures.
Uncontrolled (no TCP) projected oxidant concentrations exceed the standard
beyond 1985.
Actions Required—A Transportation Control Plan (TCP) is
required for Attainment and a Maintenance Strategy is required.
C. Problems and Suggestions
The major drawback to using any sophisticated modeling procedures at
this time is the inconsistency and inaccuracy in the emissions data base
and the uncertainty of the demographic growth rate data. As these deficiencies
are resolved, an effort should be made to coordinate the collection of data
in a form useful for input to the analysis techniques. Point source data
are currently collected in a form suitable for input to models for particu-
lates and S0?. However, more short-term operational data would be useful.
Area source data for these two pollutants are not collected on a sufficiently
detailed scale to input to a model such as AQDM or COM. The CAASE program
may provide adequate detail. Fugitive dust emissions must also be collected
for input to the model for particulates.
66
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Projected mobile source emissions data are currently available only
on a county basis and are not suitable for input to any carbon monoxide
air quality model. Data should be obtained in a format suitable for
input to such models as SAPOLLUT and APRAC-1A.
The results of the RAPS program will be invaluable to upgrading the
emissions inventory and analysis procedures for the St. Louis area. However,
they will not be available within the proposed timeframe for AQMP submittal.
Therefore, interim analysis approaches must be used. It is recommended
that priority for all such interim analyses be given to the "hot-spot" areas.
VII. Selection of Maintenance Strategies
The air quality analysis indicates that attainment of the primary
standards for TSP, SO^* CO, and oxidants cannot be achieved by 1975. In
addition, maintenance strategies are required for TSP, S0?, and oxidants.
The development of a maintenance strategy, therefore, requires a review
of existing and proposed attainment plans and an evaluation of alternative
maintenance strategies. The following sections provide a brief review of
the status of attainment plans and the evaluation of alternative maintenance
measures. A proposed maintenance strategy is outlined and the constraints
to implementation of the selected strategy are described.
A. Status of Attainment Plans
1. Particulates
Current trends in air quality indicate the particulate standards
will not be attained by 1975; the cause of this trend cannot be isolated.
Therefore, no new attainment measures can be justified unless 1975 ambient
data confirm this trend. Monitoring and surveillance programs are currently
being expanded in order to verify the effectiveness of the existing
attainment plan. It is recommended that a fugitive dust inventory be
completed as a part of this monitoring program.
It would not be justifiable to require additional TSP control measures
to attain the standards at this time until it can be determined whether
the existing controls are being implemented to their intended extent and
are achieving the expected results. Therefore, the only additional
attainment measures recommended at this time are measures directed at
expanding the monitoring and surveillance programs.
67
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Compliance schedules and source review procedures are currently being
reviewed by EPA and State air pollution agencies. The City of St. Louis
has increased the frequency of monitoring in order to provide a more
accurate assessment of ambient air quality. Monitoring has also been
expanded in Illinois. In addition, the RAPS program will eventually provide
detailed ambient data and emissions data to determine the relationship
between emissions and ambient concentrations.
The City of St. Louis has also compiled a list of sources of particulates
not included in the existing inventory, but does not have emission data for
these sources. This program could be expanded to include a regionwide
compilation of "fugitive dust" emissions.
2. Sulfur Dioxide (SO?)
The SIPs for Illinois and Missouri both project attainment of
the primary S0~ standards by 1975. However, 1972 air quality exceeded
the primary standards at several sites in the Illinois portion of the AQMA.
The Illinois EPA feels these violations are related to individual sources.
The analysis concluded that the primary standards would not be
attained by 1975 at several points in the AQMSA due to source-oriented
problems. In addition, anticipated increased emissions from steam electric
power generation provide the "potential" for short-term standards to be
violated depending upon individual source operational characteristics.
It is concluded that attainment of the SCL standards is a specific
source oriented problem and efforts are currently underway to determine
source compliance with existing regulations. However, IEPA has designated
their portion of the AQMSA for S02-
3. Carbon Monoxide and Photochemical Oxidants
St. Louis was not among the original group of cities required to
submit transportation control plants to attain and maintain the NAAQS for
CO and oxidants. Recent ambient data from the expanded monitoring network
suggest an attainment problem does exist for CO and oxidants. Therefore,
the MACC in cooperation with the Illinois EPA and the EWGCC augmented by
additional community representatives is currently preparing a Transportation
Control Plan (TCP).
68
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It is assumed that the strategy selected will provide for attainment
of the CO and oxidant standards by 1977 as required by the Clean Air
Act provision. The strategy selected will greatly affect the maintenance
of the oxidant standard due to the impact on growth in hydrocarbon emissions.
The attainment dates and long-term maintenance impacts cannot be evaluated
until the TCP is finalized.
B. Maintenance Strategy Selection
The maintenance strategy must provide sufficient emission reduction
to account for the projected growth or plan for appropriate growth in
areas where the ambient air quality is at or near the standards.
The maintenance problem in the St. Louis AQMSA is characterized by a
number of areas where existing sources are expected to continue to emit
pollutants at rates that virtually preclude the influx of additional
emission sources into these areas without violation of ambient air quality
standards once they are attained. Maintenance strategies for these areas
must include further emission reductions from the existing sources and/or
effective methods of preventing new sources from locating in these areas.
The potential maintenance strategies outlined in Volume 3 of the
guidelines series were reviewed and evaluated for application in the St. Louis
AQMA. Those measures considered generally applicable to the St. Louis
Maintenance problems were evaluated for:
long-term effectiveness
• effectiveness in preventing the location of, new sources in
"hot-spot" areas
• general application to the potential problem or "hot-spot" areas
implementation obstacles
The conclusions of this review are as follows:
• Long-term air quality maintenance requires a regionwide, comprehensive
approach associated with the community planning process. Two administrative
approaches appear applicable and implementable--Emissions Allocation and
Regional Development Planning.
• Measures that have long-term general application and effectiveness
as part of a comprehensive approach include: indirect source review and
environmental impact statements, transportation control measures, indirect
regulatory controls, Federal New Source Performance Standards.
69
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• Emission source control measures that have short-term or long-
term effectiveness in the "hot-spot" areas include: more stringent
controls on existing sources, phaseout of emission sources, control of
fugitive dust.
C. Proposed Attainment/Maintenance Strategy
The air quality analysis, status of attainment plans, and evaluation
of maintenance strategy alternatives indicate that the best available
approach to the attainment and maintenance of air quality in the St. Louis
AQMA is a program that includes:
Full implementation and enforcement of all attainment plan measures
included in the state implementation plans
• Expanded monitoring and surveillance through the RAPS/RAMS programs
• A Transportation Control Plan (TCP)
• Long-term comprehensive planning approach to air quality maintenance
Interim measures to ensure maintenance during the period required
for development and full implementation of the long-term plan.
A summary of the proposed plan elements for each pollutant is shown
in Table III-3.
D. Constraints and Timetables for Development and Implementation of
Air Quality Maintenance Plan
The major feature of the proposed maintenance strategy is a comprehensive
approach that incorporates air quality maintenance into the community
planning process. There are many issues and constraints that must be
resolved before such an approach can be implemented. Discussions with
planning community and air pollution agency representatives suggested
that the interagency coordination required to implement a long-term
comprehensive approach would take two to three years to establish (see
Section II). If a formal or mandatory control program, such as emissions
allocation, is selected as the desired administrative approach, some
additional legal authority will be required in order to implement this
program on a regional basis. The conclusion is that the comprehensive
approach cannot be fully implemented for three to five years and "stop-gap"
measures are therefore required to maintain the standards during the
interim period.
70
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It is therefore recommended that the development and implementation
of the maintenance plan be phased. Figure II1-5 shows the suggested time-
table for development and implementation of the comprehensive air quality
maintenance plan. The key milestones are indicated.
There are three major phases shown for AQMP development and implementation:
• Phase 1 - now to June 1975
• Phase 2 - June 1975 to June 1980
• Phase 3 - June 1980 to June 1985
During Phase 1, the attainment measures (including the TCP) and
interim measures should be finalized and submitted to EPA in June 1975.
The task descriptions, agency responsibilities, and funding requirements
for the long-term comprehensive plan development should also be submitted
to EPA in June 1975. In addition interagency memoranda of understanding
should be obtained stating the agency responsibility in plan development and
agreements to persuade new industry with significant TSP or S0? emissions
to avoid the "hot-spot" areas. Any transportation system improvements
or review procedures, mobile source controls, or indirect source control
programs that are required for attainment or maintenance should be delineated
and presented in the transportation control plan or the maintenance plan
submitted in June 1975.
Phase 2 consists of the selection and development of the long-term
comprehensive approach: the implementation of all attainment measures,
TCP measures, transportation policies or measures required for maintenance,
interim source control measures required for maintenance, and voluntary
compliance with the "hot-spot" land use policy. If voluntary compliance
with the "hot-spot" policy is not effective, the Missouri Air Conservation
Commission "hot-spot" regulation can be strictly enforced for existing
sources. Any SIP revisions can also be completed during this time period.
By 1980, it is expected that all administrative programs, legal
authority, and monitoring and surveillance requirements of the comprehensive
long-term plan can be implemented. The AQMP development can then become
a five-year review and revision cycle, as proposed in the EPA Guidelines.
72
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VIII. Legal Authority
The enabling legislation given in the State Implementation Plans is
sufficient basis for the implementation of all source control measures
required for attainment and maintenance of the standards.
The long-term comprehensive approaches to air quality maintenance
described in Chapter IV are administrative approaches. They maintain
air quality indirectly by the application of land use and transportation
policies that tend to minimize emission, especially in the "hot-spot"
areas. Specific land use control regulations may be adopted to formalize
these policies. For example, emissions allocation can be implemented as
a regulation calling for a ceiling on emissions within each small community
or geographic area within the AQMSA.
The following paragraphs describe existing legislation directly
related to air quality maintenance.
The Air Quality Implementation Plans and related regulations as
adopted by Missouri and Illinois form the enabling legislation for the
St. Louis AQMSA. Attainment of the standards will rely on implementation
and enforcement of these regulations. Any regulations adopted as a
result of the Transportation Control Plan currently being prepared will
become part of this body of regulations.
Two regulations included in the Missouri SIP are particularly
applicable to the maintenance of air quality once the standards are
attained. These regulations are summarized briefly below.
Regulation XVIII. Approval of Planned Installations, Land Use Plans,
and Zoning Regulations Required. This regulation is the basis for the permit
system for new sources. Paragraph B of this regulation requires the
executive secretary of the MACC to review all land-use plans prior to
formal adoption by local areas and prepare recommendations according to
the regulations. No local plan may be adopted without the approval of
the executive secretary. Paragraph C places similar requirements on the
review and approval of zoning agency regulations and proposed changes
in zoning classifications.
This regulation is not currently implemented in the AQMSA and because
no penalties are stated for non-compliance, the agency has no enforcement
74
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authority. However, it could serve as the basis for monitoring all planned
community growth and development.
Regulation XXIII. Additional Air Quality Control Measures May Be
Required When Sources Are Clustered in a Small Land Area. This regulation
applies to particulate and SO- emission sources in areas that exceed a
given allowable emission density. The MACC may prescribe more restrictive
requirements in such areas than are provided in the regulations of general
applicability.
This may be referred to as a "hot-spot" regulation. It provides for
more restrictive controls where source clustering may cause the standards
to be exceeded although all emissions limitations are being met. This
regulation is not currently being implemented because many compliance
schedule deadlines have not been reached. However this regulation could
be applied to maintain emission density levels below that level at which
ambient pollutant concentrations are estimated to exceed the standards
for particulates and sulfur dioxide. This would require an accurate
estimate of the relation between emission density and ambient concentration
in a given area. This relationship may vary due to the relative source-
receptor characteristics of an area. The RAPS program should provide
sufficient data for this determination. Short-term emissions limitations
would be the most difficult to establish.
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SUMMARY OF ST. LOUIS AQMSA
POLLUTANT: TSP*
NAAQ STANDARD: 60 ug/m3 (annual secondary standard); 75 yg/m3 (annual)
CURRENT AIR QUALITY, 1971: 135.0 yg/m3 (annual)1"
EXPECTED AIR QUALITY IN 1975: 120 yg/m3 (annual, projected)
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD: 63% (by rollback)
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
1. SIP Regulation Enforcement, Extended Monitoring - June 1975
2. "Hot-spot" Regulation - June 1976
3. Long-Term Comprehensive Approach - June 1980
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
New Federal programs for particulate control must be coordinated,
including: new source performance standards, fine particulate regulations,
and significant deterioration. Long-term coordination with regional
planning to avoid "hot-spots".
* 3
Background of 40 ug/m assumed.
Broadway and Hurek, St. Louis City
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SUMMARY OF ST. LOUIS AQMSA
POLLUTANT: CO
NAAQ STANDARD: 9 ppm (2nd highest - 8 hr.)
CURRENT AIR QUALITY, 1972: 16.8 ppm (2nd highest - 8 hr.)
EXPECTED AIR QUALITY IN 1977*: 7.6 ppm (APRAC-1A projection)
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD: 46% (rollback)
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
1. Transportation Control Plan - June 1975
2. Indirect Source Review - June 1975
Exclusive Bus/Carpool Lanes - June 1975
3. Comprehensive Transportation Planning (in effect) - June 1980
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
Coordination of FHWA, EPA, State Highway Departments, local street
planning, the 3-C planning agency, the indirect source review agency,
and the air pollution control agencies. The TCP Advisory Committee
can provide initial guidance.
*
With proposed TCP Strategy III as in PEDCo Attainment Study.
77
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NUMMARY OF ST. LOUIS AQMSA
POLLUTANT: S0x
NAAQ STANDARD: 80 pg/m3 (annual); 365 yg/m3 (2nd high - 24 hr.)
CURRENT AIR QUALITY, 1972*: 557 yg/m3 (max. 2nd highest - 24 hr.)
EXPECTED AIR QUALITY IN 1975: 322 M9/m3 (24 hr., projected at one source)
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD: 34% (rollback)
PROPOSED ATTAIN/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
1. Enforcement of SIP Controls - June 1975
Expanded Monitoring (RAPS)
2. "Hot-Spot" Regulation - June 1976
3. Interim Source Controls - June 1975
S02 Reduction at Power Plants
Municipal Refuse in Power Plants
4. Long-term Comprehensive Planning - June 1980
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
Coordination between EPA and the Federal Power Commission, utility
companies, air pollution agencies. Coordination with energy conservation
programs. Long-term coordination with regional planning to avoid "hot-
spots".
*
Illinois data, Missouri at standards.
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SUMMARY OF ST. LOUIS AQMSA
POLLUTANT: HC/Photochemical Oxidants
NAAQ STANDARD: 160 yg/m3 (peak--one hour)
CURRENT AIR QUALITY, 1972: 300 pg/m3 (2nd highest peak-hour)
EXPECTED AIR QUALITY IN 1975: (75) 240 yg/m3 (Max - hr., Appendix J)
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD: 47% (Appendix J)
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
*1. Transportation Control Plan - June 1975
2. Additional stationary source HC control - June 1976
3. Comprehensive Transportation Planning (in effect) - June 1980
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
Coordination of FHWA, EPA, State Highway Departments, local planning,
air pollution control agencies for mobile source control as in the CO
control. Negotiation between EPA, state air agencies and individual
source for compliance schedule changes as stationary point sources.
*
Additional stationary source control may be required. June 1975.
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Chapter IV
BALTIMORE TRIAL AIR QUALITY MAINTENANCE PLAN*
I. Characteristics of the Baltimore AQMSA
The Baltimore Air Quality Control Region boundaries conform to the
Baltimore Standard Metropolitan Statistical Area and encompasses 2,364
square miles (Figure 1). Included in the region are the City of Baltimore
and the counties of Anne Arundel, Baltimore, Carroll, Marford, and Howard.
The Region forms the western edge of the northern section of Chesapeake
Bay. The western portion of the Region lies in the Piedmont Plateau,
while the eastern portion lies within the Middle Atlantic Coastal Plain.
The eastern portion is generally flat, with elevations of less than 500
feet. Toward the west, the elevation rises gradually to the gently rolling
areas of Carroll and Howard Counties where elevations reach 1,000 feet.
The topography generally permits free air movement with little channeling
effect.
Population of the Region increased 19 percent between 1960 and 1970
to a total of nearly 2.1 million. The 1970 census data indicate that
projected growth patterns and population estimates were reasonably accurate
except for the City of Baltimore, which was estimated to have lost
approximately four percent in population. The population of Baltimore
County increased over 26 percent in the same 10-year period and ranked
as the most populous county in the State.
Weather Bureau data indicate that inversion conditions occur on
short term basis about 34 percent of the time in the Region. Over a
thirty-year interval, the Region averaged 1.5 times per year when stagna-
tion occurred that averaged 4.3 days duration. During the same thirty-
year period, the region experienced three cases of stagnation that lasted
for seven or more days.
The time frame in which air quality maintenance plans were considered
to be applicable was 1975 to 1985.
Four pollutants were considered for analysis (i.e., particulate matter, sulfur
dioxide, photochemical oxidant (hydrocarbons) and nitrogen dioxide. Carbon
*
Development of a Trial Air Quality Maintenance Plan Using the Baltimore
Air Quality Control Region, NTIS No. PB 416/AS
81
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PENNSYLVANIA
PRINCE
GEORGE
COUNTY
ANNE
ARUNDEL
COUNTY
MONTGOMERY
COUNTY
Figure iv-l. Baltimore air quality control region
R2
-------
monoxide was not included in the sample plan. A preliminary analysis
based on existing air quality and emission inventory data indicated that
the future carbon monoxide levels-would not exceed the standards and there-
fore should not be considered in the maintenance program.
The sample air quality maintenance plan was developed so that the
National Secondary Ambient Air Quality Standards would be achieved and
maintained. The analyses did not attempt to develop plans for achieving
or maintaining the more stringent ambient air quality standards of the
State of Maryland.
To initiate analyses of the need for air quality maintenance plans,
consideration was given to the existing air quality, existing emission
inventory, and existing regulations and compliance schedules for reducing
various pollutant sources. Maintenance plans were conceptually designed
to offset increases in projected emissions as a result of growth through
enactment of increasingly stringent control measures (Figure 2). It is
therefore assumed that existing regulations would be complied with by
1975 or 1977. However, it was recognized that, in certain cases,
the National Secondary Ambient Air Quality Standards would not be met by
the 1974 or 1977 date. In such cases, maintenance strategies theoretically
could be selected that would more than compensate for the anticipated
growth in emissions. The selected control measures would thereby offer
the possibility of eventually replacing currently unacceptable control
measures such as gas rationing. During preparation of the sample plan,
Congress extended the date for additional motor vehicle emission controls
to 1977 and limited application of certain measures that had earlier been
advocated as hydrocarbon control (VMT) measures; for this analysis, the
assumption was made that by the year 1985 motor vehicles would be tightly
controlled.
Control measures considered for implementation were reviewed and
evaluated by the Baltimore Regional Planning Council's Air Quality Task
Force. The background and experience of the Task Force offered a broad-
based and wide-ranging viewpoint from State and local officials toward
the air quality planning as a part of other and broader long range plans
for the Region. Similar groups should be of value in development of
other AQMPs.
83
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II. Intergovernmental Cooperation
A. List of Agencies, Governments and Groups Contacted in Preparing and
Implementing AQMP
1. State
a. Maryland Department of Health and Mental Hygiene, Bureau
of Air Quality Control;
b. Maryland Department of Transportation, Division of
Systems Planning and Development;
c. Maryland Department of State Planning, Office of Regional
and Local Planning—Baltimore Area; Office of Comprehensive State
Planning—Natural Resources.
d. Office of Maryland State Attorney General.
2. Regional
Baltimore Regional Planning Council
A-95 Review
HUD 701 Planning Programs
3-C Planning Programs
Land Use and Recreation Department
Transportation Department
Air Quality Task Force v
3. Local
a. City of Baltimore
Mayor's Office —'
Department of City Planning
City Health Department -
Interstate Division for Baltimore City (Joint City/State)
b. Anne Arundel County
Department of Planning
Citizen Representative —
c. Baltimore County
County Developme
Department of Planning
County Development Coordinator -
— Indicates that contacts were made primarily or solely through the
Air Quality Task Force of Baltimore Regional Planning Council.
85
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d. Carroll County
Citizen Representative —
County Health Department —
Department of Planning
e. Harford County
County Planning and Zoning Commission —
f. Howard County
Department of Planning
Citizen Representative —
g. City of Annapolis
Director, Planning and Development —
4. Other
a. Baltimore City Medical Society --
b. Better Air Coalition -
c. American Lung Association of Maryland —'
d. Baltimore Gas and Electric Company
B. Responsibilities of Agencies, Groups and Governments to AQMP Agency
The agency to be assigned responsibility for the preparation of the
AQMP is the Maryland Department of Health and Mental Hygiene, Bureau of
Air Quality Control (BAQC).
1. Planning Activities
a. Provide Land Use Plans
Baltimore Regional Planning Council (RPC), Land Use and
2/
Recreational Department —
City and County planning agencies, as necessary, to
amplify and up-date RPC plans.
b. Provide Transportation Plans
Department of Transportation - Division of Systems
2/
Planning and Planning — will be prime source of data, of interpretation
and of technical assistance in the plan
Baltimore RPC, Transportation Department, who have worked
closely on transportation plans with Maryland DOT
-Indicates that contacts were made primarily or solely through the Air
Quality Task Force of the Baltimore Regional Planning Council.
2.1
—Indicates prime source(s) of data and assistance throughout this section
of the Digest.
86
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BAQC has worked extensively with the data and will
have much of it available in-house.
c. Provide Housing Plans
2/
Baltimore RPC, Housing Department —
City and County planning agencies will provide details
and up-date of the data as necessary.
d. Provide Redevelopment Plans
2/
Baltimore RPC - will have most of the data
2/
City of Baltimore, Department of City Planning — will
be the source of detailed plans for the City as these are necessary,
County planning agencies for other redevelopment, both
public and private, where additional detail beyond that available from
RPC is required.
e. Provide Health Plans
Maryland Department of Health and Mental Hygiene
Baltimore RPC will have local, current, detailed,
knowledge of facility construction plans through their review process.
f. Provide Open Space/Recreation Plans
21
Baltimore RPC, Land Use and Recreation Department —
have complete and detailed data on all types of recreation and open
space probram.
Maryland Department of State Planning can provide more
detailed data on specific state recreational facilities.
g. Provide Capital Improvement Programs
Baltimore RPC will provide bulk of data
Baltimore City and County agencies may be called on
for additional details and assistance as necessary.
h. Participate in A-95 Review Process
Baltimore RPC is the accredited review agency and would
cooperate with the AQMP agency at planning and implementation phases.
i. Review EIS
Not applicable in planning stage since no EIS prepared.
21
— Indicates prime source(s) of data and assistance throughout this section
of the Digest.
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j. Prepare EIS
The sponsoring agency must prepare the EIS for defined
Federal actions, but at the planning stage of the procedures, there is
no EIS prepared.
k. Provide Growth Projections
Baltimore RPC (Systems Analysis and Data Services) can
provide the basic sets of growth projections on which most of the
transportation-land use and public facility planning in the region is
predicated. These may be taken as approved by the local communities
since the General Development Plan has been adopted.
Study team went through process of growth real location in the analysis
of the effects of land use strategies in maintenance of air quality
standards.
1 . Review Growth Projections
Other agencies have developed differing projections or
may regard existing projections dates as a result of rapid recent changes
in social and demographic indices. Department of State Planning should
review RPC's projections.
m. Provide Emission Factors
Bureau of Air Quality Control, the AQMA planning agency,
should have access to this data from their own records.
Utility company will provide supplementary data on
policy regarding future distribution of home heating units between
oil, gas and electricity and on the future availability of fuels to be
used in local generating plants.
Federal EPA publications.
n. Review Emissions Factors
BAQC will do in final plan.
o. Provide Emissions Projections
BAQC will do in final plan.
p. Review Emissions Projections
BAQC will do in final plan.
q. Other
none.
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2. Implementation Activities
The activities described include all of those considered and
discussed in the planning program and not only those actually incorporated
into the selected plan. The manner in which responsibilities for imple-
mentation may be assigned are specified in a. to g. below.
a. Zoning
City of Baltimore. Most of the "hotspots" for TSP
concentrations, to which zoning regulations would be applied, are in
the City.
Adjacent counties would be called on to amend their zoning ordinances
and zoning plans to exclude certain uses and promote desired development
patterns.
This category of implementation measure includes:
Special Use Zone
Floating Zone
Large Lot Zoning
Agricultural and Conservation Zoning
Holding Zones
Planned Unit Development
Performance Standard Zoning
Emission Density Zoning
b. Permi ts
The use of permits would be applied as an operating
procedure to many of the types of control measures discussed in this
section.
c. Utility Extension
The provision of water and sewer services as a means
of controlling growth would lie with the municipalities (cities and
counties), though RPC would be the means of developing the overall policy
and plans under which the separate municipal utility construction programs
would proceed.
d. Subdivision Regulations
These local controls affecting, for example, permitted
densities anf regulation of paved sections, would be the responsibility
of the local governments.
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e. Building Codes
These local controls specifying construction techniques,
materials and standards, including heating and insulation specifications
are the responsibility of individual cities and counties. The State could
play a major role in the promulgation of a State model code incorporating
required changes assigned to improve air quality.
f. Housing Codes
These controls, applying to all residential structures
and specifying standards to insure adequacy of light, heat, air and
ventilation, are the responsibility of the cities and counties. Again,
the State could assist by promulgating a model code sensitive to air
quality considerations.
g. Emission Density Zoning
This is covered in Paragraph a. Zoning above.
h. Stationary Air Pollution Control
The Bureau of Air Quality Control has full authority
to control emissions from existing sources, to control the introduction
of new sources (other than power plants) and to control changes in
industrial processes and materials that result in changes in emissions.
This agency, also the AQMP Planning Agency, should retain these responsibilities
i. Performance Standard Zoning
This is included under Paragraph a. Zoning above.
j. Control Travel
The selective banning of trucks and of automobiles in
specified areas would be undertaken by cities and counties in conformance
with detailed plans prepared under the auspices of RPC.
The restriction of total number of aircraft operations out of
Baltimore-Washington International Airport would be the responsibility
of the operators, Maryland DOT, State Aviation Administration.
k. Taxes
Taxation policies to control land development on the
urban fringe would be the responsibility of localities within legislative
limits established by Maryland State Legislature.
Differential rates of sales tax on larger automobiles as a means of
encouraging use of smaller vehicles would require authorization by
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State and administered by the Maryland Department of Taxation and
Revenue.
The imposition of increased levies on automobile ownership would
be achieved through local annual taxes on property.
1. Vehicle Emission Controls
Requirements for fitting emission control devices to
heavy duty vehicles could be either a Federal or State action. State
action is recommended since this is easier to achieve expeditiously.
m. Reviews
Review of public actions under Section 109 (J) of the
Federal Highway Act and under A-95 review procedures would lie with RPC.
n. Other Development Controls
Development districts and transfer of development rights
are measures that would be exercised by local governments within a frame-
work for action prepared under the auspices of RPC.
o. Urban Renewal
This measure must be initiated by local governments,
primarily the City governments, with support from State and Federal
agencies.
p. Public Participation
The Air Quality Task Force of RPC, suitably broadened,
restructured and with a redefinition of its mission would be the means
by which public participation in the implementation of the plan would be
achieved.
C. Basis for Assignment of Responsibilities
1. Zoning
The local governmental units have the legal authority and the
technical capacity to perform. Any other assignment of responsibility
would be politically unacceptable, calling for major redelegation of
police powers by the State of Maryland.
The task will be satisfactorily performed if the local units of
government will participate in the regional AQM planning procedures and
their elected officials are able to justify the actions to City and County
residents.
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2. Permits
This is not considered a separate measure, but would be applied as
an operating procedure to many of the types of control discussed here.
However, the fact must be recorded that any extension in applications,
permits and approvals required to run a business, develop land or operate
motor vehicles will be unpalatable to the public and will be resisted.
Permit systems will be required, but their success will depend on
keeping them simple, speedy, reduced to a minimum and easily understood
by the public.
3. Utility Extension
Current authority is vested in water and sewer authorities or
in Public Works Departments of city and county governments, but the
management structure is in both cases local . Any manipulation of these
elements as part of the AQM would therefore be effected through these
agencies.
New measures would be effective provided that they are not extreme
to the point of challenge on the grounds of legality.
4. Subdivision Regulations
The local planning agencies and their appointed boards and
commissions already have the legal authority and administrative machinery
to implement these measures and they are best qualified to retain this
responsibility.
The revised regulations to improve air quality will more readily be
implementable in the Baltimore AQMA if they are applied to the State as
a whole; development of State model regulations would facilitate imple-
mentation.
5. Building Codes
The local building inspectors administer the existing codes after
adoption by City Council or county council or commissioners. They have
the legal authority and the administrative machinery to administer
revised codes and are best qualified to retain this responsibility.
The revised codes will be more readily implementable in the Baltimore
Region if they are applied to the State as a whole; development of State
model codes would facilitate implementation.
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6. Emission Density Zoning
This is covered in Paragraph 1. Zoning above.
7. Stationary Air Pollution Source Control
The BAQC of Maryland State Department of Health and Mental
Hygiene has the legal authority and the administrative machinery to set
standards, monitor and control emissions and the responsibility should
remain with this agency.
The agency has ample authority to be effective and will retain this
authority given community and political support.
8. Performance Standard Zoning
This is covered in Paragraph 1. Zoning above.
9. Control of Travel
The RPC is the proper forum for planning and public discussion
of the details of a regional plan for selective regulation of truck and
automobile travel. It has no legal authority but it can provide a good
forum for discussion and agreement between local and regional interests.
The controls would be imposed by local government on City and county
streets. This is where the legal authority currently lies.
*v
Authority to restrict or regulate aircraft operations lies with the
operator of Baltimore-Washington International Airport, the State Aviation
Administration of Maryland DOT. No shift in this responsibility should
be considered. The feasibility of appropriate changes in operations would
hinge on two factors, the ability of the airlines to substitute larger
aircraft for smaller aircraft and Federal policy regarding distribution
of aircraft operations between the three Washington metropolitan airline
airports.
10. Taxes
Responsibility for the land taxes discussed in the plan lies
with local governments. The development changes to which tax revisions
are directed must be determined and approved by local governments and it
is proper that the implementative machinery also remain with local
government, through their taxation and assessor's offices.
11. Vehicle Emissions Controls
The measure will be partially effective in the Baltimore Region
if it is implemented at State level, and fully effective if it is imposed
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as a Federal requirement. The authority of both Federal and State
governments to impose such requirements exists. State regulation is
recommended on the grounds that this may be more easy to achieve.
12. Reviews
These are established procedures by the Federally designated
agency (RPC) and should not be changed.
13. Other Development Controls
Development districts and transfer of development rights lie in
areas of responsibility delegated to local governments by the State of
Maryland. There is no advantage to re-assigning those responsibilities.
14. Urban Renewal
Urban renewal is a function delegated to local government and no
advantage is seen in re-assigning these responsibilities.
This measure will be effective only if the major funding programs
of Federal and (to a lesser extent) State governments are continued.
15. Public Participation
RPC is already the primary forum for discussion and resolution
of regional problems and issues; its nature permits these discussions to
take place in a comprehensive context; lines of communication are already
very well established; RPC already has an action Air Quality Task Force.
In all respects, it is the appropriate level and agency to handle public
input and discussion of implementation, in conjunction with the AQMA
Planning Agency.
D. Organizational Relationships To Maintain Coordination
1. Organization Relationships Utilized in Preparation of Sample Plan
a. Technical Agencies
The principal technical agencies involved in preparing
the AQMA sample plan were:
Regional Planning Council
Maryland Department of Health and Mental Hygiene,
Bureau of Air Quality Control
Maryland Department of Transportation
Division of Systems Planning and Development
City of Baltimore
Department of City Planning
Interstate Division for Baltimore City
94
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These agencies provided data and references and reviewed study
progress and findings on a continuing basis through the study procedures.
b. Air Quality Task Force of RFC
This is a joint technical-citizen advisory group established
by RPC, prior to commencement of the AQMP activity, with membership from
disparate agencies, interests and local units of government from the
Baltimore Region.
It provides an excellent forum for discussion of plan elements with
industry, government and citizen groups, for the resolution of problems
and for testing public acceptability of various maintenance measures.
However, the level of coordination between counties required for the plan
preparation was not possible through this Task Force since not all counties
were represented at all meetings, and representatives had no authority
to speak for or commit their counties to a line of action.
c. Existing Institutional Relationships
Refer to Figure 3 showing existing relationships.
d. Pertinent Aspects of Existing Institutional Relationships
The AQ Task Force includes representation from all
listed principal technical agencies, including BAQC.
The AQ Task Force includes representation from all jurisdictions
in the region.
The AQ Task Force is organized as an advisory body to the RPC, the
agency with responsibility for comprehensive planning inclusive of land
use, transportation and public facility planning and for coordination of
the activities of the constituent local governments in the region. A
direct conduit between the Task Force and RPC assumes that RPC's activities
will be sensitive to air quality concerns and to the proceedings of the
Task Force.
The chart does not reflect on-going contacts and cooperation
between BAQC and virtually all of the technical agencies represented
on the chart.
The chart does not show BAQC participation in the major studies.
95
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2. Problems Encountered in Preparation of the Trial Plan
a. Coordination
Few problems. The cooperation of agencies was outstanding
and the existence of the AQ Task Force provided readymade machinery for
public input and coordination meetings.
b. Other
Time to complete the project.
3. Changes in Institutional Arrangements Recommended for Preparation
a. The AQ task force be assigned additional responsibility
for advice to BAQC in its planning program, sponsoring public meetings
at appropriate stages of the program and serving as the channel for
communication with the community through the study period.
b. If it is to serve this purpose, some enhancement of its
membership may be required, together with additional staff support from RPC.
III. Baseline Emissions Inventory
*
A. Baseline Year
1972 was the latest year for which a complete hydrocarbon and NO
X
emission inventory was available along with the required air quality
data. Furthermore, this was the baseline year for the EPA Transportation
Control Plan (TCP).
For particulates and sulfur dioxide, 1972 area source data and 1973
point source data were used. It may have been preferable to use the 1970
inventory, which would have been compatible with the SIP but such data
were not available.
B. Source of Emissions Data
All emission data were obtained from the Maryland BAQC, which was the
source for the TCP. The BAQC VMT data were obtained from a modification
of the regional planning council transportation study.
BAQC emission data were used in preference to NEDS data since comparison
showed the Maryland data to be more complete (NEDS files are being
updated by BAQC).
The BAQC transcribes pertinent information from their permit applications
onto computer tape, generating a file that identifies all sources of
97
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emissions in the entire state. An extract of this file for the AQMA was
obtained from the BAQC along with the appropriate file/field identifications.
There were over 10,000 point and area sources included in Baltimore AQCR
so relevant data were summarized. Certain criteria were used in making
the summaries. For example, not all of the 9,000 point sources could be
included in the dispersion models. For particulate matter, 100 point
sources with greater than 25 tons/year of emissions were used. Area sources
were delineated on the tape as discrete categories such as domestic,
commercial, vehicles, etc.
C. Geographic Location of Sources
All sources in the AQMA were considered without regard to location
for HC/0V relationship and projections. The same applied for nitrogen
J\
dioxide.
For particulates and sulfur dioxide, all point and area sources
were located. The magnetic tape obtained from the BAQC identified hori-
zontal and vertical coordinates of each stack.
D. Technical Assumptions about Existing and Future Emissions
Source Controls
All EPA regulations imposed by the TCP were assumed to be enforced
except gas rationing and LDV retrofit. In addition, a state regulation
prohibiting any new source of 100 tons/year or greater of any pollutant,
or any increase of all sources by the same amount was considered to be
effective.
In determining projected emissions for 1975 and 1985, all emissions
regulations were considered effective. This involved the use of EPA
regulations for automobiles, state regulations for particulates and sulfur
dioxide, and local regulations predominantly for sulfur in fuel limits.
The state regulations that were used were those in effect during the
course of the study that would regulate the amount of the emissions from
each source category.
E. Technical Assumptions about Emission Factors
EPA emission factors made available for this evaluation were used.
F. Problems and Suggested Solutions and Recommendations
The problem of reconciliation of the hydrocarbon inventory among
the interested participants was of some significance in this investigation.
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In the development of AQMPs early meetings should be held to discuss
differences and reach concensus.
IV. Emission Projections
Methodology similar to that described in EPA guideline documents
was used for projecting emissions from one base period to some future
period.
A. Methodology
Planning data from the Regional Development Plan were incorporated
into this study. In general, the following factors were used for direct
proportioning of data of the base period year to some future period:
power plants - FPC projected capabilities which were available until 1983
industrial processes - manufacturing employment (intensive)
fuel combustion/residential heating - number of dwelling units
fuel combustion/commercial and institutional - employment (intensive)
refuse disposal - population increase
transportation (cars, trucks) - vehicle miles travelled
The planning data from the RPD were delineated by regional planning
districts. ES converted the projections for the RPD areas to coincide
with the Maryland BAQC grid system. Since the emission inventory was
available for grid system, the land use planning projections had to be
made to 'fit' the existing data base for area emissions.
Changes in vehicle miles travelled were based on ddLd from the
MOOT. These data were stratified by RPD and were based on the General
Development Plan highway and transit systems with no controls or policy
changes in effect. The MOOT projections of VMT were derived from the Baltimore
Regional Environmental Impact Study (BRIES). This study developed models
for trip generators, mode choice, and traffic assignment based on the
RPC land use model forecasts. Among the outputs of the models were VMT
for each RPD stratified by highway type and by level of congestion for
1980 and 1995. Linear interpolation was used to obtain projected values
for 1977, 1980, and 1985.
Specifically for the projections of hydrocarbons the following
assumptions were used:
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• Gasoline storage and handling growth rates were projected at one
half the growth rate of VMT (in thousands of miles).
VMT 1977 - 3,255.90
Growth Rate = 3.62 percent per year
VMT 1980 = 3,622.04
Growth Rate =1.72 percent per year
VMT 1985 = 3,943.65
This projection assumed the continuation of the present trend toward
smaller cars and increased gasoline mileage.
• Power plant emissions would decrease because of the decrease in
generating capacity within the AQMA.
• No change was projected in hydrocarbon emissions from refuse disposal
because of the ban on open burning and control of incinerators,
• Diesel and shipping included, for 1977, 0.28 tons per peak period
for diesel highway vehicles and 0.92 for other diesel sources, Diesel
highway vehicles and 0.92 for other diesel sources. Diesel highway
vehicle emissions were projected at 1.1 times the growth rate in VMT
to reflect increased city bus service. Other sources were projected at
the growth rate of transportation employment, 1.2 percent per year.
• Growth in industrial process heating was based on growth of manu-
facturing employment, 0.5 percent per year.
• A reduction in dry cleaning establishment emissions resulted from
the regulation prohibiting the use of reactive solvents.
• Emissions from other solvent uses were projected on the basis of
growth in manufacturing employment.
• Miscellaneous gasoline engines were projected to grow at the same
rate as population, 1.52 percent per year.
• Aircraft operations would grow at a rate of 7.7 percent per year.
• VMT growth factors were obtained from transportation data provided
by the Maryland Department of Transportation (from BRIES).
B. Problems and Suggested Solutions
One of the fundamental problems in estimating future air quality
based on economic and land use projections is the assumed geographic
location of the new sources. In Baltimore a large quantity of particulate
emissions are generated from large industrial operations like the
Sparrows Point Plant of the Bethlehem Steel Corp. It is unlikely that a
two-fold increase in intensive employment at the Sparrows Point RPD
could result in a corresponding two-fold increase in particulate emissions
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from the steel plant. Although growth is anticipated at the Sparrows
Point Plant, the employment will likely occur in nonpolluting sources
that augment the basic steel manufacturing processes. It is suggested that
for those areas of the country where one single plant influences the air
quality, that these large industrial sources should be treated separately,
perhaps as power plants are in the fuel combustion category. Another
significant problem encountered in projecting air quality for particulates
was the handling of a large number of small sources in dispersion models.
One future procedure might involve the smearing of the small point sources
among the various grids (area sources) used in the study. Of course,
this would require assumption of the release height. Area sources for
example were assumed to have an emission release height of 10 meters.
When combining these less than 25 ton per year point sources and calling
these area sources, a stack height of perhaps 25 meters should be incor-
porated. The effect of including all, instead of one-third of the emissions
as was done in this trial plan, will be a better resolution in terms of
calibration of the dispersion models.
C. Recommendations
The methodology described in the guideline documents seems strictly
applicable to area type emission sources. Marginal errors are likely
when projecting point source emissions from one base period year to a
future period. Instead of basing the point source emissions on various
economic and land use planning parameters, it is suggested that a statistical
sampling of large industrial sources to determine what each individual
source plans are for the 10-year period ending in 1985. In heavy industry
AQMAs, this procedure is likely to be significantly more accurate than
projecting emissions with the use of economic parameters. One of the
reasons why power plants were excluded from the projection methodology
used for the industrial processes and other sources categories was they
constitute a significant portion of emission in an AQMA. In addition, power
companies generally know what future power requirements will be. Power
companies have to know this because it takes approximately 10 years from
the time of initial conception to having an electric generator unit built
and going on line. Similarly, large industrial processes will likely
know what their expansion plans are for the next 10-year period.
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V. Establishment of Baseline Air Quality
A. Baseline Year
Engineering-Science used baseline air quality data that coincided
with the baseline emission inventory data (the 1972 and 1973 period).
In the air quality control region there were about 30 monitoring stations
that recorded data for particulates, sulfur dioxide, carbon monoxide and
oxidant.
B. Time Compatibility of Baseline Quality and Emissions
Since Engineering-Science used various air pollution dispersion
models to calculate the future air quality for inert pollutants in the
AQMA, baseline air quality data that coincided with the baseline emission
data were essential for calibrating. The models were set in the calibration
mode in an attempt to validate the dispersion models for the area as well
as compute a calibration factor that would relate emissions to air quality
more accurately. For particulate matter and using only 1/3 of the
emissions in the entire AQCR, Engineering-Science obtained a correlation
factor of 0.75. This would indicate that the model was fairly accurate
in predicting air quality from these sources but probably, because of
the incomplete emission data base, was not precisely predicting the values
measured in the field. Some engineering judgment is required to relate the
computer predicted values to the measured air quality data.
C. Source of Air Quality Data
All air quality data for the period 1972 and 1973 were obtained from
the Maryland Bureau of Air Quality Control.
D. Accuracy and Representativeness of Data
The stations have been located fairly uniformly throughout the
congested areas of the AQCR and quite likely reflect the hotspots of
higher pollution concentrations. For the pollutants measured the air quality
data was considered to be representative as well as accurate for air
quality in the Baltimore region. Standard sampling methods had been used
to collect the data. In addition, a telemetering system was used by the
Maryland Bureau of Air Quality using automatic sampling instruments that
would provide continuous concentrations of the various pollutants.
No statistical analyses were conducted of the air quality data in the
region. However, the number of samples taken would indicate that a
102
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sufficient population had been obtained that statistically represented the
air quality data for the region. Most of the data from the years 1972
and 1973 had already been incorporated into the SAROAD data bank.
E. Estimation of Air Quality from Monitoring Data
Calibration of the dispersion model for particulates showed the y-
3
intercept background to be recorded at 41 .8 ug/m . This y-intercept
represented that portion of emissions in the area not accounted for by the
model. Air quality data from rural areas of the state indicated a back-
ground concentration of particulate matter of about 35-40 yg/m .
VI. Air Quality Projections to 1985
A. Methods Considered
To estimate pollution levels in the year 1985, Engineering-Science
considered first the use of a proportional model based on predicted emissions
for the year 1985. By comparing existing baseline emissions and air
quality, a simple roll-back roll-foward model could predict future air
quality in relation to estimated emissions. Such a model is completely
adequate for predicting hydrocarbon and nitrogen dioxide levels. For
these air contaminants, longer term secondary reactions in the atmosphere
are considered of paramount importanct; less significance is given to the
spatial distribution of sources. Engineering-Science did consider temporal
variations important, e.g., the 6 to 9 A.M. peak which may be important
in estimating compliance with oxidant standards.
For suspended particulate and sulfur dioxide estimations, spatial
distributions were considered to be extremely important. Therefore,
a second step of modeling was required beyond that of estimating emissions
to the year 1985. For this modeling effort. Engineering-Science selected
the AQDM of EPA.
B. Methods Used
The AQDM has a feature that allows the planner to determine the
impact on a given receptor point of any source in the AQMA. Such a model
therefore offered the potential for determining the effectiveness of
various control measures.
C. Estimation of Future Air Quality
For hydrocarbons and nitrogen dioxide, the 6 to 9 A.M. emissions were
projected for 1977, 1980 and 1985. Air quality (oxidant) was assumed
to be proportional to hydrocarbon emissions using appendix J based on the
1973 baseline relationship.
103
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For suspended participates and sulfur dioxide, emissions were pro-
jected for 1977, 1980 and 1985 and air quality levels were predicted by
the AQDM model for 1977 and 1985. The 1980 air quality levels were
bracketed by the 1977 and 1985 emission levels so no computer run was
deemed necessary.
VII. Selection of Maintenance Strategies
A. Effect of SIP Controls on the Sources and Source Categories
with Regard to Attainment/Maintenance
In the case of particulates and sulfur dioxides, all SIP regulations
and industrial compliance schedules were assumed to be met by 1977.
In the case of HC, the TCP was assumed to be followed completely with the
exception of gasoline rationing and LDV retrofit.
B. Identification of Sources or Source Categories That Would Cause
the National Air Quality Standards to be Exceeded
In preparing the emission inventories for all pollutants, the potential
sources were divided into several source categories such as residential
heating, commercial heating, industrial heating, power generations,
industrial processes, refuse disposal and transportation. For the hydro-
carbon inventory, a further breakdown was provided for the transportation
sources. It was assumed that all hydrocarbon (oxidant) and nitrogen
dioxide emissions had equal impact on air quality regardless of location
and stack height. In the case of particulates and sulfur dioxide, the
computer model predicted ground level concentrations that would be due
to various source categories.
Air quality levels were predicted first without considering the need
for maintenance measures. All source categories were listed, their contri-
bution to future air quality identified, and the available potential
control measure for those sources listed without regard to feasibility,
acceptability, or impact.
C. Selection of Maintenance Strategies
The following basic types of control measures were considered for
maintaining NAAQS:
• modify demand for the product
• modify raw materials
104
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• modify production process,
• modify product output,
• modify residual effluent,
• modify assimilative capacity of the atmosphere,
• modify spatial and temporal source distribution.
Engineering-Science, Inc. utilized the "Residual Environmental Quality
Management" (REQM)* system approach to systematically itemize and evaluate
control measures. The effectiveness of each control measure was considered
in terms of its range of effectiveness, its percentage reduction in
overall emissions, and its improvement in air quality (in the case of
particulates). The measures were considered independently for the first
analysis. Potential control measures were listed and ranked subjectively
in a matrix by several criteria such as effectiveness, timing, acceptability
and so forth. The ranking of control measures was accomplished by having
an air pollution task force of the Baltimore Regional Plan Commission act
as a, sounding board to the Engineering-Science draft.
From the sample matrix (Figure 4), one can see that the following
factors were considered in selecting a combination of control measures which
constitute an AQMP strategy for each pollutant.
• policy instrument to implement
• range of effectiveness
• percent emission reduction
• improvement in air quality
• direct costs
• administrative costs
• social costs
• administrative considerations
flexibility
application of control
• timing considerations
years before implementation
years before effectiveness realized
• political considerations
• legal considerations
*
For example, see: Bower, Blair T. and Basta, Daniel J. Residuals-Environ-
mental Quality Management: Applying the Concept, Baltimore, Maryland. Johns
Hopkins Center for Metropolitan Planning and Research, October 1973, p. 12.
105
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• environmental effect
• public responsiveness
When example maintenance strategies were being developed, consideration
was given to the duplication, overlap or variance of the control measures
as applied together and air quality reductions (effectiveness) were
modified accordingly.
Several notations were used in the matrix for rating environmental,
social, economic, temporal and political criteria. The symbols and
numerical notations for the most part are self-explanatory. One exception
may be the column entitles Public Responsiveness; the numerical entries
represent the number of responses for, or in opposition to, a particular
control measure. These responses were recorded at meetings of the Air
Quality Task Force. Not all members responded to each measure and all
groups in the BMAQMA were not equally represented. The numbers in the
public responsiveness spaces should be viewed accordingly. More important,
perhaps than these numbers were the comments recorded at the meetings
reflecting the concerns, questions and reactions of the group toward the
measures. Intermedia environmental effects were divided into five sub-
categories; positive effects resulting from a control measure were noted
with the symbol X, negative effects with a minus symbol (-). Where
there were no effects the space remained blank.
A series of four meetings was held with the Air Quality Task Force
during the course of development of the example plan. At each meeting the
latest version of the control measure matrices was distributed to the
panel for discussion and comment. In the final version, it is believed
that a new concensus had been reached for each entry.
D. Comments
The procedure for the selection of control measures worked well.
It starts by assuming all source categories may be important and all control
measures may be equally important. The procedure was developed by EPA
Washington Environmental Research Center (WERC) and is highly recommended
for use in AQMP development.
107
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VIII. Legal Authority
As was shown in Figure 4, the legislative requirements for each
control measure considered were examined to determine the existence of
legal precedent and the need for new legislation.
Legal precedent, both in the form of air pollution control and
prevention of a general nuisance, exists to regulate emissions from the
fugitive dust sources, New, specific rules will have to be formulated
and approved.
Legal implications of the energy conservation measures include the
limitation on authority of local authorities; however, there is no reason
to consider these measures legally not implementable. The most difficult
aspect is in enforcement. In actual operation these measures will finally
respond only to the economic advantage of energy conservation brought
on by increased fuel costs.
Land use measures are currently within the purview of local and
regional zoning authorities, and have not been used for air quality
management per se in the Baltimore region or in the State of Maryland.
Such use will require regional coordination, local regulation, and may
also require state enabling legislation as deemed appropriate by the
State's Attorney General.
The central legal issue raised by the measure requiring installation of
emission control devices on heavy duty vehicles, and the measure requiring
modification of vehicle tire and brake specifications, is that of the
proper level of legal authority. State regulations for emission control
on all licensed trucks in Maryland could be implemented. But because
the Baltimore region lies within a heavily travelled truck corridor and
is close to other states, Federal support for the regulations would be
required if the measure is to be effective. Otherwise, non-conformance
on the part of out-of-state vehicles would render the measure of limited
effectiveness.
108
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SUMMARY OF BALTIMORE AQMSA
POLLUTANT: Total Suspended Particulate (TSP)
3
NAAQ STANDARD: in pg/nT
ANNUAL
24 HR.
EPA (Geometric mean) : 60 ~ 150
Maryland (arithmetic mean) : 75/65(Serious/More Adverse) 160/140(Serious/More
o Adverse)
CURRENT AIR QUALITY, 1972 & 1973: 99 vg/m , Annual
328 ug/mV 24 hr. max.; second highest
EXPECTED AIR QUALITY IN 1975/1977: Same as 1972 & 1973 _ _
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD BY 1975/1977: 39%
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
Measures to control fugitive dust:
1. Control construction sites
2. Control open bodied vehicles
3. Control deposition on roads
4. Modify tire and brake design wear
Measures to reduce energy consumption:
" 1. Improve maintenance of heating systems
2. Improve furnace design
3. Improve building insulation
4. Control room temperatures
Land use planning measures:
1. Exclude new sources from hot spots
2. Change existing land use
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
The control of fugitive dust with the first 3 control measures are
implemented by the local control agencies through City or county ordinances
modifying tire and brake wear design will require design specifications for
greater durability to be implemented at the Federal level. The Department
of Transportation would probably be heavily involved but EPA would need
to coordinate such efforts.
Local agencies would have to be involved in the improvement of
maintenance on heating systems and on improvements in building insulation.
To improve furnace design will require coordination of private and
governmental agencies such as the Building Research Advisory Board/
Federal Construction Council of the National Academy of Sciences.
Controlling room temperature will require all levels of government
and private persons to coordinate.
Local zoning agencies will have to control new sources and reclassify
existing land uses.
109
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SUMMARY OF BALTIMORE AQMSA
POLLUTANT: CO
NAAQ STANDARD:
CURRENT AIR QUALITY:
EXPECTED AIR QUALITY IN 1975/1977:
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD BY 1975/1977:
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
Carbon monoxide was not included in the example plan.
A preliminary analysis based on existing air
quality and emission inventory indicated that
the future carbon monoxide levels would not exceed
the standards and therefore should not be considered
in the maintenance program.
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SUMMARY OF BALTIMORE AQMSA
POLLUTANT: N0x
NAAQ STANDARD: 100 yg/m annual average
CURRENT AIR QUALITY, 1972 & 1973: 117 ug/m3 AAM
EXPECTED AIR QUALITY IN 1975/1977: 104 yg/m3 AAM, By 1980 and 1985 emissions
are expected to be below the level required to maintain the AAQS.
PERCENT REDUCTION NEEDED TO ATTAIN STANDARD BY 1975/1977: 0
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
None Recommended.
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
The Federal controls of motor vehicles and regulations of the State
of Maryland are adequate to maintain AAQS.
Ill
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SUMMARY OF BALTIMORE AQMSA
POLLUTANT: S0x
NAAQ STANDARD: in yg/m3
EPA MARYLAND
Serious More Adverse
ANNUAL 80 79 39
24 hr. 365 262 131
3 hr. 1300 525 262
CURRENT AIR QUALITY, 1972 & 1973: Annua1--37 yg/m3; 24 hr. max.—131 yg/m3
EXPECTED AIR QUALITY IN 1975/1977: Less than 1972/73. Projected S02 emissions
inventory shows a net reduction of S02 of 35% by 1980 and 31% by 1985.
PERCENT REDUCTION NEEDED TO ATTAIN STANDARD BY 1975: No additional reduction
is necessary
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
None are recommended.
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
The State of Maryland Bureau of Air Quality Control has sufficient
sulfur-in-fuel regulations that apply to the AQMA.
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SUMMARY OF BALTIMORE AQMSA
POLLUTANT: HC/Photochemical Oxidants
o
NAAQ STANDARD: 160yg/m (1-hr, max.; not to be exceeded more than once/yr.)
CURRENT AIR QUALITY, 1972 & 1973: Highest Hrly ave. 0.21 ppm; Next highest 0.21('72)
Highese Hrly ave. 0.23 ppm; Next highest 0.20('73)
EXPECTED AIR QUALITY IN 1975/1977: Highest Hourly Ave. 0.09 ppm
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD BY 1975/1977: 70% HC emissions
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
1. Improve emission controls on heavy duty vehicles.
2. Reduce use of hydrocarbon solvents.
INTERGOVERNMENTAL RELATIONSHIPS REQUESTED
1. The control of emissions from heavy duty vehicles will probably
^require Federal action for nation-wide coverage and uniformity. However,
the State of Maryland can implement this program (retrofit). Therefore
both agencies must cooperate in this effort.
2. The ban on reduction of solvent manufacturing will require
cooperation from Federal, State, Regional and local government agencies. In
addition private interest groups such as associations and unions should
also be consulted.
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Chapter V
DENVER TRIAL AIR QUALITY MAINTENANCE PLAN
I. Denver AQMSA Characteristics
The Denver Front Range Air Quality Maintenance Study Area includes the
Metropolitan Denver Air Quality Control Region (AQCR), containing Adams,
Arapahoe, Boulder, Clear Creek, Denver, Douglas, Gilpin, and Jefferson
Counties, and Larimer and Weld Counties of the Pawnee AQCR. The AQMSA
extends eastward from the Continental Divide into the plains, with the
major urban centers located along the foothills of the Rockies. The
greater Denver area lies within the South Platte River drainage basin
with the City of Denver having an elevation in excess of 5,000 feet above
sea level. Roughly 20 miles to the west the mountains reach a height of
8,000 feet above Denver; to the southwest, the land rises more gradually
along the South Platte River valley. The principal areas of concern for
the development of the AQMP are the population centers along the eastern
foothills. In addition to the City of Denver, the AQMSA includes the major
urban centers of Boulder, Longmont, and Broomfield in Boulder County,
Fort Collins and Loveland in Larimer County, Greeley in Weld County, and
Brighton in Adams County.
The pollutants designated to be of interest in the AQMSA are total
suspended particulates, carbon monoxide, nitrogen oxides, and photo-
chemical oxidants. The particulate problem is basically a result of the
arid conditions of the region which allow for entrainment and subsequent
transport of particulates during windy conditions. Manmade sources of
fugitive dust include the following: unpaved roads; sand on paved roads;
agriculture; land development; residential, industrial, and commerical
construction; highway construction; aggregate storage; cattle feedlots; and
quarrying, mining, and tailings.
The other pollutants of interest, CO, NO , and photochemical oxidants,
/\
result from the heavy use of motor vehicles in the Denver AQMSA. The
Denver metropolitan area is characterized by a high growth rate of motor
vehicles (5.2 percent per year) and the highest per capita automobile
registration in the nation, one automobile for every 1.5 persons. The
115
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motor vehicle pollutant problem for the AQMSA is exacerbated by the high
elevation of the region, since operating parameters of gasoline-powered
engines and the effectiveness of control devices are functions of ambient
air density.
The topography of the region also adds to the high ambient concentrations.
Under light, nighttime wind conditions, surface air, made relatively more
dense by radiational cooling, drains down the river valley toward the
northeast and lower elevations. This cold air drainage apparently stops
just beyond the suburbs and the shallow air mass, which has accumulated
pollutants from city sources, is frequently brought back by a wind direction
reversal around noon. Under a light wind regime, crossing and recrossing
of the pollutant source by the same air mass may continue for several
days, thus leading to local accumulation of pollutants.
An understanding of socioeconomic characteristics of the AQMSA provides
important criteria for evaluating the potential effectiveness and applica-
bility of control measures, and for selection of measures for final plan
development. The Denver region's population has grown at a fast pace
in the past three decades, increasing from 3 to 4.6 percent per year.
Population is decreasing in the central city as urban sprawl moves to the
north and south along the front range. The suburban communities have
accounted for approximately 80 percent of the area's population increase
between 1950 and 1970. This trend is expected to continue with the per-
centage of the total metropolitan Denver population residing in Denver
County going from 65 percent in 1950 to 25 percent in the year 2000.
Growth in Larimer and Weld Counties has been even more dramatic, es-
pecially for their major cities. While the growth rate has been fairly
consistent in the past, the recent trend has been an acceleration of growth.
Between 1960 and 1970 Fort Collins had a 73.2 percent rate of increase,
Loveland had a 66.6 percent increase, and Greeley had an increase of 47.8
percent. It should be noted that the two cities that increased the most
between 1960 and 1970 were both located in Larimer County which itself under-
went a growth of 68.5 percent over the previous decade. Weld County, as
a whole, had a growth rate of only 23.4 percent during the same time period,
which is less than that for the entire State and indicates a slow rate of
increase in population in the rural districts.
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Residence patterns are crucial in regional development planning, public
transit system development and selective transportation control measures
designed to alter travel patterns to attain a shift in modal mix that both
meets transit needs and minimizes air pollution and other environmental
degradation. Low density and dispersed residential development patterns
characterizing the regions are expected to continue with circumferential
growth occurring from city centers and radial growth along transportation
corridors. Other housing trends, such as a declining number of persons per
housing unit and popularity of low density residences, are expected to
continue.
Approximately two-thirds of the employment growth between 1964 and 1970
occurred in Denver County, while about 95 percent of the population growth
was in surrounding counties. This indicates an inward work trip transpor-
tation flow for the region. Projected employment density patterns indicate
that employment will continue to be concentrated in the core region,
thus requiring continued commuter traffic. Some services have followed the
residential development in the suburbs, but as yet no proliferation of
industrial development is apparent.
Based on a census week in 1970, only 4.2 percent of the workers in
the Denver SMSA traveled to work on public transportation. The majority
of the workers, 74.8 percent, drove private automobiles while 10.4 percent
were passengers in private autos, and 8.5 percent walked to or from their
place of work.
II. Intergovernmental Cooperation
A. Agencies Contacted
1. State
Colorado Air Pollution Control Commission - The duties of the
Colorado Air Pollution Control Commission include the development and
maintenance of a comprehensive program for prevention, control and abate-
ment of air pollution throughout the entire state, including a program for
control of emissions from all significant sources of air pollution; the
promulgation of ambient air goals for every portion of the state; the
adoption and promulgation of ambient air quality standards and emission
117
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control regulations; the receipt of and, at its discretion, the hearing and
determination of violations; the receipt of applications for variances and,
at its discretion, the review of any variance order or determination of
the variance board to which such applications may have been transmitted.
The Commission must also hold a joint meeting with the State Board of
Health during the month of October of each year in order to hear public
comment on air pollution problems within the state and to answer questions
from the public concerning the administration and enforcement of promulgated
rules and regulations.
Colorado Air Pollution Control Division -- The Division is
empowered to conduct studies and research with respect to air pollution,
the control, abatement, or prevention thereof; determine if the ambient
air standards are being violated in any area of the state; enter and inspect
any property, premise, or place for the purpose of investigating actual,
suspected, or potential source of air pollution; furnish technical advice
and services; notify any affected jurisdiction of standards that are not
being met; and issue contaminant emission notices. The Division also
has the authority to enforce compliance with the promulgated emission
control regulations.
The Department of Health, in which the Air Pollution Control Division
was established, is designated as the "state agency" for all purposes of
the Federal Clean Air Act, as amended, and regulations promulgated under
said act. The Department of Health accepts and supervises the administration
of loans and grants from the Federal government (and from other sources,
public or private) that are received by the state for air pollution control
purposes.
Colorado Division of Planning - The Division of Planning serves as
an advisory and coordinating agency with no regulatory authority. It was
created within the Department of Local Affairs to, among other things,
prepare planning "for meeting problems in the areas of highways, air and
water pollution, water supplies, sewage disposal, recreation, urban and
nonurban growth, transportation, education, industrial and commercial
development, and related matters."
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The duties of the Division of Planning are primarily those of assistance
in the gathering and using of data. The population statistics, estimates,
and projections prepared, maintained, and interpreted by the Division of
Planning are designated as the official data. The Division of Planning
must prepare and periodically revise an inventory of the public and
private natural resources, major public and private works, and other
facilities and assemble information deemed to be important for the planning
and development activities of the state.
The Division of Planning's primary input to the development and imple-
mentation of an air quality maintenance plan, aside from the use of its
data, is the use of its function as the A-95 clearinghouse. The Division
of Planning is also the lead state agency in HUD 701 planning.
All master or zoning plans, prepared by any region, county, or district
planning commission, must be submitted to the Division of Planning for
review and comment before adoption or certification. The planning commission
submitting such plans is not bound by such advice or criticism.
Colorado Land Use Commission - The Colorado Land Use Commission was
established within the Office of the Governor to provide the leadership
necessary to encourage planned and orderly use development. For the
past three years the Land Use Commission has been working to identify a
program that will provide a framework and a process whereby the State of
Colorado and its political subdivisions can guide future development.
This has culminated in a report entitled, "A Land Use Program for Colorado,"
which is briefly discussed below.
Of particular interest to the development of an air quality maintenance
plan is the program outlined for the environment. The report recommends
a three-pronged approach to the achievement of environmental goals.
As a first element, environmental inventories would be prepared and plans
made that reflect the location of significant natural amenities and
ecosystems, as well as scenic, cultural, and historic resources. The
identification of these critical environmental areas will, in turn, guide
the administration of land use and environmental regulatory programs,
including a new-development permit system.
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This permit system would apply to all developments located in areas
of critical environmental concern and to proposed activities of regional
or State significance. The granting of a permit will be the function of
regional permit boards within the five regions of the State, with appeals
to a State Permit Review Board. The criteria for determining when a
permit is needed, whether it should be granted, and what restrictions or
conditions should be attached to it will thus be responsive to regional
differences. Permit decisions will reflect a comprehensive review of the
proposed development's effects on the environment, public services, and
existing public infrastructure. Public hearings on permits will be conducted
at the regional level, with an opportunity for citizen participation. This
permit system, along with strengthening of local land-use controls, and
improvements in state regulation of environmental quality, make up the
second element in the recommended environmental strategy.
The third element looks toward the creation of a Special Land Agency,
a state-owned corporation empowered to acquire environmentally critical
lands, or partial interests in these lands, such as scenic easements, and
to help provide accessible recreational opportunities for Coloradans. In
urban and urbanizing areas, the Commission suggests the creation of linear
parks along rivers and streams or other environmental corridors. Such
parks would preserve both shorelines and other environmental qualities.
2. Regional
Joint Regional Planning Program - Denver SMSA - The responsible
agency for comprehensive planning in the Denver SMSA is the Denver Regional
Council of Governments (DRCOG). The responsibility for continuing,
comprehensive, and cooperative (3-C) transportation planning rests with the
Joint Regional Planning Program (JRPP). The JRPP is a cooperative trans-
portation planning effort carried out jointly by the DRCOG, the Regional
Transportation District (RTD), and the Colorado Division of Highways (CDH).
Consistent with its role as intergovernmental coordinator for the
SMSA region, the DRCOG coordinates the joint planning efforts with federal,
state and local units and agencies of governments. In carrying out this
role, the DRCOG makes application for federal assistance to the planning
program, coordinates the planning program with the planning for all modes
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of transportation, coordinates the needs and findings of the planning
program with units of local government, coordinates with state planning
efforts, and, upon adoption, certifies land use and public transportation
plans to the federal government. General policy guidelines are established
cooperatively by the policy bodies of each agency. The staffs of the
DRCOG, the RTD, and the CDH have responsibility for management and control
of the planning elements and tasks assigned to their respective agencies.
Specific planning responsibilities of the agencies are outlined below.
DRCQG Activities - Those activities of the DRCOG that are instrumental
in the JRPP are detailed below:
Comprehensive Planning Information - Preparation of regional goals
and objectives, estimates and projections of population counts and charac-
teristics, socioeconomic/employment information, land use, identification
of natural and man-made physical characteristics influencing regional
development, identification and projection of community facilities and
service requirements, and preparation of land development criteria and
standards.
Urban Development Plans - Preparation, analysis and evaluation of
regional development plans based upon alternative development policies.
Joint Development with RTD and CDH of Transportation Plans - Preparation
of transportation information, development of travel pattern data, prepara-
tion and evaluation of transportation models, preparation of transportation
system criteria and standards, forecasts of regional travel demand,
preparation and testing of alternative transportation corridors, and
evaluation and selection of highway and public transportation plans.
Continuing Development of Short and Long Range Plans and Planning
Information - Continuing development and analysis of indicators of regional
growth and change; coordination of planning program findings with public
transportation operators and with the Colorado Division of Highways;
monitoring of public action programs that may affect the planning program
and development of short-range highway transportations plans that, combined
with short-range public transportation improvements, will tend to raise the
overall level of transportation service in the region.
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RTD Activities - These activities are listed below:
Joint Development with DRCOG and CDH of Transportation Plans -
Preparation of public transportation information, travel pattern data,
transportation models, transportation system criteria and standards,
regional travel demand, alternative transportation corridors, and evalua-
tion and selection of public transportation plans.
Detailed Long-Range Public Transportation System Plans - Estimates
of system usage, line and station location studies, preliminary vehicle
design, preparation of operating plans, preliminary engineering studies,
detailed cost benefit analysis, preparation of capital and operating cost
estimates, and architectural and urban design studies.
Implementation Program - Preparation of financial program and
construction phasing, examination of organizational and legislative programs,
and preparation of a step-by-step implementation program.
Short-Range Improvement Programs - Analysis of bus ridership
pattern, analysis of route structure, identification of role for local
transit service, analyzing deficiencies in service, and preparation
^fc
of a short-range public transportation improvement program.
Demonstration Programs - Identification, development and implementation
of programs that will aid in ultimate development of the long-range public
transportation plan and serve to demonstrate that modern public transporta-
tion is a viable alternative to automobile travel.
Public Education Program - Development and implementation of a
community interaction and information program to ensure that any new
public transportation plan is responsive to;the needs of the entire community
and to provide for effective citizen participation in the public transporta-
tion planning process.
Community Approval - Sponsorship of public hearings, modification of
public transportation plans as required, and submission of a plan for the
development, maintenance, and operation of a public transportation system
to the voters of the District.
Implementation of Plan - Upon favorable approval of the electorate and
sale of authorized bonds, unification and operation of existing public
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transportation systems as well as construction of new facilities in
accordance with the plan.
Continuing Development of Short and Long Range Plans - Together with
the Council of Governments, continuing preparation of short and long
range plans to meet public transportation needs and requirements of the
region.
CDH Activities - The activities of the CDH, relating to the Joint
Regional Planning Program, are given below:
Joint Development with DRCOG and RTD of Transportation Plans -
Preparation of highway transportation information, travel pattern data,
transportation models, transportation system criteria and standards,
regional travel demand, alternative transportation corridors, and evaluation
and selection of highway transportation plans.
Continuing Development of Short and Long Range Plans - Contributing
to preparation of short and long range plans to meet highway transportation
needs and requirements of the region.
Implementation of Highway Plans - Budgeting, engineering and construc-
tion of highway improvements resulting from cooperative planning program.
Mechanism for Planning Coordination - There exists a Memorandum of
Agreement between the DRCOG, the RTD, and the CDH, signed on April 16, 1971,
and currently in effect. The DRCOG, as the designated areawide planning
agency and coordinating member of the JRPP, has the responsibility to
administer and coordinate all transit planning funds. The DRCOG also has
the authority to contract with other agencies to provide and administer
planning monies. HUD 701 planning, A-95 review, and Sections 201, 208,
and 303 water quality planning are some of the functions the DRCOG is
supposed to perform in the Denver SMSA.
In order to provide continuing liaison between federal, state, and
local agencies, and provide for effective input of their expertise,
concerns and desires, the JRPP has designated the DRCOG's Regional Planning
Advisory Committee (RPAC) as a technical advisory committee to the trans-
portation planning process. Voting members of the RPAC represent the
cities and counties of the region. While membership is not limited to
particular professional disciplines, members are usually city planners or
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engineers. Also included on the committee, in a non-voting, associate
capacity, are representatives of the Colorado Division of Planning, the
Colorado Land Use Commission, the CDH, the RTD, the Federal Highway
Administration, the Department of Housing, the Bureau of Outdoor Recreation,
and the Federal Aviation Administration. Meetings of the RPAC are held
at least monthly. While the transit operating agencies of the region are
not directly represented on the RPAC, representation is provided through the
Committee's two members from the City and County of Denver.
Larimer-Weld Regional Planning Commission - The only regional
planning commission that has been created in the Denver AQMSA, other than
the DRCOG, is the Larimer-Weld Regional Planning Commission. The Larimer-
Weld RPC has developed and adopted a master plan that states the goals and
policies for the Larimer-Weld region and provides the development plan
for these two counties. This plan is not deemed to be an official advisory
plan unless adopted by the planning commission of the municipality or county
affected. HUD 701 planning and A-95 review are two of the responsibilities
of the commission.
Local Pollution Control Authorities - Colorado has a very strong
interest in maintaining control over local problems in the jurisdiction
of interest. As much as possible, initial regulatory control is placed
in the local authorities with final control by the state only if necessary.
The Colorado Air Pollution Control Act delegates to the local governmental
agencies the authority to enforce the rules and regulations adopted by
the Air Pollution Control Commission.
The local air pollution control authorities in the Denver Air Quality
Maintenance Study Area, none of which were contacted during this study,
are 1isted below:
County Agency Title Location
Adams Tri-County District Health Department Englewood
Arapahoe Tri-County District Health Department Englewood
Boulder Boulder City-County Health Department Boulder
Clear Creek
Denver Denver Department of Health and Hospitals Denver
Denver Building Department Denver
Douglas Tri-County District Health Department Englewood
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County Agency Title Location
Gil pin
Jefferson Jefferson County Health Department Lakewood
Larimer Larimer County Health Department Fort Collins
Weld Weld County Health Department Greeley
Local Planning Commissions - All counties in Colorado must have,
and any municipality may have, a planning commission. Any such planning
commission must prepare a comprehensive plan (master plan) for its jurisdic-
tion. These plans are officially adopted (after public hearings), and must
be considered before decisions are made about certain types of facilities.
Generally, the master plan has little legal effect on private actions as
there is no requirement that zoning be in accordance with the community
master plan. In Weld County, at present, it is the policy to rely on
the comprehensive plan in zoning decisions. Municipal, but not county,
planning commissions must also review the locations of public thoroughfares,
utilities and open spaces.
B. Responsibilities of Agencies
1. AQMP Preparation
The inputs of the various agencies to the maintenance plan pre-
paration follow naturally from their role in the region as described
above. Table 1 presents a matrix that summarizes these inputs.
2. AQMP Implementation
The plan implementation responsibilities of the various agencies
are also a direct result of their role in the region and the available
legal, organizational structure. The maintenance plan for the Denver
AQMA relies primarily upon the authority vested in the Air Pollution Control
Commission and the Land Use Commission as described below.
3. Responsibility Assignments — In the preparation of the Denver Example
AQMP, the existing infrastructure was examined to determine the path of
least resistance for generating a feasible cooperative mechanism.
The first item considered was enabling legislation. In Colorado
there are two primary legislative mandates for use in maintenance planning.
The first is the Air Pollution Control Act of 1970 which established the
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Air Pollution Control Commission. The second is Colorado House Bill 1041
which amends previous land use law. Colorado law also provides for the
adoption, by municipal planning commissions, of regulations to govern the
subdivision of land. The statute contains a list of features that may
be regulated, including "light and air." The RTD is specifically provided
for in legislation and has relatively broad powers to both plan and
implement a program of mass transportation, including authority to tax,
incur debts, and issue bonds. Thus, a search of existing legislation
serves as the primary means of identifying agency responsibility.
A second source of agency identification is examination of what has
already been done in terms of socioeconomic projection, air quality data
collection, and other specific programs. This serves to identify technical
ability to perform the task. In the case of Denver, land use, highway,
and transportation plans are already available, though in ever changing
form, through the JRPP. The JRPP is a joint effort among DRC06, the CDH,
and the RTD. In doing their planning, population and employment projections
are generated. Land use planning on a macroscale is already available
through the Land Use Commission.
In addition to their roles in preparing comprehensive plans, both
DRCOG and the Larimer-Weld COG serve as forums for discussion. As voluntary
associations of county governments they have no legal authority per se. They
do have, however, political influence resulting from the councils' member-
ships. In short, while COG's don't exhibit legally binding authority,
they do have the potential for exercising significant political influence.
C. Recommended Organizational Relationships
For the Denver AQMSA, it is recommended that the Air Pollution Control
Commission and the Land Use Commission undertake the development and imple-
mentation of the maintenance plan as a joint venture. This appears to be
the most suitable organizational structure, given the land use law as well
as the Air Pollution Control Act. Each of these pieces of legislation
gives large amounts of power to the respective agencies. The joint venture
is to be accomplished by the exchange of information between the two groups.
Further, it is suggested that periodic meetings be established where both
commissions are represented. This will allow for any problem areas to be
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resolved. Obviously, the other respective responsibilities of the commissions
will change in no way. This organizational structure increases the work
load of each body, but only by one-half of what it would be if sole
responsibility were delegated to one commission.
D. Problems and Suggested Solutions
Several obstacles may hinder the creation of an adequate intergovern-
mental cooperation mechanism. The first arises because of the nature of
air quality maintenance. Maintenance, perhaps even more than air quality
attainment, must be coordinated with many other social goals. Given the
fact that air quality maintenance is perpetual in nature, its objectives
must be coordinated with these other goals. For this reason, land use and
transportation planning, at least a priori, are good candidates as mainte-
nance measures. Their use as a strategy allows for simultaneous movement
toward a number of objectives. The major problem arising from their use
is the necessity for including additional agencies in maintenance plan
development. The solution to this problem is identification of key bodies
for accomplishing each objective and coordination from the top of the
hierarchical structure. This was the approach used in the example plan
for the Denver AQMSA.
The second problem area is really at the heart of maintenance plan
development. Air quality maintenance, while not a new concept, is an
unknown as far as institutionalization is concerned. At present there exist
no laws or bodies with the explicit function of providing for the mainte-
nance of air quality. Thus, the problem of intergovernmental cooperation
is compounded. Existing legislation must be looked at, interpreted in
the light of air quality, and roles to agencies must be assigned.
Along these same lines, there is the problem of how well the selected
bodies will work with one another. At the present time, information links
can only be suggested. Only after the concept of maintenance has been
around for a while can one be assured that these links will be sufficient.
An alternative, if such an informal arrangement does not work, is the
creation of an ad hoc committee, by the governor, on air quality maintenance.
This would be made up of members from both of the aforementioned bodies.
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III. Baseline Emissions Inventory
A. Baseline Year
The baseline year for the emissions inventory used in the development
of the example AQMP for the Denver AQMSA was 1972 for most of the pollutant
sources. This year included the most recent update of NEDS for this region
and also was the year for which fugitive dust emissions and traffic
volumes for the Metropolitan Denver highway network were provided. However,
for mobile source emissions in Boulder, Fort Collins, and Greeley, it was
necessary to use 1968 as the base year from which projections were made,
due to the lack of more recent data.
B. Source of Data
1. Point Source Emissions
Base year point source emissions are given for all pollutants in
NEDS. The NEDS point source data were provided by the Environmental
Protection Agency, Region VIII, and contained listings of the individual
point sources, including names of companies, location, and process rates.
2. Line Source Emissions
The emissions of CO, HC, and NO were calculated by use of the
X
Kricher and Armstrong emission factors along with diesel emission estimates
from AP-42 for the grid squares (see below) for which estimates of traffic
volumes for the current Metropolitan Denver highway network (1972) had
been made. This procedure involved a summation over low mileage emission
factors, emission control deterioration, weighted annual travel, and
different speed types. Evaporative hydrocarbons were also accounted for
in the calculation. The basis for the traffic data used in the emission
calculations was an origin-destination survey and travel forecast carried
out under the JRPP.
Base year mobile source emissions were also derived for Boulder, Fort
Collins, and Greeley based upon 1968 VMT data as a function of road type
as listed in the Classification, Needs, and Fiscal Study prepared for
the CDH by Wilbur Smith and Associates.
3. Area Source Emissions
Non-fugitive area source emissions of particulates and non-mobile
related CO, HC, and NO area source emissions were used as provided in
X
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the NEDS. Fugitive dust emissions were provided for each county in the
AQMSA in the PEDCo report, Investigation of Fugitive Dust - Sources,
Emission, and Control - For Attainment of Secondary Ambient Air Quality
Standards, Colorado.
C. Allocation of Emissions
For all particulate sources, a universal transverse mercator (UTM) co-
ordinate system was used. Point sources included in NEDS had UTM coordinates
already assigned to them and these were located accordingly. Non-fugitive
particulate area source strengths rounded to the nearest 100 tons/year,
were provided in UTM grid squares on a map printout of each county by EPA
at Research Triangle Park. Fugitive dust emissions were also allocated to
the grid squares by first disaggregating the county into zones representative
of the current land use (croplands, urban area, woodlands), assigning the
emissions for the various activities to the corresponding land uses
(e.g., agricultural emissions were assigned to cropland), and then the
2
emission densities, tons/year/4 km , were calculated for each grid square.
Emissions of CO, HC, and NOV were allocated to the 240 grid squares (2
X
miles on a side) used for air pollution studies by APRAC. These emissions
were calculated from the average daily VMT data provided by the Research
and Special Studies Branch of the CDH for the same grid squares. It was
not necessary to convert these to UTM coordinates as the change in emission
densities over time was to be the determining factor in the development
of maintenance measures.
D. Emission Control Assumptions
1. EPA Regulations
The only EPA promulgated emission regulations used were those that
apply to motor vehicle related emissions under the Federal Motor Vehicle
Control program. Modifications were made in the emission and deterioration
factors to account for the fact that high altitude emission standards
will first apply to 1977 year vehicles and that the interim standards are
assumed to be extended through the 1977 model year.
Other strategies promulgated by EPA to control motor vehicle pollution,
were assumed in the projection of emissions. These were assumed to be
implemented on or before 1977:
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1. Semi-annual inspection and maintenance using the idle test mode
(failure rate = 50 percent)
2. Air bleed retrofit on pre-1968 light duty vehicles
3. Air bleed retrofit with exhaust gas recirculation on 1968 to
1974 light duty vehicles
4. A maximum reduction in light duty vehicles VMI of 15 percent
for all VMT-reducing strategies.
Hydrocarbon emissions from stationary sources were assumed to be con-
trolled to the degree indicated in the EPA-promulgated transportation
control plan.
Other EPA regulations, e.g., New Source Performance Standards, were not
considered due to the already high degree of control on existing sources
through the application of Colorado regulations and the small contribu-
tion any influx of new sources would have on the total air quality.
2. Colorado Regulations
Regulation No. 1 of the State of Colorado, promulgated to control
the emission of particulates from point sources, was applied to all point
sources of over 100 tons/year particulates. This was accomplished by
applying the process rate based regulations to the process rates as given
in NEDS. Section II-D of Regulation No. 1, a recently promulgated section
concerning the control of fugitive dust, was applied to the emission
levels of fugitive dust.
3. Local Regulations
No local regulations were discovered during the course of this
study and therefore none was applied.
E. Emission Factor Assumptions
Except in the case of motor vehicle emissions, emission factors were
assumed to be consistent with those of the emission data base development,
both in NEDS and by PEDCo. For mobile source emission estimates, as
stated earlier, modifications were made in the emission and deterioration
factors to account for the problems associated with high altitude.
F. Problems
A minimal number of problems were encountered at this stage of the
plan development. As is the case throughout the maintenance planning
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procedure, there is some inconsistency of data bases. This was evident
by comparing the point source emissions given by PEDCo and that in NEDS.
As NEDS was supposed to be more accurate and detailed, and no evidence
to refute this was developed, this was the data base used.
It was also felt that insufficient accuracy was represented in the
area source emissions allocated in NEDS where a rounding to the nearest
hundred tons/year occurred. This deficiency was more pronounced in rural
areas where many grids were assigned either no area sources or 100 tons/year.
A similar lack of accuracy was also evident in the allocation of fugitive
dust emissions by gross land use areas. Solutions of these problems were
not attempted due to the limited time allotted to the example plan
development.
G. Recommendations
Establishment of a baseline emissions inventory requires extreme
care since it is the basis for long term projections of emissions and
resulting air quality. Since the projection techniques and factors
incorporate inherent uncertainty for a 10-year period, it is necessary
to provide the most accurate base possible from which to predict.
IV. Emission Projections
A. General Methodology
The development of projected emissions for the Denver AQMSA assumed
that emissions would grow in direct proportion to various parameters that
relate to the size of a source. This is not an unreasonable assumption
as many of the emission regulations for industry are applied on the basis of
process rates and residential pollution is expected to grow with the number
of residents.
Growth Projection Data
In the Denver metropolitan area, the JRPP provided projected
levels of population and employment by industry type within small zones
called superdistricts for 10-year intervals to the year 2000. Outside
of the JRPP superdistrict areas official state population projections through
1980 were available for each county from the Division of Planning. Other
population and economic estimates included OBERS data on an AQCR basis and
county planning commissions' data. It was found that significant dis-
crepancies existed between these two sources and the official projections
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of the JRPP and the Colorado Division of Planning. It was decided to
rely upon the projections of the JRPP and the Division of Planning's
projections to the maximum extent possible as these were not only the
official projections but also the agencies from which these projections came
are primarily responsible for growth planning in the region.
Travel activity data were also used for projecting emissions. Data on
both present and projected automobile travel were supplied by the Colorado
Division of Highways. Vehicle-miles traveled data were available by
highway functional classification and by geographic area. The major
problem is that these data are given only for the years 1968 and 1990
for non-JRPP areas and for 1972 and 2000 in the case of the metropolitan
Denver area. A linear interpolation was used to generate traffic activity
for intervening years.
B. Pollutant and Source Specific Methodology
1. Particulates
Point Sources - Projections of particulate emissions from point
sources were derived from a review of regulations controlling these emissions
and parameters of economic growth, as discussed above, during the period
of interest. Sufficient information was not available to allow for spatial
allocation of projected emissions so projections are assumed to apply to
the location of existing sources.
Initial projection of the 1972 NEDS data to 1975 emission levels
was accomplished by applying the Colorado regulations to the process rates
for all sources producing more than 100 tons particulates per year. This
in effect provides a new base year, 1975, from which other projections
are made. The actual projections of emissions were made by applying the
employment growth rates for commercial-institutional and industrial
employment sectors within each zone to the 1975 emission levels for the
corresponding source sector.
NEDS Area Sources - Area source emissions of particulates provided
by the NEDS, are projected to 1975, 1980, and 1985 on much the same basis
as particulate point sources; however, no regulations are applicable to
these emissions to provide an initial decrease in emissions. In addition
to employment projections by source sector, population growth rates are
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used to project emissions from the residential sector. Projections of
participate emissions from motor vehicles are made by assuming that the
total emissions from the motor vehicles grow with the increased VMT.
Unlike the direct application of population and employment growth rates to
the emissions, the VMT growth rates are reduced by the degree of control
of particulate emissions expected due to the installation of catalytic
mufflers in new cars.
Fugitive Dust Sources - The fugitive dust emissions were projected
to 1975, 1980, and 1985 by applying the regulation recently promulgated
by the Colorado Air Pollution Control Commission and the appropriate travel
and socioeconomic growth parameters to the corresponding source sectors
for fugitive dust. The fugitive emission reductions are determined for
unpaved roads, land development and construction activities, and mining
and storage operations based on the analysis of control measures provided
in the PEDCo study thereby giving a new baseline year of 1975 to which
the growth factors can be applied.
Several source categories were seen as unlikely to greatly change
in activity in the AQMSA during the 10-year period: agriculture; quarrying,
mining and tailings; aggregate storage; and cattle feedlots. In addition,
control measures on an increasing number of unpaved roads were expected
to offset increased traffic on present low-volume unpaved roads. Emissions
due to sand on paved roads was projected to increase in direct proportion
to total VMT; land development and residential-commercial construction was
calculated based on JRPP projections of land use; highway construction
activity was projected from the JRPP estimates of land use for roadways.
2. Carbon Monoxide
Point and Area Sources - The emission levels of carbon monoxide
from point and non-vehicular area sources were assumed to be negligible
when compared to motor vehicle sources so no growth is projected for this
source sector for this pollutant.
Mobile Sources - The projected emissions of carbon monoxide were
made by applying the emission factors and control strategies discussed
earlier to the projected vehicular activity determined by a linear inter-
polation of the data given for 1972 and 2000, or 1968 and 1990 for non-JRPP
urban areas.
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3. Hydrocarbons
Point and Area Sources - The projected emissions of hydrocarbons
from point and area sources were assumed to be those given in the EPA
promulgated transportation control plan for the Denver metropolitan area.
Mobile Sources - The projected emissions of hydrocarbons were
made on the same basis as for carbon monoxide discussed above.
Nitrogen Oxides
Point Sources - The growth rates for nitrogen oxide emissions was
broken down by power plant, industrial, commercial-institutional , and
residential sectors and are calculated only for the metropolitan Denver area
as a whole. The growth rates applied were those of employment or population
in the various sectors and ranged from 1.0 for power plants to 1.4 for
industrial and residential related sources over the time period 1975-1985.
Area Sources - The impact of nonvehicular area sources on the air
quality was considered to be negligible so no projections were made for
this source sector.
Mobile Sources - The projected emissions of nitrogen oxides were
made on the same basis as for carbon monoxide discussed above.
4. Problems
The major problem in the projection of emissions was the lack of a
defined methodology for determining and processing the growth parameters.
An additional problem was the coordination of the various data sources.
Not only is the data often generated for specific geographic areas that
are not congruent, but similar data from different sources will be
inconsistent.
C. Recommendations
The Booz-Allen document, Manual of Instruction for Projecting County
Emissions, Volume 7 of the Guideline series, provides a workbook approach
for calculating emissions using the best available sources and should
provide some alleviation of the problem of projecting emissions.
Suggested guidelines for standardization of data, especially directed
at the long-term need for continued data handling, include the following:
1. Input should be encouraged to be based locally and the projections
(with confidence levels) should be made for the smallest possible unit.
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2. There should be requirements that all planning activities
(air quality maintenance, Section 208 - water quality) and other infra-
structures use this consistent data base to ensure comparability of
projections.
V. Establishment of Baseline Air Quality
A. Baseline Years
The establishment of baseline years for the individual pollutants
being considered depends on both the availability of acceptable air quality
data and the guidelines for selection of the concentrations to be used
in the development of control strategies. For this reason, each pollutant
may be expected to have a different baseline year, especially if there is
no air quality trend evident due to emission regulations.
For particulates, no overall trend in the annual geometric means
appeared to occur during the period 1970 to 1973. Since the individual
24-hour concentrations were not yet available for 1973 and the annual data
had not yet appeared in SAROAD, the development of baseline data was
restricted to the years 1970, 1971, and 1972. The selection of the no-
3
trend option provided for the use of a 3-year average annual mean of 130 ug/m
in Denver County. In effect, no air quality baseline year was determined
for particulates.
Carbon monoxide measurements were made at only one station in 1971
and 1972 with five additional monitors being added in 1973. A review of the
measured 1-hour and 8-hour concentrations indicated that control of the
8-hour concentrations would ensure the attainment of the 1-hour standard
also. As no trend could be definitely established, examination of the
second highest 8-hour concentrations for the 3-year period indicated that
3
the control strategies would be based on the 1971 second high of 31.6 ug/m .
The study of the oxidant concentrations reported since 1970 by a
variety of methods, including the approved chemiluminescence method begun
in 1973, indicated that the second highest 1-hour concentration of oxidants
3
observed was 490 ug/m and occurred in 1973. Therefore, 1973 must be the
air quality baseline year for strategy determination.
Data collected in Denver in 1972 provide the only set of nitrogen
dioxide measurements made with a currently acceptable analytical method,
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that is also statistically adequate for the determination of an annual
mean. The annual arithmetic mean obtained from the 6759 1-hour observations
3
made by an instrumental colorimetric method during the year was 73 pg/m .
B. Compatibility with Emission Baseline
The time compatibility of the baseline air quality and the emissions
was either assumed or ensured depending upon the methodology for selection
of the air quality base year. As a nontrend option for particulates was
selected, it was assumed that the emission levels given in NEDS and PEDCo
study had not significantly changed over the 3-year period. This was a
reasonable assumption due to the effective dates of regulations controlling
these sources.
Since the air quality levels for carbon monoxide, nitrogen oxides, and
photochemical oxidants were to be used for the determination of allowable
emissions, it was necessary to calculate the emission levels of each
pollutant for its air quality baseline year selected above. Nitrogen
oxides emissions were already based in 1972, the same year as the NO
/\
air quality baseline year. For carbon monoxide and hydrocarbons (photo-
chemical oxidants) it was necessary to interpolate the emission levels one
year from the 1972 baseline year to 1971 and 1973 respectively. These
interpolations were done on the VMT data with consideration to emission
controls.
C. Air Quality Data Sources
Air quality data considered were those measured at the Denver CAMP
station and by the State of Colorado as reported in the National Aerometric
Data Bank. In addition, since the NADB did not contain an updated complete
set of data from many of the more recent monitors, it was necessary to
contact the CAPCD and the EPA Region VIII office directly.
D. Accuracy and Representativeness of Data
Consideration was given to the method of sampling, sampler location and
placement, and the number of samples from each sampler in the determination
of the baseline air quality. From July 1970 until July 1973, the KI
methods (both alkaline and colorimetric neutral) were used for the deter-
mination of total oxidants; however, these values were exceeded by subse-
quent values measured by the approved chemiluminescence technique.
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Similarly for NO , the acceptable analytical method was considered to be
X
statistically adequate for only one site for one year. In reviewing the
reported participate concentrations, it was decided to ignore the actual
highest 3-year average concentration of 170 yg/m due to the low sampling
height of 9 feet at this station. Other assumptions, including the no-trend
option, were used to select a reasonable baseline particulate air quality
value.
No analyses were performed to determine whether specific problem areas
(e.g., fugitive dust from agricultural emissions) were adequately repre-
sented by the current monitoring network. Generally, most of the samplers
were in an urban to suburban setting. Along the same line, no investigation
was made to determine any needed changes in the current monitoring network.
E. Estimation of Air Quality from Monitoring Data
Current guidelines on the handling and interpretation of air quality
data were adhered to. Therefore, only actual air quality data were used
and no estimation of the air quality was performed.
F. Problems
A basic problem in determining the base year air quality data is the
non-availability of current data that would be most representative of the
present situation. Much of the data is not readily retrievable in the
NADB. In this study it was necessary to search state and federal (the
Regional EPA office) data files to complete the data base.
VI. Air Quality Projections to 1985
A. Methodology Considerations
It is not necessary to make projections of air quality in order to
determine needed reductions in emissions to compensate for expected growth.
However, where different types of sources are to be controlled to varying
degrees, and the impact of the emissions of the various source sectors on
air quality is not parallel, it is useful to project the actual air
quality impact of each source sector separately and to combine these
impacts at the intervals of interest.
For carbon monoxide, hydrocarbons, and nitrogen oxides the primary
source sector is mobile sources so that it is only necessary to project the
total emissions over the 10-year interval to determine what types of
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control measures are needed. The contributions to the particulate
concentrations, on the other hand, come from basically three source
sectors - point, area, and fugitive, or only the latter two after point
source regulations are applied.
The emission projection methodologies have already been outlined in
Section IV so only the method used for projecting the particulate air
quality is described below.
B. Methods Used
Atmospheric modeling was used to help provide projections of particulate
air quality thereby helping in the analysis of the spatial concentration
pattern and changes of pattern due to variations in source strengths during
the period of interest. By calibrating the model with the actual air
quality measurements, it is possible to project the air quality over a
much larger area than that covered by the network of stations.
For purposes of air quality projections, the Climatological Dispersion
Model (COM) was used to calculate average annual ground level air pollutant
concentrations due to point sources. Area and fugitive dust source contri-
butions were evaluated by means of the Hanna-Gifford Area Source Model.
The COM was chosen for point sources with buoyant plumes since it can
account in more detail for the meteorological variables. The Hanna-Gifford
model has the advantage that the air quality within a particular grid
square may be related directly to the emission density within that square
and those immediately adjacent.
The modeling was performed on the 1972 emission levels for point,
area, and fugitive sources and for 1975 point source emissions to provide an
estimate of the impact of the point source regulations on air quality.
The percentage contribution of each source sector to the total calcu-
lated concentration was maintained and projected to 1975, 1980, and 1985
by use of the emission growth factors derived earlier. By projecting the
percentage contributions, new calculated concentrations could be determined
as well as new percentage contributions from each source sector.
C. Determination of the Potential for NAAQS Violation
The extent to which a pollutant might exceed the National Ambient Air
Quality Standards between 1975 and 1985 was determined by separate method-
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ologies for participates and mobile source pollutants. As described
above, actual projections of particulate air quality under current regula-
tions were made for the years 1975, 1980, and 1985. These projections
demonstrated that at most sampling sites the secondary standards for parti -
culates would continue to be exceeded and the primary standard would not
be attained in the urban areas of the AQMSA. Additional reductions to
obtain the primary and secondary standards in 1975 in downtown Denver
were determined to be 46 and 64 percent, respectively. In the more rural
regions, the attainment of the secondary standards required a further
reduction of 43 percent.
Instead of air quality projections, allowable emission levels for
carbon monoxide and hydrocarbons were calculated by applying the appropriate
rollbacks of 68 and 67 percent, respectively, to the emission levels in
the air quality baseline year. The baseline air quality for nitrogen
oxides allowed for an increase of 37 percent over the base year emission
levels. These allowable emission levels were then compared with the
projected emissions to determine whether the particular air quality
standard would be violated. This review indicated that the nitrogen oxide
standards would not be violated throughout the 10-year period of interest
and that, once attainment of the NAAQS was achieved for carbon monoxide
and photochemical oxidants, the maintenance of the standards for these
pollutants would be ensured until after 1985. The projections demonstrate
attainment of the CO and oxidant standards in 1980 and 1982, respectively,
without additional measures.
D. Sources Contributing to Standard Violations
Since stationary hydrocarbon sources are already under control by
EPA, and mobile sources are the prime contributor to the emissions of CO,
the latter were the object of the development of control measures. Since
light duty vehicles comprised the major sector of mobile sources, this
source sector was singled out for major attention.
The projected particulate air quality and the percentage contributions
from each source sector indicated that point sources, under current
regulations, contribute only to a small degree to the measured concentra-
tions of particulates. The contributions from area and fugitive sources
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are comparable and represent the majority of the emissions contributing
to the increased level of participates.
E. Level of Emission Control
The level of restraint on emissions needed to maintain the NAAQS
immediately followed from the projection of emissions and the determined
allowable levels for CO and HC and from the projected air quality of
particulates. The proportional rollback equation was used to determine
the needed percentage reduction of projected emission levels.
F. Problems
Although the most detailed projections of growth available were used
for projecting the emissions and thereby the air quality, there can be no
guarantee that all areas within a zone will grow at the same rate or that
the modeling sufficiently portrays the air quality concentrations in the
modeling area. Therefore, it must be recognized that the possibility of
"hot spots" of air pollution exist and that, to prevent their occurrence,
continuing review of development activities is necessary.
VII. Selection of Maintenance Strategies
A. The Need for Attainment
The above air quality projections indicated that the primary problem
was not in the maintenance of air quality during the 10-year period, but
attainment of the standards. Basically, if the standards are attained,
the maintenance will follow without additional effort. Since the projections
took into account the current and scheduled emission controls, it v.-as
necessary to consider additional attainment strategies to provide the needed
attainment of standards. The attainment measures are primarily directed at
the control of emissions themselves or the reduction of the number of
certain types of sources. This differs from the maintenance measures that
are aimed at controlling the amount of growth or the location of the
growth.
This study was not intended to provide a detailed analysis and develop-
ment of any needed attainment measures; however, some were presented and
discussed. These centered on the implementation of available travel-
reduction measures (e.g., bus service, carpooling, 4-day work weeks) for
the motor vehicle related pollutants. For fugitive dust, more stringent
141
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dust control measures were suggested. No analysis of the proposed travel -
reduction measures was possible and the application of more stringent
fugitive dust regulations demonstrated that the secondary standard for
particulates would still not be met.
B. The Example AQMP
Air quality maintenance for the Denver Front Range Air Quality
Maintenance Study Area depends primarily on assurance that the growth pro-
jections used for projecting activity in the metropolitan Denver area will
not be exceeded. It must be remembered that the assumption inherent in
the data base and projection factors used in the development of the AQMP
become integral parts of the AQMP and any changes in the base or the factors
could significantly change the validity of the AQMP. It is therefore
necessary to consciously incorporate the assumptions of the projection
factors into the plan.
For the Denver metropolitan region, the JRPP projections of population,
employment, and VMT were used. These projections assumed a particular
controlled growth rate of population and land use, partially influenced
by a mass transit system being developed by the Regional Transportation
District. Therefore, the maintenance measures proposed were simply those
directed toward ensuring the institutionalization of the JRPP plan:
1. Construction of the RTD rapid transit system
2. Construction of the JRPP highway system
3. Construction and indirect source review compatible with the
JRPP land use and transportation plan
4. Development of activity centers as proposed by the JRPP
5. Use of the land use development permit system to complement the
air quality permit system.
C. Factors Pertinent to the AQMP Selection
As this plan was developed by JRPP, a joint cooperative effort of the
highway, mass transit, and local government authorities, most of the
factors that normally need to be evaluated have already been considered
by the JRPP.
1. Socioeconomic
In the selection of the maintenance plan for the Denver AQMA, a
major constraint variable was the existing social, economic, political, and
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legal nature of the region. By choosing the JRPP plan as part of the
maintenance strategy package it is felt that this constraint condition
is met.
The JRPP plan involves transportation, land use, and highway plans.
For each of these, studies were done to gauge the socioeconomic effects
that would result from the plan implementation. Although no final decision
as to exactly what is involved in the RTD transportation plan has been made,
all of the alternatives are being viewed in light of both the social
system and the economic system. Features being looked at in the social
system include accessibi1ity, service to transit dependents, intrusion
on private space, and changes in the stability of the neighborhoods
affected. Economic considerations include transportation cost savings,
energy consumption,-job creation due*to system construction, and impacts
on business establishments during.and after-construction.
«
Activity center creation and tfte highway plan also are based upon
socioeconomic input. Activity'centers wi.ll serve to relieve growth pressures
from the urban fringe. Input from "citizens presently living in areas
proposed as activity centers has been gathered through a series of open
meetings. Comments of both residents and entrepreneurs in these locales
have been obtained. The highway plan is designed to absorb future increases
in automobile travel. Public hearings provide citizen input.
2, Policital Effects
The political effects of the maintenance package are c1ight because
of the nature of the JRPP. Since DRCOG is involved in the plan creation,
and since it is an organization of sub-state governmental units, agreement
is contingent upon political acceptability.
Indirect source review, as well, presents no political obstacles since
it is a necessity by law already legislated in Colorado. Land development
permits are the only feature of the maintenance strategy package that
may involve political acceptance problems. Land use legislation has been
slow in evolving and a majority of power still resides at the municipal
level. Modification of the existing interfacing structure to provide
more authority to the state agencies will most easily be accomplished on
a cooperative basis with the local levels.
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3. Technical Feasibility
The technical feasibility of the transportation system has not
yet been fully demonstrated at this time as it is still in the planning
stage. The feasibility, or lack thereof, will be demonstrated in time for
the development of the actual AQMP for this region.
4• Political Acceptance
The public acceptance of such a plan is an on-going goal of the
developers. Acceptance must be pursued at every step through the develop-
ment and implementation of the plan. Current feeling is that this system
has a high potential for continuing public acceptance due to the interest
of Coloradans in the preservation of the environment and the possibility
of increasing personal transit costs.
D. Implementation Obstacles
Given the continued public acceptance and a demonstrated technical
feasibility, there should be no major implementation obstacles for the RTD
mass transit plan. Activity centers are assumed to follow, to a large
extent, the corridors of the transit system.
Some major obstacles of permit review authority may arise if the
Colorado Air Pollution Control Commission demands that it be given veto
authority as may be required by the Federal regulations. Although it
may be possible to provide a cooperative working review, it is not certain
that this will meet with the approval of the EPA.
VIII. Legal Authority
A. Necessary Authority
The legislation necessary to carry out an air quality maintenance plan
includes a strong air pollution control act and land use legislation
which at least addresses the question of air quality. Ideally such
legislation should include two features. First, it should provide some
delineation of decision making power, attempting to identify the extent
of such power for each feature covered in the legislation. Secondly,
the laws should cover those areas germane to air quality maintenance.
B. Available Authority
Legislation available in Colorado to carry out an air quality mainte-
nance plan includes the following pieces of major legislation.
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1. Air Pollution Control Act of 1970
2. Land Use Act
3. House Bill 1041 which amended the Land Use Act.
The Air Pollution Control Act created the nine-member Colorado Air
Pollution Control Commission to develop an effective air pollution control
program and promulgate such regulations as may be necessary or desirable
to "achieve the maximum prictical degree of air purity in every portion
of the state." The regulations especially applicable to air quality
maintenance follow.
1. Regulation No. 3: Regulation Governing Authority to Construct
and Permit to Operate
2. Regulation No. 6: Standards of Performance for New Stationary
Sources
3. Regulation No. 9: The Control of Automotive Air Pollution
through Motor Vehicle Restraints and the Encouragement of Public Transporta-
tion and Carpooling.
The Land Use Act as amended provides for a Land Use Commission to
provide leadership for planned and orderly land use development. To this
end the Commission has worked at providing a framework whereby the State
of Colorado and its political subdivisions can guide future development.
Municipal decisions regarding land use are fostered by this legislation.
As it stands now air quality is not addressed in the legislation. From
a maintenance standpoint, this is the major deficiency of the law.
C. Additional Authority Required
A comparison of the legal foundation necessary for a viable air
quality maintenance plan with the existing legislation and regulation
brings out two salient features. First, air quality should be explicitly
considered in land use planning. The Land Use Act should be so amended.
Secondly, some legislation or even an executive order should provide for the
coordination between the Air Pollution Control Commission and the Land Use
Commission. As it now stands, there is no formalized information flow
between the two.
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SUMMARY OF DENVER AQMSA
POLLUTANT: TSP*
NAAQ STANDARD: 60 yg/m3 annual geometric mean
CURRENT AIR QUALITY, 3-year average, 1970-72: 130 yg/m3 annual geometric mean
EXPECTED AIR QUALITY IN 1975: 114 yg/m3 annual geometric mean
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD: 70%
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
Stricter fugitive dust controls - 1975
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
None additional.
* 3
Background at 30 ug/m assumed.
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SUMMARY OF DENVER AQMSA
POLLUTANT: CO
NAAQ STANDARD: 10 yg/m3 (8-hour average)
CURRENT AIR QUALITY, 1971: 31.6 yg/m3 (8-hour average)
EXPECTED AIR QUALITY IN 1975/1977: 26 pg/m3*/14 yg/m3*
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD: 68%
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
Attainment Measures
I. Preferential Treatment of Buses
A. Exclusive Bus-Carpool Lanes
1. feasibility study (September 1, 1974)
2. plan submission (July 1, 1975)
3. plan implementation January 1, 1976
B. Park-N-Ride Facilities/Express Buses to CBD
1. plan submission (October 1, 1974)
2. plan implementation (est.) January 1, 1976
II. Employer Plan Requirements for Carpooling and Mass Transit
Incentives
A. Carpooling
1. DRCOG proposal for carpool locator service (November 1, 1974)
2. Employer submittal of affidavit stating that DRCOG
locator service will be provided to employees or that
another locator service of equal or greater effective-
ness will be used.
large employers (>250 employees) submitted (February 1, 1975)
other employers (50-250 employees) submitted (August 1, 1975)
3. Plan Implementation
large employers April 1, 1975
other employers October 1, 1975
B. Mass Transit Incentives
1. large employers plan submittal (February 1, 1975)
2. other employers plan submittal (August 1, 1975)
III. Parking Requirements
DRCOG recommendations of parking requirements that may stimulate
the use of public transportation and decrease single passenger
VMT (March 1 , 1975)
Maintenance Measures
1. Construction of the RTD rapid transit system - 1983
2. Construction of the JRPP highway system - ongoing
3. Construction and indirect source review compatible -(policy statement
with JRPP land use and transportation plan by July 1, 1975)
- ongoing
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Maintenance Measures (continued)
4. Development of activity centers as proposed by the JRPP - 1983
5. Use of land use development permit system to - ongoing
complement air quality permit system
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
Attainment
For the preferential treatment of buses RTD, working with the Colorado
Department of Highways and DRCOG, must submit a detailed plan to the APCC.
The other two maintenance strategies require DRCOG, with the aid of the
CDH and RTD, to perform analyses and make formal reports to the APCC.
Maintenance
The maintenance strategy package requires the APCC and the LUC to
exchange information and coordinate efforts related to air quality
maintenance through periodic meetings. The progress of the JRPP plan
will be monitored by the APCC through reports from the involved agencies.
The LUC will work with municipal government units in the operation of the
permit system.
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SUMMARY OF DENVER AQMSA
POLLUTANT: N0x
3
NAAQ STANDARD: 100 yg/m annual arithmetic mean
CURRENT AIR QUALITY, 1972: 73 ug/m3 annual arithmetic mean
EXPECTED AIR QUALITY IN 1975: 70 yg/m^annual arithmetic mean
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD: None needed.
PROPOSED ATTAINMENT/MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
None required.
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
*
No modeling involved, only proportionality techniques.
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SUMMARY OF DENVER AQMSA
POLLUTANT: HC/Photochemical Oxidants
NAAQ STANDARD: 160 yg/m3, 3-hr concentration (6 to 9 a.m.)
CURRENT AIR QUALITY, 1973: 490 yg/m3, 3-hr concentration (6 to 9 a.m.)
EXPECTED AIR QUALITY IN 1975/1977: 455 pg/m3/ 307 pg/m3*
PERCENTAGE REDUCTION NEEDED TO ATTAIN STANDARD: 67%
PROPOSED ATTAINMENT MAINTENANCE MEASURES AND DATE THEY MUST BE IN EFFECT:
Same as carbon monoxide strategies.
INTERGOVERNMENTAL RELATIONSHIPS REQUIRED:
Same as carbon monoxide strategies.
*
No modeling involved, only proportionality techniques,
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1 REPORT NO.
EPA-450/3-74-006
2.
3. RECIPIENT'S ACCESSI Ot* NO.
4. TITLE AND SUBTITLE
Guidelines for Air Quality Maintenance Planning and
Analysis
Volume 5: Case Studies in Plan Development
5. REPORT DATE
January 1975
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
41U-946-9
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Research Triangle Institute
P.O Box 12194
Research Triangle Park,
North Carolina 27709
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-1386, Task 9
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, N.C. 27711
13. TYPE OF RE PORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Trial Air Quality Maintenance Plans for Baltimore, Denver, San Diego,
and St. Louis are presented in digest form. In each digest the Air
Quality Maintenance Area is described in terms of topographic, economic,
and air quality characteristics; bases for intergovernmental cooperation
are discussed; baseline air quality and emissions inventory are established;
emissions are projected for 1975, 1980, and 1985 and consequent air
quality is estimated. Strategies for insuring the attainment/maintenance
of air quality during the decade 1975-1985 are proposed. Problems
encountered and possible solutions are discussed.
Full text trial plans are available from NTIS as follows:
Baltimore NTIS No. PB-416/AS
Denver NTIS No. PB 237-414/AS
San Diego NTIS No. PB 236-932/AS
St. Louis NTIS No. Not yet assigned
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDEDTERMS
C. COSATI Held/Group
Air Pollution
Atmosphere Contamination Control
Urban Planning
Regional Planning
Air Quality Maintenance
Area
Air Quality Maintenance
Plan
National Ambient Air
Quality Standards
13-B
13. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (This Report)
unclassified
21. NO. OF PAGES
158
20. SECURITY CLASS (This page)
unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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