EPA-450/4-74-003
July 1974
(OAQPS No. 1.2-022)
GUIDELINES FOR AIR QUALITY
MAINTENANCE PLANNING AND ANALYSIS
VOLUME 3:
CONTROL STRATEGIES
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Vi aste Manaement
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
Tf f,-i*»\ «^« 1 1
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EPA-450/4-74-003
(OAQPS No. 1.2-022)
GUIDELINES FOR AIR QUALITY
MAINTENANCE PLANNING AND ANALYSIS
VOLUME 3:
CONTROL STRATEGIES
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, N. C. 27711
July 1974
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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current contractors and
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, Springfield, Virginia 22151.
This report was furnished to the Environmental Protection Agency by
the Research Triangle Institute, Research Triangle Park, N. C., and
PEDCo-Environmental Specialists, Inc., Cincinnati, Ohio, in fulfill-
ment of Task Order No. 1, Contract Number 68-02-1386. The contents
are reproduced herein as received from the contractor. Prior to final
preparation the report underwent extensive review and editing by the
Environmental Protection Agency and other concerned organizations.
The contents reflect current Agency thinking and will form the basis
for promulgation of official policy in Requirements for Preparation.
Adoption, and Submittal of Implementation Plans (40 CFR Part 51).
Publication No. EPA-450/4-74-003
(OAQPS Guideline No. 1.2-022)
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FOREWORD
This document is the third 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 preparation of Air Quality Maintenance Plans
required under 40 CFR 51. The volumes in this series are:
Volume 1: Designation of Air Quality Maintenance Areas
Volume 2: Plan Preparation
Volume 3: Control Strategies
Volume 4: Land Use and Transportation Considerations
Volume 5: Case Studies in Plan Development
Volume 6: Overview of Air Quality Maintenance Area Analysis
Volume 7: Projecting County Emissions
Volume 8: Computer-Assisted Area Source Emissions Gn'dding
Procedure
Volume 9: Evaluating Indirect Sources
Volume 10: Reviewing New Stationary Sources
Volume 11: Air Quality Monitoring and Data Analysis
Volume 12: Applying Atmospheric Simulation Models to Air
Quality Maintenance Areas
Additional volumes may be issued.
All references to 40 CFR Part 51 in this document are to the
regulations as amended through July 1974.
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TABLE OF CONTENTS
CHAPTER PAGE
Foreword ^ n- n-
List of Figures v
List of Tables , V1-
I INTRODUCTION , I_l
A. General I_l
B. Types of Maintenance Measures Available 1-3
II LAND USE AND PLANNING MEASURES II-l
A. Emission Allocation Procedures II-l
B. Regional Development Planning 11-15
C. Emission Density Zoning 11-26
D. Zoning Approvals and Other Indirect Regulatory 11-39
Controls
E. Transportation Controls 11-57
F. Emission Charges 11-77
G. Transfer of Emission Source Location 11-82
H. Indirect Source Review 11-88
I. Environmental Impact Statements (EIS's) 11-98
III EMISSION CONTROL MEASURES HI_1
A. New Source Performance Standards III-l
B. Revision of Existing SIP Control Measures III-9
C. Phaseout or Prohibition of Emission Sources 111-12
D. Fuel Conversion 111-17
E. Energy Conservation and Utilization 111-22
F. Combination of Emission Sources 111-29
G. Special Operating Conditions 111-44
H. Stack Height Regulations 111-51
I. Control of Fugitive Dust Sources 111-56
IV INTERRELATIONSHIPS AMONG MEASURES IV-1
IV
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/ LIST OF FIGURES
Figure No.
III-l Schematic representation showing applicability of NSPS III-8
to construction and modification
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LIST OF TABLES
Table No.
1-1 Air quality maintenance measures
II-l Summary of selected land-use management measures that may
affect maintenance of air quality standards
II-2 Transportation control measures 11-60
II-3 Examples of existing transportation controls to 11-63
reduce traffic congestion
II-4 Transportation control measures proposed in promulgated plans 11-64
II-5 Estimated emissions reductions from the inspection/ 11-68
maintenance program in New Jersey
II-6 Estimated motor vehicle emission reductions from individual 11-75
transportation controls
II-7 Indirect sources requiring approval 11-91
II-8 Required information for indirect source review 11-93
under February 25, 1974 regulations
II-9 EPA rating systems for project impact and EIS adequacy 11-102
III-l Status of standards of performance for selected III-4
source categories (NSPS)
III-2 Regulations adopted to prohibit or phase out specific 111-14
sources of emissions
III-3 Frequency distribution of measured SO? concentrations before 111-47
and after implementation of supplementary control systems
at Paradise steam plant
III-4 Smelter monitor I-hour S02 concentrations for three 111-47
selected time periods
IV-1 Interrelationships among maintenance measures IV-2
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Chapter I: INTRODUCTION
A. GENERAL
The purpose of this report is to describe several alternate admin-
istrative and technical programs for the maintenance of air quality
standards in designated Air Quality Maintenance Areas (AQMA's). Indi-
vidual programs that act to maintain air quality standards, either
through the prevention or reduction of emissions or the spatial and
temporal redistribution of emissions, are termed maintenance measures.
The maintenance measures described herein are shown in table 1-1.
Groups of one or more compatible maintenance measures that are expected
to provide the total necessary control of emissions in an AQMA are
referred to in this report as maintenance strategies.
Volume 2 of this quideline series, Plan Preparation, recommends
that a two-stage procedure be used in selecting the preferred group of
maintenance measures for an AQMA: screening of all potential measures
for those that are feasible and compatible, followed by selection based
on socioeconomic evaluations. It is anticipated that the information
in this report will be useful primarily for the initial stage, in iden-
tifying and screening measures for applicability in a particular AQMA.
The description of each of the 18 measures covered is organized into
the following topics:
A brief definition of the measure
Current applications (case histories)
Recommendations for implementing the measure
Conditions of applicability, interactions with other
measures, potential conflicts with other community
development plans, and practical limitations
Estimates of potential effectiveness
Some of the measures have not been used previously by control
agencies or planners to improve air quality. Only limited experience
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Table 1-1. Air quality maintenance measures
LAND USE AND PLANNING MEASURES
Emission Allocation Procedures
Regional Development Planning
Emission Density Zoning
Zoning Approvals and Other Indirect Regulatory Controls
Transportation Controls
Emission Charges
Transfer of Emission Source Location
Indirect Source Review
Environmental Impact Statements
EMISSION CONTROL MEASURES
New Source Performance Standards
Revision of Existing SIP Control Measures
Phaseout or Prohibition of Emission Sources
Fuel Conversion
Energy Conservation and Utilization
Combination of Emission Sources
Special Operating Conditions
Stack Height Regulations
Control of Fugitive Dust Sources
in the application of other measures is available. In contrast, appli-
cations of some measures have been so varied that an entire document
could be written on each one. Therefore, with the exception of the
case history data, the information presented is necessarily general.
Analyses and conclusions drawn from the case histories usually have
not been stated directly. However, these conclusions have formed part
of the basis for recommendations on implementation of the measure and
are also a factor in the estimates of potential effectiveness.
The report discusses three measures that are already in effect
in all AQMA's regardless of maintenance plan provisionsindirect source
review, Environmental Impact Statements (EIS's), and Federal New Source Perfor-
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mance Standards (NSPS). It is important that the capabilities of these
measures for maintenance be known and considered in the preparation of
Air Quality Maintenance Plans (AQMP's).
Three other tools available under the Clean Air Act that may serve
to mitigate the impact of general growth are discussed within other
sectionsthe requirement in 40 CFR 51.18 that each State Implementation
Plan (SIP) have procedures to review, and if necessary prevent, the con-
struction or modification of stationary sources at any location that would
result in interference with the attainment or maintenance of a national
standard; emission standards for new motor vehicles promulgated under
section 202 of the Act; and requirements in section 110, that the
Administrator call for revision of inadequate SIP's whenever ambient air
quality monitoring or other information indicates the necessity.
B. TYPES OF MAINTENANCE MEASURES AVAILABLE
In theory, air quality maintenance measures are to be implemented
to keep air quality better than or equal to the National Air Quality
Ambient Standards (NAAQS). Ideally, the measures would affect primarily
the growth component of AQMA emissions, both from new sources and from
increases in activity levels at existing sources, by controlling the
amount, timing, and/or location of new emissions. Based on this concept,
maintenance measures could also be characterized as moderate, long-term
actions that are capable of offsetting the growth in regional emissions
that would occur without some comprehensive plan, and that act to reduce
emissions at about the same rate at which the new emissions begin.
Therefore, preferred measures should emphasize management and preventive
aspects of air pollution control. However, if pollutant concentrations
are at or above the NAAQS at the time the AQMP is to be implemented,
measures that provide for additional emission reductions by existing sources
must be included in the maintenance strategy (or a separate attainment plan
must be submitted).
Unlike provisions in the control strategies of the SIP's, mainte-
nance measures must be implemented prior to the time that excessive
emissions would otherwise occur. Because of this prior implementation,
they are particularly sensitive to planning projections used in the
development of maintenance plans. NAAQS may never be exceeded in one
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part of an AQMA just because projected growth or emission sources
do not materialize. On the other hand, maintenance measures may fail
in their objective even though they are properly implemented, due to
incorrect estimates of the rate, location, or amount of projected
growth, or to the impact of projected additional emissions on air
quality.
Identification of specific measures that have the characteristics
described above is a difficult task. The 18 measures presented are
thought to include the major approaches to air quality maintenance.
However, the example types of applications discussed under each measure
may include only a few of the many possible applications. Those invol-
ved in the development of a maintenance strategy are encouraged to seek
additional measures or applications that may be specific to the AQMA.
These measures have been divided into two classes--land-use and
planning measures and emission control measuresbased on some distin-
quishing characteristics that were observed among different measures.
Since this classification is somewhat arbitrary, a few of the measures
have characteristics of both of the classes.
Land-use and planning measures, as the name implies, are primarily
involved with planning for future regional air quality. They are con-
cerned mainly with new emission sources. As such, they usually have an
indirect or inactive effect on emissions from any specific source.
Important land-use and planning measures are discussed in chapter II.
In contrast, emission control measures are technological or opera-
tional changes that most often affect existing sources (NSPS are a
notable exception). The result is a reduced quantity of emissions, a
reduced impact of emissions on ground-level air quality, or a temporal
redistribution of emissions. Emissions control measures tend to have a
direct, active effect on emissions from individual sources and, hence,
their impact can be quantified much better than that of land-use and
planning measures. Emission control measures are discussed in chapter III.
No order of priority or hierarchy of these measures appears appropriate,
except that an SIP revision (more stringent controls on existing sources)
is to be considered prior to the evaluation of maintenance measures.
The observation is made that most of the land-use and planning measures
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(except indirect source review and EIS's) represent comprehensive
approaches to air quality maintenance, while the emission control
measures generally apply only to specific source categories. There-
fore, the emission control measures may be implemented within the
framework of different land-use and planning measures, and may be the
specific actions taken to effect emission reductions that are needed
under a land-use and planning measure. However, individual or groups
of emission control measures can also provide for maintenance inde-
pendently of any land-use and planning measure.
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Chapter II: LAND USE AND PLANNING MEASURES
A. EMISSION ALLOCATION PROCEDURES
1. Definition of the Measure
Emission allocation is a maintenance measure that requires
emissions of pollutants be limited to prescribed levels within an
airshed, air basin, AQMA, or portion thereof. On the regional level, a
relationship is established between the assimilative capacity of the
ambient air in the region and the amount of emissions within the region
that would not violate air quality standards. The emission allocation
procedure would probably be administered by an agency or several agencies
having cognizance over air pollution or land use. A special entity having
representation of air pollution agencies and land-use planning and control
agencies and created for administering emission allocation procedures is
also a viable alternative.
The procedure may be applied to all pollutants and to both existing
and new point, line, and area sources. Although related to emission
density zoning, emission allocation should be viewed as a much more
generalized technique concerned with regional air pollution problems
that focuses on the comprehensive land-use plan as the basic document
from which future levels of air quality are estimated. In contrast,
while applicable to all land uses, emission density zoning is a more
specific technique most applicable to controlling stationary source
pollutants in localities having heavy concentrations of industry.
The purpose of emission allocation is to utilize land-use-based
measures to control the air pollution potential of comprehensive land-
use plans within an AQMA or some other defined region. The land-use
plans, therefore, need to be viewed as an accurate representation of the
future development that can be expected in the region. The land-use
plans, associated transportation plans, and the enrission/actors thus
assume key positions in estimating future levels of air quality.
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2. Historical Review of the Measure
a. Current Application of the Measure. Emission allocation
procedures are not currently being utilized by any air pollution control
or land-use planning agency in the United States. There are no current
zoning or planning regulations containing emission limits based on a
regional definition of assimilative capacity. There is a bill in the
California Assembly (S.B. 1543), however, that would mandate the applica-
tion of this procedure in the 11 air basins in the State of California.
The concept of emission allocation procedures is that there should
be established some relationship between total air pollutant emissions
in a region and the assimilative capacity of the ambient air in the
region, and that this relationship can be projected into the future to
establish the total amount of emissions that can be allowed at some
future point in time. A principal assumption is made that there is a
direct relationship between urban growth and increasing levels of air
pollution. Thus, if future areas and levels of land development in a
region can be predicted, the type of air quality maintenance strategy
that would be necessary to ensure that air quality standards will not be
violated could be determined. The comprehensive land-use plan provides
this prediction of future development.
The recognition of the importance of land-use planning as a tech-
nique for air quality improvement led the California legislature
in 1972 to direct the California Air Resources Board (ARE) to prepare a
report on proposed guidelines for the preparation of an air pollution
control element in city and county general plans. In response to this
mandate, the ARB let a contract to the consulting firm of Livingston and
Blayney to prepare such a report in cooperation with the ARB staff.
However, as the study progressed in early 1973, it became apparent that
air quality management could be effectively integrated with land-use and
transportation planning only on an air-basin-wide scale. Accordingly,
the procedures that the consultant recommended would vest responsibility
in regional agencies for allocating air pollutant emissions limits
within each air basin of the State.
However, for States maintaining centralized control over air pollu-
tion control activities, responsibility could be vested in the State
agency and the program administered from that level in cooperation with
local and regional agencies.
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b. Effectiveness of the Measure in Current Applications.
Since the emission allocation procedures have not been applied to date
in the State of California, it is impossible at this time to determine
the effectiveness of the measure. The potential effectiveness of the
measure is discussed later in this section.
3. Implementation
a. Procedure. Emissions allocation could be established
and implemented in several different ways, depending on the types and
levels of government involved. One generalized procedure is described
here; it is emphasized that the agencies recommended for participation
are just for this example procedure.
Six steps are proposed to integrate air quality goals into the
land-use and transportation planning process under the emission
allocation procedures.
1) Compile detailed inventories of air pollution emis-
sions in planning subareas of an AQMA or air basin. Emission data must
be obtained for each planning subarea and not disaggregated from county
or AQMA totals.
2) Designate maximum emissions allowable in each
planning subarea to achieve and maintain air quality standards, based on
an analysis of present air quality and the assimilative capacity of the
air to absorb pollutants and still maintain air quality standards.
3) Estimate planning subarea emissions likely to be
generated by sources indicated in land-use and transportation plans for
designated future time periods and compare these emissions with the
allowable emission limits.
4) Evaluate and revise land-use and transportation
plans so that prescribed emissions limits would not be exceeded.
5) Adopt and implement land-use and transportation
plans, emission controls, and other measures that are prepared to meet
air quality goals and standards.
6) Monitor public and private development through a
refined environmental impact assessment process in which emissions
projected directly or indirectly from proposed projects are accounted
for in EIS's.
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The key to this process is the concept of allocating air pollutant
emissions within an AQMA. As long as plans and projects conform to pre-
scribed emission limits, air quality standards should be maintained. An
appeal process would permit deviation from prescribed limits where
technical information is available to demonstrate that air quality
standards will not be exceeded by the proposed deviation.
The responsible agency in the AQMA would compile the planning sub-
areas' emissions inventories and then designate the emissions limits for
each planning subarea. Planning agencies would make emissions projections
based on their plans to meet prescribed emission limits. Transportation
planning agencies likewise would make projections of the emissions that
would be generated by their proposed plans and would revise them accord-
ingly. A significant amount of interaction between the agencies in-
volved would be necessary before all plans throughout an AQMA or air
basin met the prescribed emissions limits. If and when the allowable
limit is reached, some equitable procedure must be developed to permit
additional growth and development. Hopefully, this will not occur until
later, in or after the 1975-1985 period covered by the AQMP. By that
time improved control technology and experience gained during the
implementation of the AQMP should permit revision of the plan to ac-
commodate additional growth while maintaining NAAQS.
Appeals to exceed emissions limits would be decided by the State or
designated regional agency, if such responsibility has been so designated.
Once the plans have been approved by this agency, the responsibility
for implementing them would probably rest at the level of cities and
counties. However, the designated regional agency would continue to
monitor development to ensure that emission limits would not be violated.
The State agency would retain the overall responsibility for monitoring
the program and intervening where necessary to ensure compliance with
established procedures and criteria.
While the emission allocation process has been designed to utilize
existing land-use and transportation plans, air quality standards, and
emission inventories, the procedures can also utilize new land-use and
transportation plans developed specifically with air quality objectives
in mind. In such a case the AQMP could consist of a program to develop
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a comprehensive plan plus a series of emission reduction measures for the
initial portion of the 10-year period. Upon completion of the comprehensive
land-use plan, the State would develop an appropriate long-range AQMP
incorporating emission allocation procedures. The State, in the
submission of the AQMP, must demonstrate the capability to develop a
mechanism for the creation of a comprehensive plan that recognizes the
requirement for the maintenance of air quality.
The first step is to compile an emissions inventory for areas
within the air basin for a base year. Planning subareas would best be
chosen to conform as much as possible to the boundaries of political
subdivisions, census tracts, and existing planning areas. They also
would have to be of small enough size to permit definition of specific
areas with air quality maintenance problems.
Given the emissions inventory and air quality data obtained by
monitoring in the planning subarea and the air basin for the base year,
the maximum allowable emissions that should meet air quality standards
in each subarea can be set. Two possible options for the designation of
maximum emissions allowable in a planning subarea can be considered.
Either the dispersion or proportional model can be used to estimate the
control requirements in each planning subarea. The dispersion model is
preferred if sufficient data are available for its validation.
Furthermore, proposed regulations for supplementary control systems
indicate that EPA is going to require dispersion models to evaluate
particulate and SOY strategies unless it can be demonstrated that such
A
models are not appropriate.
To designate the maximum allowable emissions for other than
photochemically reactive pollutants in each planning subarea, the
relationship for each pollutant category Em in the planning subarea to
the allowable emissions in an air basin according to the implementation plan
would be the same relationship obtaining for the emissions in a planning
subarea base year to the emissions in an air basin base year. This
allocation can be expressed as follows:
E allowable in planning subarea E planning subarea base year
E allowable in air basin accord- E air basin base year
m ing to implementation plan
where Em refers to emissions for each pollutant category.
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In a planning subarea, 80 tons of sulfur dioxide per day might
be emitted in 1970, and the basinwide proportional growth that could
still maintain the air quality standard for sulfur dioxide might be 25
percent. In this case, the emissions of sulfur dioxide allowable in the
subarea would be 100 tons of S0? per day.
If a dispersion model is validated and accepted by the air pollution
control and land-use planning agencies, the air basin emissions alloca-
tions for pollutants may conform to the model's projection for
achieving and maintaining air quality standards. With such a model, it
is anticipated that it would not be necessary to reduce emissions in all
planning subareas in the basin as drastically as required in the subarea
with the worst air in order to meet air quality standards, because the
transport of pollutants from one subarea to another could be simulated.
Implementation of emission allocation procedures requires a coor-
dinated effort at all levels of government, State to local. The specific
requirements of emission allocation procedures must be considered in the
development of the management and organizational structure required for
implementation of the AQMP. The exact structure will be dictated by
local requirements.
Because land-use, transportation, and emission control plans are
regional in nature, there may be merit in the State's retaining
responsibility for their preparation and promulgation. Such an approach
would minimize the problems that can result from locally developed plans
designed to attain diverse and sometimes competing goals. In any event,
the State must retain ultimate responsibility for ensuring that regional
and local plans are compatible and promulgate State-developed plans if
necessary to resolve local level conflicts.
A description of the proposed operation of emission allocation
procedures in the State of California provides insights into the func-
tions and organizational structure that may be used for implementation
of this measure. It must be borne in mind that, in California, land-
use, transportation, and air quality planning responsibilities are
decentralized using the nesting approach whereby the State prescribes
general requirements with successively more specific requirements being
developed at lower levels. While the specific organizational and
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responsibility structure may not be completely applicable for other
States, the functions being carried out at the regional and local levels
must be performed by some agency, whether or not responsibilities are
delegated to activities below the State level.
The following agencies are involved in the California plan for
operationalizing emission allocation procedures:
Air Resources Board (ARB). The State air pollution control agency.
Basin-wide Air Pollution Control Coordinating Councils (BCC).
Regional agencies responsible for preparing and implementing
basin-wide air pollution control plans. BCC's are composed of
groups of county air pollution control districts.
Local Agency Formation Commission (LAFCO). A commission that
usually operates at the county level charged with the responsi-
bility of determining maximum service areas and service capacities.
City and county governments.
Air Pollution Control Districts. A county or multicounty agency.
Regional Transportation Planning Agencies.
Governor's Office of Planning and Research.
The duties to be carried out by these organizations are as follows:
1) The Air Resources Board shall:
Establish emission limits for each pollutant for each basin
by July 1975.
Provide emission factors that relate quantity and type of
pollutants to land-use and transportation plans.
. Review and approve methodology utilized by air-basin-wide
agencies in allocating emissions limits to planning subareas.
Provide technical support to other agencies.
Upon passage of legislation, the program shall be activated in
the Sacramento, San Joaquin, San Francisco, San Diego, and South Coast
Air Basins. The ARB shall monitor general plans in the other air basins
of the State. At its discretion, it may activate the program in other
basins or portions of other basins of the State where it determines that
achievement and maintenance of air quality goals may be endangered by
projected growth and development.
2) The Basin-wide Air Pollution Control Coordinating
Councils (the designated regional agencies in this case) shall:
Subdivide the air basin for the purpose of establishing emissions
limits.
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Adopt emissions limits stating the quantity of pollutants in
each pollutant category that can be emitted in the air in each sub-
division of the air basin by December 31, 1975. The totals for all
areas shall not exceed ARB limits established for the air basin.
Review the emissions limits periodically and adopt amendments
when new data indicate that a different quantity of pollutants should be
allocated.
Require a current, detailed emissions inventory and periodic
updating.
Provide technical assistance to cities, counties, Councils of
Government, and regional transportation planning agencies on the
preparation of general plans and transportation plans that would conform
to emissions limits, and on the utilization of emissions allocations and
emissions limits in evaluating the air quality impact of proposed projects
in environmental impact reports.
Define projects likely to have a significant impact on air
quality.
Review environmental impact reports prepared for projects with
potentially significant air quality impacts and for major growth-
inducing projects.
Review within 90 days of receipt, city and county general
plans, regional land-use plans, and regional transportation plans in
accord with procedures and methodology prescribed by the Air Resources
Board, and approve plans that are judged to maintain projected emissions
from planned land uses and transportation facilities within emissions
limits allocated to the basin subdivisions.
Establish procedures for BCC review of applications to the
LAFCO* to annex or incorporate territory, or to create special districts
or expand their service areas or functions, for potential impact on air
quality, and notify each local agency formation commission of any expected
violations of air quality goals likely to result directly or indirectly
from application approval.
*LAFCO's are required by Assembly Bill 237 (1972) to undertake studies of
existing governmental agencies, including dependent special districts, in
order to determine maximum service areas and service capacities. They
usually operate at the county level.
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3) Cities and counties shall:
Determine that projected air pollution emissions, directly or
indirectly generated by land uses designated in the land-use element and
by transportation facilities designated in the circulation element, do
not exceed the allowable emissions allocated to the city or county and
air basin subdivision by the BCC or equivalent agency.
Submit the general plan to the BCC for review for consistency
with air pollution emissions limits by December 31, 1976.
After the receipt of the allocation of emissions limits pre-
scribed by the BCC, submit to the BCC for review the adopted general
plan and a projection of the quantity of emissions in each pollutant
category resulting from the plan's proposals.
After receiving a notice of disapproval of the plan for
failure to meet emissions limits, submit a revised plan and projection
of emissions to the BCC for review.
Modify the objectives, criteria, and procedures adopted for
evaluation of projects and preparation of environmental impact reports
to include procedures for the projection of air pollutant emissions,
directly or indirectly generated by proposed projects, and for the
evaluation of emissions with reference to emissions limits allocated to
air basin subdivisions within the jurisdiction of the city or county by
the BCC.
4) Local Agency Formation Commissions (LAFCO)
shall:
Prior to the approval of an application for annexation, in-
corporation or the creation of a special district, or the expansion of a
special district's territory or functions, consider the effect of the
proposed action on air quality and on the emissions limits allocated by
the BCC to the air basin subdivision affected by the application.
Require that the project conform with the emissions limits
assigned to the air basin subdivision in which the project would be
located, as well as with city or county general and specific plans.
5) Air Pollution Control Districts shall:
Revise their orders, rules, and regulations to be consistent
with the allocation of emissions limits prescribed by the BCC, partic-
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ularly those regulations regarding complex sources aimed at preventing
the construction or operation of facilities that either directly or
indirectly would cause emissions allocations to be exceeded.
Require the developer of any project of the type defined as
major growth inducing or likely to have a significant impact on air
quality by the BCC to obtain a permit from the air pollution control
district.
Issue no permit for the construction, alteration, or operation
of any project for which projected emissions would exceed the limits
allocated to the air basin subdivision or city or county.
6) Regional Transportation Planning Agencies
shall:
Determine that the regional plan is consistent with the
allocation of emissions limits prescribed for the air basin.
Provide a report of projected emissions from the transportation
system proposed in the plan in the EIS now required.
Not adopt a regional transportation plan until receipt of a
statement of approval from the BCC, certifying that the emissions pro-
jected from the proposed transportation system do not exceed the limits
allocated to the air basin or its subdivisions.
7) Office of Planning and Research shall:
Prepare in conjunction with the ARB and the Council on
Intergovernmental Relations a handbook of technical guidelines
and administrative procedures for reviewing and projecting emis-
sions from proposed projects, for reducing emissions in existing and
proposed developments, and for preparing plans that maintain emissions
within allocations of emissions limits.
b. Conditions of Applicability. Following the earlier
discussion, prerequisite conditions of applicability are as follows:
1) The availability of a current emissions inventory
and land-use data. This land-use data would be for current land use and
for expected future development.
2) The availability of sufficient resources to develop
the emissions rates and to administer the regulations over time.
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3) The availability of sufficient monitoring data
either to calculate the emissions ceiling of the proportional model or
to calibrate the dispersion model.
4) A well-developed land-use and transportation plan-
ning capability on the part of municipal and county or regional govern-
ment.
5) Appropriate enabling legislation.
If all these data and capabilities are present or can be assembled,
an emissions allocation procedure can be used for any combination of
emissions sources, and within a wide range of administrative structures.
This measure offers a broad, flexible approach that is directed spec-
ifically at maintenance of air quality standards, and would be
applicable in most AQMA's. The primary limitations on the use of
emissions allocation result from its large, continuing administrative
staffing requirements and its need for extensive interagency
cooperation.
c. Interactions with Other Measures. In general,
emission allocation procedures may be thought of as a framework within
which other measures can be applied. This measure does not provide the
actual emission reductions and is therefore dependent on the existence
of other measures to provide reductions shown to be needed in particular
subareas. However, it does provide control over the admittance of new
sources into subareas that are either approaching or are at their
emissions allocation.
The procedures would be a supplement to source control regulations
and could be administered in concert with them. Used together, they
would be particularly valuable in avoiding "hot spots," areas where
large sources cluster and technological source controls are not adequate
to avoid local violations of air quality standards.
Emissions allocation procedures can also provide an overall structure
in which other administrative measures, such as emission density zoning,
indirect source review, or transportation control plans, can function.
The interaction with emission density zoning is discussed in the section
on that measure. In California, the proposed maintenance plan utilizes
both indirect source regulation and State-required environmental impact
assessments as integral parts of their emissions allocations procedure.
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d- Potential Conflicts and Negative Impacts. California's
experience in conceptualizing the procedures and organization to oper-
ational ize emission allocation procedures indicates some potential
problem areas that must be considered in the development of similar
procedures by other States. The major difficulty with the program as
initially conceived was that it would mean that no growth or development
would be allowed in the Los Angeles air basin over the short-term, at
least until the automobile becomes a much cleaner means of transportation
or major reductions in existing stationary sources are obtainable. The
Air Resources Board chose instead to modify the program and to reserve
the right to designate emissions limits for each air basin. The air-
basin-wide agencies would be required only to allocate the designated
emissions to planning subareas within each basin. They would not have
to determine whether Federal and State air quality standards would be
achieved and maintained. The ARB was in effect saying that the Clean
Air Act left them no flexibility to avoid imposing intolerable burdens
on the population of Los Angeles. They would rather see somewhat less
stringent standards and higher emissions limits set for Los Angeles
without the margin of safety inherent in the Federal air quality stan-
dards.
Although it is commonly agreed that the Los Angeles situation is
rather unique in the United States, this example demonstrates that
emission allocation is subject to some implementation problems for cases
in which emissions are at or above the allocation limits. Clearly, it
can lead to urban growth limitations in severe cases. Alternately, a time
schedule for reducing emissions to the allocated levels may be included in
the proposed allocation procedure.
This measure does not provide a clear breakpoint or transition from
the implementation plan strategy for attaining the air quality standards
to the maintenance plan strategy for maintaining them thereafter. This
is probably an advantage of the measure for air pollution control
agencies, but it does open an emissions allocation plan to unjust criticism
of not being able to maintain standards, when the problem actually is
that the implementation plan was inadequate in originally achieving the
standards.
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Another conflict centers on the transportation interface. As with
emissions density zoning, spatially defined emission rates might force
more spread development, resulting in an increase in vehicle miles
travelled. Lower densities would inhibit the use of mass transit, thus
compounding the problem. This is a speculative point, however, and
needs documentation. It does, however, suggest that regional land-use
and transportation plans providing for a limit on trip generation are
required.
e. Practical Limitations. Practical limitations include:
1) The assignment of powers over land-use to a regional
or State agency. Municipalities will feel that they have lost some
control over land-use decisions to an agency removed from direct popular
control.
2) The possibility the regional agency will make land-
use decisions ignoring other important social needs. Comprehensive
planning agencies will argue that "the tail is wagging the dog" in
regional land-use planning, since air pollution control should be just
one of the factors that influence regional land-use decisions.
3) The difficulty of defining an air shed or air basin.
With a significant amount of "background" drifting into the region, the
emission limitations would be subject to an error factor. Clearly, the
strategy is best designed for well-defined air basins as is the case in
California. Operational difficulties would be greater in the Northeast,
for example.
4) The lack of an adequate institutional structure to
deal with emissions rights. Economists contend that clean air has an
economic value and can therefore be assigned a market price. The
maximum allowable emissions would represent the supply of air rights for
a region, the price of which would be determined by the demand. The
supply of air rights would remain fixed, so that an increase in demand
would cause an increase in the price of the assimilative capacity of the
air. Conceptually, the air pollution agency could develop a market
mechanism allowing for the transfer of the rights to highest bidder. A
new source could also "buy" emission rights from an existing source who
would then be required to commensurably reduce its emissions. The
concept of "highest and best use" common in land-use law would apply,
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with price as the decision criterion. It is unclear what effect such a
mechanism would have in terms of land value and locational patterns in
urban regions, but the impact would probably be significant.
4. Evaluation of Control Measure Effectiveness
a- Ability of Measure to Maintain Standards. Emission
allocation should not be viewed as a one-time procedure. Continued
monitoring and recalculation of the relation of emissions to assimilative
capacity would be necessary. The logic of assigning a set quantity of
emissions to each planning subarea would seem to encourage a refinement
of the initial, rather crude allocation procedures. Ideally, roll back
and modeling approaches should be combined to minimize error. The land-
use-based emission factors would have to be reevaluated periodically to
incorporate any changes in emission rates resulting from improved
technology, fuel changes, etc.
As a technical procedure, emission allocation is a powerful tool.
Politically, the problem of strict adherence to allocations would be the
major difficulty. Retention of control at the State level would mitigate
this political difficulty. States have all powers and only permit local
government to take such actions as the state legislature sees fit. The
problem is not completely eliminated and may even be magnified because
State legislators represent local areas and act to serve local interests.
As with land-use planning, the pressure to grant variances or increase
allocations would be strong. A project review/environmental impact
statement process would have to be conducted on a fairly detailed level in
order to guarantee that allocations would not be exceeded.
b. Relative Efficiency. Among the variety of maintenance
measures, emission allocation is an extremely efficient approach to
maintain acceptable levels of air quality. A direct relationship is
established between emissions and ambient air quality levels. Its major
problem is that, although the logic is simple, the implementation of
the procedures becomes a rather sophisticated process. Multiple levels
of government are involved, and interaction between air pollution
control officers and land-use and transportation planners and controllers
must be close and continuing. In practice, the procedures would require
well-trained professionals at various levels of government.
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B. REGIONAL DEVELOPMENT PLANNING
1. Definition of Measure
Although technology-oriented control measures can go a long way
toward reducing air pollution levels, there is no assurance that they
will produce full compliance and continued maintenance of air quality
standards. It is therefore necessary that air quality considerations be
made an integral part of the regional planning process, and that con-
straints on development be shown in regional plans if they are indicated
to be necessary to maintain standards. Regional development policies by
themselves may have a significant effect on the location of pollutant
emission sources and on the exposure of the populace to them.
From a practical standpoint, it must be recognized that regional
plans, as well as community master plans, rarely carry any legal en-
forceability. They normally constitute a statement of the goals and
aspirations of a region or community. In addition, generalized land-use
objectives may be expressed in the form of a map commonly called the
comprehensive plan or the master plan. Because they lack enforceability,
comprehensive plans are dependent on measures such as zoning and other
land-use ordinances for their implementation.
Notwithstanding, a comprehensive plan is a necessity if implemen-
tation measures are to be coordinated for the attainment of long-term
land-use and environmental objectives.
Four principal elements of regional planning can be used to assist
in maintaining air quality: a) regional form, b) open space planning,
c) stationary source location, and d) transportation planning. Trans-
portation planning is discussed in Chapter II, Section E.
2. Historical Review
a. Current Applications. A survey recently sponsored by EPA
investigated the degree to which regional and town planning agencies
incorporate specific air quality considerations into the planning
process (ref. 1). The recognition of air quality as an important input
or constraint to the formulation of regional plans is far from uniform.
The survey found that only 36 percent of those agencies responsible for
land-use planning explicitly consider air quality implications. Only 33
percent of the agencies responsible for transportation planning give
explicit consideration to air quality. The significance of these find-
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ings is summarized well in the survey report (ref. 1):
These figures are important because planning traditionally has had
its greatest impact in land-use and transportation, and ... these
two activities have important causal links to air quality. There-
fore, it is in these areas that planning could make a significant
contribution to the task of controlling air pollution; or, on the
other hand, it could cause significant problems through neglect.
b. Current Effectiveness. As indicated by the preceding
survey results, air quality is infrequently included as a criterion in
arriving at regional development decisions. Even those agencies
that consider air quality rarely do so in a quantitative manner. There
may be goals for clean air but rarely are there tools for evaluating the
implications of alternative development proposals on air quality.
Thus, an objective observer would be forced to conclude that the
consideration of air quality in regional planning has been largely
ineffective.
c. The Vermont State Land-Use Plan. To control unplannned
development and to protect State interests, State land-use plans have
been implemented in Vermont, Maine, and Hawaii. Because the three
States were similar in their approach, only one will be discussed here--
the Vermont plan.
1) Background. Spurred by the problems some towns were
experiencing as the result of large second home and ski resort develop-
ments, in 1969 Governor Dean C. Davis formed a Commission on Environ-
mental Control to study the problems resulting from unplanned and rapid
growth in Vermont (ref. 2). The Commission recommended that the leg-
islature immediately adopt a statewide system of land-use planning and
development regulation. The 1970 General Assembly accepted the Commission's
recommendations and enacted Act 250 to establish a statewide process for
dealing with land-use and environmental problems and the public service
costs resulting from development.
Act 250 did two things. First, it established a system for re-
viewing applications for major subdivisions and developments across the
State. District Environmental Commissions, composed of citizens appointed
by the Governor, were established to review applications for development
for compliance with 10 criteria. Nearly all significant development
falls under the Act 250 review process (ref. 3).
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2) Criteria. Before granting a permit, the district
commission must find that the development meets the following 10 criteria
(ref. 4):
a) Will not result in undue water or air pollution;
b) Has sufficient water available;
c) Will not cause unreasonable burden on an existing water supply;
d) Will not cause unreasonable soil erosion or reduction in the
capacity of the land to hold water so that a dangerous or
unhealthy condition may result;
e) Will not cause unreasonable highway congestion or unsafe
conditions with respect to use of the highways existing or
proposed;
f) Will not cause an unreasonable burden on the ability of a
municipality to provide educational services;
g) Will not place an unreasonable burden on the ability of the
local governments to provide municipal or governmental services;
h) Will not have an undue adverse effect on the scenic or natural
beauty of the area, aesthetics, historic sites, or rare and
irreplaceable natural areas;
i) Is in conformance with the duly adopted development plan,
land-use plan or land capability plan; and
j) Is in conformance with any duly adopted local or regional
plan.
A permit may not be denied solely for the reasons set forth in e,
f, and g above, but reasonable conditions and requirements may be attached
to alleviate the burdens created.
In addition to the District Environmental Commissions, Act 250
established an Environmental Board, also composed of citizens appointed
by the Governor, to hear appeals from the decisions of the District
Environmental Commissions and to promulgate rules and regulations to
administer the Act.
Because the criteria of Act 250 were general and could not accom-
plish all of the purposes of Act 250, the legislature also directed the
Environmental Board to adopt a series of three land-use and development
plans. In addition, it was provided that the State plans were to be
further implemented at the local level by authorized land-use controls
such as subdivision regulations and zoning.
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3) Interim Land Capability Plan. The first plan man-
dated by Act 250 was the interim land capability plan, which was basi-
cally a statewide inventory of: present land uses; physical limitations
on development (e.g., steep slopes, shallow depth to bedrock); potential
for agriculture, forestry, or mineral extraction; and unique or fragile
areas, such as high elevations or wetlands. The interim land capability
plan was adopted by the Environmental Board and approved by the Governor
in March, 1972.
4) Capability and Development Plan. The second plan
called for by Act 250 was the capability and development plan, which was
enacted by the General Assembly in 1973. The capability and development
plan was to be consistent with the interim land capability plan and to
promote a coordinated, efficient and economic development of the State.
The capability and development plan establishes policies and criteria
designed to:
a) Minimize the adverse impact of development on lands with high
potential for agriculture, forestry, or mineral extraction or
with significant natural, recreational, scenic, or other
resource value;
b) Protect the public from having to assume an unreasonable or
or unscheduled burden in providing facilities and services to
support scattered development; and
c) Safeguard the public investment in utilities, facilities
building, and lands.
The policies in the capability and development plan were adopted to
provide guidance in preparing the State land-use plan and town and
regional plans.
5) The Land-use Plan. The final and most important
plan mandated by Act 250 was the land-use plan, which failed to pass the
1974 legislative session, but will likely be enacted next year (ref. 5).
The land-use plan is to be based on the capability and development plan.
It is to consist of a map and statements of present and prospective land
uses, which determine in broad categories the proper use of lands in the
State whether for forestry, recreation, agriculture, or urban purposes.
In drawing up the State land-use plan, consideration is to be given to
duly adopted regional and town plans, capital programs, and municipal
bylaws pertaining to land-use. However, once adopted, the State land-
use plan and the capability and development plan are to be implemented
at the local level by authorized land-use controls, such as subdivision
regulations and zoning.
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6) The Effectiveness of Act 250 (ref. 6). Although Act
250 has brought development close to a halt in some areas, this is
relatively uncommon. In a study of the early period of the Act's
administration, it was concluded that Act 250 had no significant impact
on the rate of development and that most of the apparent slowing effect
was attributable to the general state of the economy.
Examination of the permits processed by the District Commissions
during the first 3 years of Act 250 indicate that only about 3 percent
were denied. Although the Division of Protection is empowered to en-
force the rules of the District Commissions, it has undertaken very few
legal actions, preferring to use the threat of such sanctions to obtain
compliance. The enforcement of the act is aimed much more at inducing
compliance rather than punishing noncompliance. In considering appli-
cations for projects in which air pollution was an issue, the District
Commissions have been quite free in imposing conditions on permit
acceptance.
There can be little doubt as to the potential effectiveness of
State land-use plans such as Vermont's Act 250 in controlling the air
quality impacts of new development. It could well serve as an example
of a control measure that more progressive States might adopt as part of
the AQMP's.
3. Implementation
a. Mechanics of Incorporating Air Quality into the Regional
Planning Process. To incorporate air quality considerations and con-
straints into the regional planning process, existing regional and
community comprehensive plans must be scrutinized to determine their
future compliance with air quality standards. Perhaps the best process
for doing this is the use of environmental simulation models. If the
analyses show that existing plans would result in future problems main-
taining air quality standards, alternative plans should also be inves-
tigated to determine those more acceptable on the basis of regional air
quality.
A recommended methodology for considering air quality in
the planning process is presented in Guidelines for Air Quality Maintenance
Planning and Analysis, Volume 4. Land Use and Transportation Considerations.
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Conceptually, the air quality simulation process is very
straightforward. Basic requirements consist of the location of
emission sources and their emission rates, along with a method to
relate emissions to pollutant concentrations. Ultimately, it is the
concentration of pollutants in the air that is of vital interest.
In spite of this conceptual simplicity, the air quality modeling
process is extremely complex. Using the future land-use plan as a base,
estimates must be made of the magnitude of area and point source emis-
sions throughout the urbanized area. This in itself is a highly complex
task, since estimates must be made of the specific emission character-
istics of developments that show up on long-range plans defined in
rather broad categories. In addition, estimates of future control
technologies must be made. The output of the stationary source emis-
sions model should be a display of the location and emission rates of
all significant area and point sources in the metropolitan area, for
each pollutant of interest.
Based on the future land-use plan and the future transportation
network, estimates must be made of the line source emissions from the
transportation system. Since the emission rate of mobile sources is
generally dependent on traffic flow rates, operating speeds, and trip
origin-destination characteristics, the modeling of mobile source emis-
sions is necessarily a complex task. It typically involves going
through the complete transportation modeling process of trip generation,
trip distributions, modal split, and traffic assignment to determine on
a link-by-link basis the traffic flow rate and operating speeds.
Because of the importance of cold-start and hot-soak emissions, trip-end
information (i.e., the origins and destinations in each zone) should be
utilized as well. Once the transportation system operating character-
istics have been determined, emission factors must be applied to arrive
at mobile source emissions. Most of this transportation simulation is
required in the 3-C planning process.
As complex as the foregoing procedures are, they are only the
beginning. The stationary and mobile source pollutants identified in the
emission modeling process must be input to appropriate atmospheric
dispersion models to translate raw emissions data to the parameter of
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real interestconcentrations of pollutants throughout the region.
Because the emission and diffusion characteristics of pollutants differ,
separate dispersion models must be exercised for each pollutant of interest.
Particularly complex is the modeling of the photochemical oxidant formation,
since it involves the interaction of hydrocarbon and nitrogen oxide
emissions, their mixing in the atmosphere, and solar energy.
Although the environmental simulation process is very costly and
highly complex, it does provide a framework for evaluating alternative
long-range development plans. It permits the identification of subareas
with unacceptable air quality, making it possible to prescribe remedies
in the form of rearranging land uses. The simulation should ideally be
an iterative process until an acceptable arrangement of future land uses
is achieved. Perhaps the most realistic means of minimizing the high
cost of simulation would be to include an environmental simulation
element in the 5-year regional planning update cycle.
The following sections present techniques that can be employed to
improve regional plans to bring them in compliance with ambient air
quality standards.
b. Regional Form. Studies have been performed in several
urban areas to relate air quality to regional development patterns. In
a study of the Hartford, Conn, region (ref. 7), it was determined that a
developed area elongated in a direction perpendicular to the prevailing
winds would produce a much smaller area of unacceptable air quality than
the long-range development plan in force at the time. However, the
elongated development pattern did enlarge the area of questionable air
quality.
A similar study in Chicago (ref. 8) indicated the desirability of
concentrating development in relatively high density corridors bordered
by green space. The presence of green areas adjacent to sources of
pollution has been singled out as an important land-use factor in
pollution reduction (ref. 9). A good example of this concept is the so-
called "Wedges and Corridors" Plan for Metropolitan Washington, D.C.
Several studies have focused on the mobile source contribution to
air pollution and the relative desirability of various urban forms.
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Another study performed of Hartford (ref. 10) estimated an increase in
average trip length of 22 percent for an urban form with a single major
center over a form with balanced subcenters. However, due to the
relative importance of trip-end emissions in comparison to running
emissions, the air quality impact of trip-length reductions would be
much less than 22 percent.
A similar study of Montgomery and Prince George's Counties, Md.,
found significant differences in pollutant production for various land-
use and transportation network assumptions (ref. 11).
The importance of creating subregions with a balance of residential
and employment opportunities has long been recognized by planners as a
method of reducing travel requirements. Encouraging balanced subregions
can potentially reduce running emissions significantly, although having
little effect on cold-start and hot-soak emissions.
While a pattern of dense corridors or balanced subregions can
apparently reduce overall urban area emissions, their effect on pollutant
concentrations is not so clear. All other things being constant, lower
population densities will generally improve ambient air quality. Lower
densities imply a dispersion of people, commercial/industrial areas, and
automobiles over a larger area, resulting in lower concentrations. However,
as residential density decreases, trip length as well as trip generation can
be expected to increase and the viability of mass transit is threatened.
With the current state of knowledge, it is difficult to generalize
about the relative importance of reduced emissions of corridor or
satellite city configurations compared with the dispersing ability of
low density development. Important considerations in this tradeoff
include prevailing meteorological conditions, as well as the existing
socioeconomic and transportation system characteristics of the region.
With this dichotomy unresolved, a reasonable compromise is likely
to be the alternating high density-low density radial corridors ex-
emplified by Chicago's "Finger Plan" and Washington's "Wedges and
Corridors."
c. Open Space Planning. The use of open spaces to act as a
buffer between incompatible land uses has been a long-recognized tech-
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nique of community planners. The ability of buffer zones to reduce the
impact of air pollution is primarily related to distance (ref. 6).
Although there are benefits to be derived from trees and vegetation, the
primary benefit results from the decrease in concentration as distance
from the pollution sources increases.
The use of buffer strips along high volume highways has been a
particularly effective means of dealing with traffic noise and air
pollution. Three types of benefits from roadway buffer zones have been
identified (ref. 6):
1) Because development is prohibited adjacent to the
roadway, there are no street canyons to concentrate pollutants, thereby
improving dispersion of mobile source pollutants;
2) Buffer zones help to reduce human exposure to high
pollution levels;
3) The presence of vegetation can further filter
undesirable emissions.
Perhaps more important than the ability of green spaces to absorb
certain pollutants are their beneficial microclimatological effects.
Because much of the radiation is transformed into evaporative energy,
the temperature over vegetated surfaces on sunny summer days may be 10
to 14 degrees cooler than over barren soil (ref. 6). This temperature
differential reduces dust formation. Due to foliage transpiration,
vegetated areas tend to have higher humidity than barren areas, also
resulting in less dust formation and in more rapid settling of suspended
particulates. Another significant effect of wooded areas is their wind-
reducing character.
A variety of open space systems has been proposed based on their
dilution potential (ref. 9). One analyst has suggested alternating rows
of development and open spaces perpendicular to the prevailing wind
direction. In general, however, the distribution of wind directions is
quite variable and it is not effective to arrange land use based on
prevailing wind direction.
Probably the best use of regional open space patterns is the
creation of alternating development corridors and open space wedges
radiating from the city center.
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d. Stationary Source Location. Topics related to stationary
source location are dealt with at considerable detail in other sections
of this document. Therefore, this section will be brief and related
specifically to their consideration in the regional planning process.
In the development of comprehensive plans, large new stationary
sources, notable heavy industry and power plants, should be planned for
areas that can accommodate the additional emissions without exceeding air
quality standards. Since new industrial sites are usually quite restricted
by the availability of utilities (rail connections, power, cooling water,
etc.), the possible selection usually is from a few readily definable
alternatives. Careful placement of industrial development can greatly
reduce the impact of stationary source pollution on the community. To
properly assess the location aspects of stationary source planning, the
planning agency should also consider local climatology, topography, and
meteorology. Consideration also should be given to the location of new
major employment centers close to population concentrations to minimize
travel and thereby reduce automotive emissions.
Because considerations other than air quality often prevail, it may
be impractical to locate industry so as to minimize the impact of air
pollutant emissions. In these cases, the impact of stationary source
emissions can be reduced by controlling the development around the sources
to ensure maintenance of air quality standards. When possible, buffer
areas can be created around heavy polluters to discourage residential and
commercial development. By controlling the development around sources in
a manner that gives proper consideration to air quality, the exposure to
pollutants can be significantly reduced. However, NAAQS must be maintained
in the buffer areas if they are accessible to the general public.
Particular care should be taken in the siting of land uses sensi-
tive to air quality. Among these sensitive receptors are schools,
active recreation areas, housing for the elderly, and medical facilities.
Because the users of these facilities are more susceptible to respira-
tory difficulties than the general populace, special care should be
taken in their placement.
e. The Need for a Regional Approach. While there are air
quality benefits to be derived from local planning efforts, it is
imperative that the overall guidance be provided by a plan with a
regional perspective.
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In their report to the California Air Resources Board, Livingston
and Blayney cited several problems with the use of local planning to
achieve air quality objectives (ref. 12):
1) Oxidant is an area-wide pollutant, the product of a
photochemical reaction between hydrocarbons and nitrogen oxides.
2) The impact of local land-use plans on local air
quality cannot be gaged by a local effort because the proportion of
local pollutants originating elsewhere in the air basin cannot be
determined by local planning agencies.
3) The impact of local land-use plans on air quality in
other portions of the same basin cannot be determined without a regional
approach.
4) The impact of local land-use plans on traffic
volumes cannot be evaluated without regional multimodal traffic models.
5) Local efforts cannot improve local air quality
without comparable efforts basinwide.
In addition to these technical problems, three administrative
problems were identified that would make implementation of locally
prepared air pollution control measures difficult.
1) No effective administrative structure exists to
resolve interjurisdictional conflicts.
2) Lack of a unified approach between local air quality
control measures and regional transportation plans could result in the
violation of air quality standards.
3) Where there is insufficient coordination between
local planning agencies and local agency formation commissions, there
may not be adequate analysis of the air quality impacts of proposed
incorporations, annexations, special district formations, or expansion of
special district areas.
As pointed out by Livingston and Blayney, these obstacles would
seriously impair the effectiveness of air quality plans drawn up at the
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local level. Although local plans may be vital elements of a region-
wide plan, the overall responsibility for a metropolitan area air
quality maintenance plan must be at the regional or State level.
4. Effectiveness of Regional Plans in Maintaining Air Quality
Long-term regional planning can be an important element of air
quality maintenance plans. The form of regional development can sig-
nificantly affect the distribution of pollutants in the region. Open
spaces can be used as buffer zones to encourage diffusion and reduce
exposure. Controls can be exercised over stationary source placement
and the land uses around stationary sources. Regional environmental
simulation models can be used to evaluate future land-use proposals.
While these potentials exist, plans must be drawn up at the regional
or State level, and they must be implemented forcefully if any of the
potentials are to be realized. At the State level, the Vermont Land Use
Plan offers considerable promise as a framework for ensuring air quality
considerations in the long-range planning process.
C. EMISSION DENSITY ZONING
1. Definition of Measure
There is some variation in the description of emission density
zoning in the literature. In this document, emission density zoning is
defined as a regulation that requires emissions of a pollutant to be
limited to prescribed levels within defined spatial areas. A limit is
established in terms of an amount of emissions per area per time period,
such as pounds of particulates per acre per year. Such a limitation may be
administered by an air pollution control agency in conjunction with
planners and zoning administrators.
Emission density zoning may be applied to existing and new sources.
For example, it may be estimated that a heavy industrial zone could
contain only those plants that would emit no more than 3 tons of total
suspended particulates per square mile of lot size per day. A light
industrial zone might have a ceiling of no more than 1 ton per square
mile per day. So also commercial, institutional, and residential areas
might have limits established.
The purpose of such a spatially defined emission limitation tech-
nique would be: a) to ensure that concentrations of pollutant emis-
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sions in a small area ("hot spots") would be avoided, and b) to main-
tain local and regional air quality at prescribed levels.
Emission density zoning could probably only be administered for
stationary source emissions, so the measure is most applicable for
sulfur oxides and particulate pollutants. There is no conceptual reason
why emission density zoning could not be applied to other pollutants,
such as carbon monoxide, hydrocarbons, or oxides of nitrogen, for the
portion of total emissions produced by stationary sources. For example,
the emissions of hydrocarbons from petroleum refining and storage might
be regulated through emission density zoning. Rather, the problem is an
operational one, centering on how the emission rates would be set. The
determination of how to set emission limits will be discussed subse-
quently in this section.
Emission density zoning forms a framework favorable to implemen-
tation of another conceptual measurethe use of pollution or emission
rights which are available in a predetermined fixed supply related to
land area and transferable from one landowner to another. The total
emission rights for a property would be equal to its area times the
allowable emission rate per unit area under the emission density zoning
regulations. In order to prevent the extreme concentration of emission
rights at a few sources, the rights would probably only be transferable
to adjacent properties or within a land-use area comprising a single
zone.
2. Historical Review of the Measure
a. Current Applications of the Measure. Emission density
zoning is not presently being utilized by air pollution or planning
agencies in the strict sense discussed above (ref. 13)\ There is no
current situation in which a comprehensive set of emission density
zoning regulations containing emission limits per unit area per time
period is actually being administered. However, there are two examples,
Jefferson County (which includes Louisville), Ky., and Cook County, 111.,
in which an emission density approach has been tried (ref. 14).
In order to promote the maintenance of air quality in Jefferson
County, the Air Pollution Control Board developed a technique that
places an overall ceiling per unit area on the maximum tolerable emis-
sions consistent with air quality objectives. Both existing and
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new growth is incorporated within a common framework of emission esti-
mation. The Board developed an emission density framework which states
that any new or modified stationary source will be allowed to locate
only if the emissions generated by the source, when added to the sum of
emissions from all point sources within a 1-mile radius of the proposed
or modified source, do not exceed 4,000 tons per year of particulates or
8,000 tons per year of sulfur dioxide. If it is anticipated that either
of these annual emission densities would be exceeded, the required
permit for construction would be denied. A permit denial can be re-
scinded if the applicant demonstrates to the satisfaction of the Board
that the new source would not prevent the continued maintenance of
NAAQS.
The determination of the amount of annual allowable emissions was
made through use of the widely available Air Quality Display Model
(AQDM). A set of emission rates was run through AQDM, with the 1-mile
radius circle translated into a square of corresponding size, and the
emissions treated as an area source. It was determined that 4,000 tons
per year of particulates and 8,000 tons per year of sulfur dioxide were
the maximum amounts that could be emitted from the square without violat-
ing air quality standards.
Clearly, the Jefferson County example is not emission density
zoning in the formal sense. The case is interesting, however, as an
attempt to apply emission limits that are tied to a spatially defined
area. While the regulation does not prescribe allowable emission
densities per unit time for fixed land areas or provide specific emis-
sion limitations for new sources, it achieves much the same purpose as
emission density zoning.
The other area of interest is Cook County, 111. The Cook County
Environmental Control Department had emission density zoning regulations
from 1963 until 1972. They were subsequently replaced by a process
weight rate approach. The old regulations divided the county into three
zones, based on zoning ordinance designations. Each zone had its own
emission limits, in terms of pounds per acre of lot area per hour, with
adjustments for tall stack heights.
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The Cook County example is emission density zoning, in that the
permit to construct and operate was tied to the meeting of emission
regulations that were stated in terms of pounds per acre per hour. The
regulations were administered by the Environmental Control Department.
As such, the ordinance was not directly tied to the planners or zoning
administrators.
Both the Jefferson County and Cook County cases illustrate the
emission density zoning principle, in that both sets of regulations
relate emissions to land area. Cook County, however, actually imple-
mented an emission density zoning ordinance, while Jefferson County
utilizes an emission density ordinance that aggregates all sources
within a defined spatial area.
b. Effectiveness of the Measure. An indication of the
measure's effectiveness is evident in the decision by the Cook County
Department of Environmental Control to replace its emission density
zoning ordinance with a point source emission limitation ordinance.
Basically, the emission density zoning ordinance favored the larger and
wealthier industries, that could more easily afford to buy additional
land if they exceeded allowable emission levels with their existing
acreage. Because the regulation discriminated against smaller indus-
tries, equity considerations were probably the major reason that Cook
County rejected emission density zoning in favor of conventional source
emission regulation.
The Jefferson County emission density ordinance, developed in 1972,
is still too new for an analysis of its effectiveness. Emmission
density zoning regulations have not yet been applied in a sufficient
number of cases to make a firm judgment as to their potential utilization
as air quality maintenance measures.
3. Implementation
a. Measure Implementation. The purposes of emission density
zoning are twofold: 1) the avoidance of "hot spots" from highly con-
centrated groups of polluters, and 2) the maintenance of air quality
standards. The Jefferson County, Ky., case discussed earlier is an
attempt to avoid "hot spots" and thereby ensure acceptable levels of air
quality.
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Emission density zoning can be implemented in two different ways:
1) point source regulations can be maintained and emission density
regulations adopted to cover only new or modified point sources, or 2)
a set of emission density regulations can be used to replace point
source controls. The probability of discarding point source emission
regulations is relatively low for most situations. Therefore, the
subsequent discussion focuses on utilizing emission density zoning as a
supplement to point source regulations.
Basically, the use of emission density zoning would involve the
following steps:
1) The determination of the emission rates, specified in
amount per area per time period, that would maintain air quality at
acceptable levels.
2) The development of regulations that encompass the
emission rates established and that require each new or modified source
to submit lot size data along with emission .estimates.
3) The structuring of a feedback mechanism that would
periodically assess air quality maintenance and, if necessary, alter the
spatially defined emission rates. The existence of this feedback
mechanism would require that the regulations contain a systematic
procedure for changing emission rates.
The first step, determination of allowable emission rates, is the
key to emission density zoning. The determination of emission rates
involves the following steps:
1) The selection of land-use categories for which
emission rates would be specified in the emission density zoning reg-
ulations.
2) The determination of the amount of land in the
different categories that would be expected to emit at no more than the
specified emission rates.
3) The calculation of the emission rates that would not
violate air quality standards, by means of a proportional or atmospheric
dispersion model.
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The selection of land-use categories is a necessary first step to
establishing emission density zoning regulations. In the work done to
date, industrial control has been the prime objective of emission
density zoning regulations. Industry has typically been divided into
two classes, light and heavy. The light industrial classification has
included SIC two-digit classes 20-25 and 34-39, while heavy industry has
included SIC 26-33 (ref. 15). In some instances, other land-use cate-
gories have been added, such as commercial and residential (ref. 16).
Because emission density zoning regulations have been for stationary
sources of particulates and sulfur dioxide, the emphasis on industrial
land use is to be expected.
Theoretically, emission density regulations could encompass the
full spectrum of land-use categories found in metropolitan areas.
Allowable emission rates could be determined for all the different land-
use categories. However, the practical effects of establishing spa-
tially defined emission rates for residential land uses could be to
discourage higher density residential areas. The discouragement of
higher residential densities through emission density zoning regulations
may be counter to the planning and zoning objectives of the study area.
The second element in estimating the allowable emission rates in
the regulations is determination of the amount of land assigned to the
different categories. Argonne National Laboratory has run an atmos-
pheric dispersion model estimating the air quality in the Chicago
region (ref. 17). In one case, the model was run for total suspended
particulates using current land-use and emission rates adjusted to meet
Federal ambient air standards. It was estimated that heavy industry
could emit 3.3 tons per day per square mile and light industry 0.85 ton
per day per square mile. When the model was rerun with currently zoned
land, the allowable emission levels dropped to 2.5 tons per day per
square mile for heavy industry and 0.55 ton per day per square mile for
light industry.
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Since land zoned heavy or light industrial includes a larger portion
of the study area than land presently in use, these results are under-
standable. Assuming that the air shed has a fixed assimilative capacity
for a given set of meteorological conditions, there is a trade-off in
the emission density zoning maintenance measure between allowable emis-
sion rates and the amount of land in the different land-use categories.
Thus, the specification of maximum emission rates by land use must
consider the amount of available and classified land in each category.
Assuming that point source regulations would be maintained for both new
and modified sources when emission density regulations are introduced,
the spatially defined emission rates would be applicable only to new or
modified sources. As such, emission density zoning would act as a
second check on the contribution of the polluter to air quality degra-
dation.
Determination of the amount of land to be included in each category
should consider the amount of land currently in use by category and the
amount currently zoned for each use. All existing sources would be
allowed to emit at levels controlled by point source regulations, pro-
viding that they did not subsequently dispose of plant property and, in
doing so, exceed emission density limits. The land available for
development in the different land-use categories would be the difference
between current land-use area and current zoned land area.
An atmospheric dispersion model could then be run with the existing
sources emitting at rates controlled by point source regulations, and
the land available for development emitting at spatially defined rates.
In this way, alternative emission rates for the different land uses
could be tested. The rates developed would ensure that air quality
would be maintained with development according to current zoning. Of
course, other estimates of future growth could be used besides the
zoning map. The general development plan of the study area is also a
possibility, as is the use of urban development simulation models.
The final step in determining the allowable emission rates is their
actual calculation. Either an atmospheric dispersion or proportional
model is most suitable, although the Hanna model or others may also be
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employed.* The proportional model assumes that increases or decreases
in pollutant emission density over an air basin result in a directly
proportional change in the ambient concentrations of pollutant in that
area (ref. 18). The proportional model does not simulate the transport
or diffusion of the pollutant, and as such is the crudest and simplest
technique to employ.
To use the proportional model, the maximum density of allowable
emissions would be determined from existing air quality data, the air
quality standard, and existing emission densities. The difference
between this emissions ceiling and the expected future contribution of
present sources would be the amount available for spatially defined
emissions from new sources or modifications.
The basic relationships are as follows:
ETOT = EEXS + EEDZ
n
EEDZ = ? Ai Ri + ENS
where:
ETOT = Total allowable emissions of pollutant in study area.
EEXS = Estimated future emissions of pollutant by existing
sources.
EEDZ - Estimated future emissions of the pollutant from sources
to be controlled by emission density zoning regulations.
A. = Area of land in land-use class i.
R. = Emission rate per area per time period for land-use
class i.
ENC = Estimated emissions of pollutant from new sources not
regulated by emission density zoning.
*Dispersion modeling is preferred over proportional modeling. The latter
should by used only when sufficient data is not available to use a
dispersion model.
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This specification of basic relationships illustrates how emission
rates could be calculated. Given an assumed distribution of land uses,
the rates would be chosen so that the total amount emitted does not
exceed a preset limit, EEQZ. An infinite set of alternative emission
rate combinations is possible if more than one land-use category is
involved. The rates would have to be chosen through an analytic or
simulation model. In the simulation approach, alternative sets of
emission rates would be tried, and the one that is most reasonable in
terms of some defined objective, such as reducing economic disruption,
would be selected. In the analytic approach, mathematical programming
could be used, provided that some criteria are established and that a
satisfactory objective function is developed (ref. 19).
If an atmospheric dispersion model is utilized, determination of
allowable emission rates would be based on maintenance of air quality
standards as calculated at specified receptor points. All existing
polluters would be treated as point sources and assumed to emit at
future controlled levels. Emission rates would be established by treat-
ing the spatial distribution of expected future sources as area sources.
Given a current emissions inventory and an estimate of future develop-
ment, alternative emission rates for the different land uses could be
entered in the model. With appropriate criteria for evaluation, the
simulation of alternative sets of rates could produce one set superior
to the others tested.
Emission density zoning requires more than the determination of
emission rates by land use. Regulations would have to be developed to
administer and enforce these spatially defined rates for the selected
land uses. Specification of maximum emissions per area per time period
would be made for new sources located in each land-use zone with pos-
sible allowances for the effect of stack height (see ch. Ill, sec. H,
Stack Height Regulations). In no case will credit be given for stack
heights above good engineering practice.
Proposed new sources would need to comply with multiple emission
requirements and supply information which could be used to determine
emission rates. Therefore, a permit system would be a necessary com-
ponent of an emissions density zoning measure. The permit system would
also facilitate coordination between the enforcement and planning agencies
in administering the regulation.
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Since point source regulations would also be enforced on the new
installations (see ch. Ill, sec. A, New Source Performance Standards), the
emission density zoning regulations would be a second checkpoint on new
development. The regulations would have to specify that violation of
either point source or emission density zoning requirements would be
grounds for permit denial.
The procedure for granting any variances to the emission density
zoning regulations would have to be carefully devised. Variances would
easily disrupt implementation of this measure and seriously hamper
maintenance of air quality. One possible means of providing for vari-
ances is the use of emission rights, through which an industry unable to
meet the emission density zoning regulations could buy the rights to
more emissions from neighboring landowners rather than purchase more
land (ref. 20).
Finally, the development of emission density zoning regulations
should include a feedback mechanism to allow changes in the emission
rates. At any point in time, the rates set are a direct function of
expected future development. Through continuous monitoring of the
development of the study area, an information base could be developed to
determine if the emission rates should change.
Since the emission rates apply only to new or modified sources, the
actual development pattern for the area becomes the basis for the
changing of the emission rates. With this kind of feedback mechanism
built into the regulations, air quality maintenance is assured.
b. Conditions of Applicability. As previously discussed,
emission density zoning can most effectively be used for control of
stationary source emissions in industrial areas. Implementation would
be aided if land uses were in separate, clearly defined zonesindus-
trial, residential, commercial, and institutionaland future land use
would also be assigned to well-defined areas.
Because of the extensive problems associated with emissions from
existing sources in a complete conversion from individual source emis-
sion regulations to an emission density zoning approach, the latter
measure is most often proposed as an overlying or secondary provision
that would be used in addition to source emission regulations. As such,
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its impact on air quality maintenance is limited to restrictions on new
or modified sources. Alternately, emission density requirements for existing
sources could be phased-in over a long period of time.
c. Interactions with Other Measures. The primary inter-
actions of emission density zoning are with point source controls,
including stack height regulations and NSPS. Utilizing emission density
zoning while maintaining point source regulations raises the question of
how to handle the alternatives that may face an applicant for a permit
to construct and operate. He may be denied a permit if the emission
levels are too high under either or both of the two sets of regulations.
Should the applicant not meet the point source regulations, certain
changes could be made in the plant structure in order to ensure com-
pliance. These changes in facility or operations would be required
regardless of whether the emission density zoning regulations were
violated.
However, if only the emission density zoning regulations were
violated, the applicant would be faced with a set of alternative choices.
First, the amount of emissions generated could be reduced through control
equipment or process changes similar to those required by point source
regulations. Second, the amount of land owned by the applicant could be
increased in size. Third, the emission rights to other parcels in the
land-use zone could be purchased, if this were acceptable under the
regulations.
Beyond the already described interactions between point source
controls and emission density zoning regulations, there is a further
relationship between emission density zoning and emissions allocation
procedures (described in sec. A, above, Emissions Allocation). Basi-
cally, emissions allocation procedures set emission lids for subareas of
the AQMA but do not specify how these subareas should maintain emissions
below the ceiling. It would be feasible for an AQMA to utilize emis-
sions allocation techniques for subareas, and then have emissions within
each subarea controlled by individual emission density zoning requirements.
d. Potential Conflicts and Negative Impacts. The spatial
component of emission density zoning does suggest that its use would
relate to community development objectives and plans. In particular,
the use of emission density zoning tends to spread development to the
extent that an industry would need to purchase enough surrounding acreage
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to meet the spatially defined standard. Lack of experience in implementing
density zoning precludes any quantitative estimate of its impact on
sprawl. Clearly, the potential disadvantages of lower density develop-
ment must be balanced against the elimination of the "hot spot" problem
and long-term maintenance of air quality.
Emission density zoning is best suited to industrial land uses. If
this maintenance measure is restricted to industrial land use only, then
the impact on total community development, in terms of restructuring
densities of population and jobs, is minimal. A small impact in dis-
persing employment centers might occur in certain land-intensive, highly
polluting industries.
The potential negative environmental impacts of emission density
zoning center on the transportation and land-use interface. If spa-
tially defined emission rates force more dispersed development, an
increase in vehicle miles can be expected. Increased transportation
source emissions is not a necessary and direct consequence of emission
density zoning; much would depend on the actual locational decisions
made as a result of emission density zoning regulations. However, the
potential interaction should be taken into account.
e. Practical Limitations. There are two major political and
social limitations on emission density zoning: 1) the ramifications of
its spatial component on individual and group perceptions of steps
necessary to maintain air quality, and 2) the interactions between
land-use planners and air pollution control specialists. Should citizens
object to or not understand an enforced relationship between air pollu-
tion and land area, administration of the emission density zoning reg-
ulations would be difficult. For example, emission density zoning has
already been criticized as favoring the large polluter over the small
one because large firms have more access to capital to buy any necessary
additional land.
Under many circumstances, emission density zoning may not be
perceived as inequitable. The concept of emissions limitations per unit
land area as a feasible means of maintaining air quality standards may
gain public and industrial support in areas where no apparent conflicts
with community development goals are apparent. Unlike emission allo-
cation procedures, in which the maintenance of air quality is left to
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local option in terras of who pollutes and how much, emission density
zoning offers a predetermined, explicit set of regulations.
In addition to potential problems with citizen understanding,
emission density zoning may be limited by the interactions between
planner and air pollution specialist. While the enforcement of the
emission density zoning regulations would probably be under the control
of an air pollution control agency, zoning and regional development
planning would probably be the responsibility of the planners and zoning
administrators. The development and enforcement of emission density
regulations would be difficult unless appropriate administrative link-
ages are established. In particular, the calculation of emission rates
is dependent on a reasonably detailed estimate of future development.
Thus, communication between planners and air pollution specialists must
be established on a continuing basis in order to ensure that the appro-
priate estimates of future growth are used.
Economic limitations on the application of emission density zoning
are primarily related to the additional costs imposed on the sources
beyond those required by point source regulations. These costs could be
in the form of buying additional antipollution equipment or changing
processes, buying additional land, or perhaps purchasing emission rights
from others. Argonne National Laboratory compared the cost of point
source control and emission density zoning (without simultaneous source
emission limitations) for Chicago, and determined that costs were
approximately equal (ref. 21). Extrapolating from this example, it
could be argued that in most cases the additional cost of emission
density zoning over point source regulations would be minimal. However,
in heavily developed AQMA's large polluters that are land-intensive may
be seriously affected and may incur great additional costs. This result
may not be unreasonable from an air quality maintenance perspective.
4. Evaluation of Control Measure Effectiveness
a. Ability of Measure to Maintain Standards. Emission
density zoning is designed specifically to maintain air quality stand-
ards throughout a regional area such as an AQMA. Within the limits of
accuracy of the emissions data and modeling procedures used in estab-
lishing its allowable emission rates, this measure should be totally
effective in maintaining the standards either by itself or when used as
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a second emission limitation requirement in conjunction with conventional
source emission regulations on stationary sources.
The measure requires some monitoring and feedback mechanism to
provide for adjusting the allowable emission rates based on measured air
quality data during subsequent periods, as the new sources are added to
the zones. With the flexibility of such a feedback, any inaccuracies in
the original emission rate development procedure can be corrected, and
air quality maintenance can be ensured.
b. Relative Efficiency. Emission density zoning is only one
of a number of maintenance measures that can be applied separately or in
combination in AQMA's. As previously discussed, emission density zoning
can be used in conjunction with point source regulations and could be a
companion measure to emissions allocation procedures. In the framework
constructed in this section, emission density zoning has no substitutes
and hence cannot be directly compared with other measures. If, however,
the option of using emission density zoning in place of point source
regulations is considered, then the previously noted work at Argonne
National Laboratory is pertinent. Their studies concluded that point
source regulations and emission density zoning have similar costs and total
emission reductions.
Emission density zoning and the emission density ordinance of
Jefferson County, Ky., may also be compared. Both approaches are
directed to the "hot spot" problem. If the "hot spot" is isolated and
general air quality in the AQMA is not approaching the standards, either
measure should be capable of maintaining standards. It is not clear
that the Jefferson County ordinance would ensure air quality maintenance
in the long run under present emission ceilings.
D. ZONING APPROVALS AND OTHER INDIRECT REGULATORY CONTROLS
1. Definition of Measure
As mentioned in the section on regional plans, they can be
only as effective as their implementation. While the comprehensive plan
may be useful in enumerating a region's goals and aspirations, as well
as in identifying desirable future land development characteristics from
an air quality maintenance standpoint, it is meaningless unless the plan
is adhered to in the day-to-day decisions of municipal governments,
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which over the long term determine the shape of future growth. This
section discusses techniques for plan implementation, identifies short-
comings in the implementation process, and also examines some of the
more innovative approaches to land-use management across the country.
The land-use management techniques described in this section are
primarily concerned with the larger issues of controlling and directing
urban growth and only indirectly with the long-term maintenance of air
quality. Nonetheless, they do have significant implications for air
quality and should therefore be considered in the development of AQMP's.
These techniques include:
Zoning
Subdivision regulations
Capital facility ordinances
Development timing controls
Moratoria
Transferable development rights
Tax policy
Capital improvement programming
Critical environmental area control
A-95 review process
The implementation measures discussed can be used to channel growth
into areas that can contain it, while discouraging growth in already
overburdened areas. Because the land-use management measures act primarily
to restrict growth, they are not feasible techniques for AQMA wide
application. It is assumed that an accurate picture of existing and
anticipated conditions exists. Only if this is the case can the agency
know where within the AQMA to discourage and where to channel develop-
ment.
2. Historical Review
Many of the planning implementation measures cited above have
received widespread use by community agencies. Zoning and subdivision
regulations are found in the overwhelming majority of local jurisdic-
tions. Capital facility ordinances, development timing controls, and
building moratoria are not uncommon. Transferable development rights,
in the form proposed, are a theoretical land-use management system
without any historical record.
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In spite of the widespread use of land management regulations, the
incorporation of air quality considerations into them is far from a
standard practice. A survey of local, regional, and State planning
agencies indicated that only 41 percent of the agencies with responsi-
bilities in land-use zoning make air quality a consideration (ref. 22).
Only 13 percent of the subdivision regulations and 15 percent of capital
improvement programs consider air quality.. Forty-five percent of the
agencies performing the A-95 review function reported giving consider-
ation to air quality. Even when consideration is given to air quality,
it normally is in a very qualitative manner.
As will be detailed in the following sections, the effectiveness of
traditional land management regulations in achieving community land-use
objectives is highly dubious. Their current effectiveness in promoting
air quality objectives is even more tenuous.
3. The Implementation of Land-use Management Techniques
a. Zoning
1) Background. Zoning is probably the most widely used
method of implementing community land-use objectives. The basis of most
present day zoning ordinances is the U.S. Department of Commerce 1924
Standard Zoning Enabling Act (SZEA), which defines zoning as the divi-
sion of a municipality into districts, and the regulation within those
districts of (ref. 23):
The height and bulk of buildings and other structures;
The area of a lot that may be occupied and the size
of required open spaces;
The density of population;
The use of buildings and land for trade, industry,
residence, or other purposes.
The primary purpose of zoning is to ensure that land uses are
properly situated in relation to each other, and that adequate space is
provided for each land use. It allows the control of development
density so that property can be adequately serviced by public facil-
ities.
The legal basis of zoning lies in the police power of the State to
enact legislation protecting the public health, safety, and general
welfare of its citizens. Although the power to zone lies in the State
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legislatures, this power is usually delegated to the local communities.
Unfortunately, most cities adopted zoning ordinances before formal
comprehensive plans existed. Subsequently, with the studied development
of regional or community comprehensive plans, there have been many conflicts
between land uses specified in area comprehensive plans and in zoning
ordinances. Zoning ordinances can be effective in dealing with regional
problems like air quality only to the extent that they are in conformance
with regional comprehensive plans that are themselves consistent with air
quality objectives.
2) The zoning ordinance. The zoning ordinance normally
consists of a land-use map that defines the boundaries of various land-
use districts, together with descriptions of the regulations attendant
to each district. Major land-use types normally provided for include
residential, commercial, industrial, and governmental. These major use
types are normally subdivided into more specific classifications. For
example, residential may be specified as single family, townhouse, and
apartment. Commercial districts may be subdivided into shopping and
office uses. Industrial classifications may be disaggregated into a
wide range of types. Zoning ordinances normally include regulations on
lot sizes, yard sizes, and the height and bulk of structures, and off-
street parking and loading.
Taken collectively, the regulations normally contained in zoning
regulations could significantly affect long-term air quality. The
relative distribution of residential, commercial, industrial, and other
zoning districts greatly affects the location of stationary and
area pollution sources. The densities inherent in building size reg-
ulations are an obvious factor in the emission rates of air pollutants.
The travel requirements attendant to various land-use configurations
have a major impact on the generation of mobile source emissions.
3) Conventional zoning regulations with particular
potential for reducing air pollution. As noted above, the general
melange of zoning controls can have a significant effect on long-term
air quality maintenance. However, certain elements of zoning practice
may exert particularly effective influences on air quality. They are
discussed in this section.
a) Development intensity regulations. Many of the
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regulations contained in zoning ordinances are directed at controlling
development density, be it residential, commercial, or industrial.
Residential districts commonly include minimum lot sizes and maxi-
mum dwelling units per acre. Many communities have tried to preserve
their rural character by zoning major tracts as large lot zones, often
in the one to five acre range. Similarly, population densities are
often controlled in multifamily residential areas by specifying a maxi-
mum number of units per area. Zoning requirements may also specify
minimum setback regulations, i.e., distance from street line to build-
ing, and the percentage of a lot that may be occupied by structures.
These types of regulations on the density and siting characteristics of
residential units can influence air quality in the community. Popu-
lation density limitations affect the concentration of pollutants from
space heating and trip-end related mobile source emissions. However,
their effect on regional emissions is not so clear, since they may
encourage longer trips, additional trip-making and discourage the use
of mass transit. They also have an undeniable impact on the direction
of urban growth, since large lot zoning and other density regulations will
alter the development economics. Regulations concerned with the siting of
structures, e.g., height limitations, setback requirements, etc., can be
used to encourage adequate dispersion of pollutants. The major objec-
tion to this class of regulations on residential development is their
regressive impact on housing opportunities. As more constraints are
placed on the development of residential land uses, housing may be
beyond the reach of all but the affluent.
b) Parking requirements at new developments. Charac-
teristically, zoning ordinances have required the provision of
off-street parking facilities in commercial and industrial developments.
The line of reasoning was that developers should be required to provide
for the vehicle storage demands of the users of the development. While
parking availability is clearly of considerable benefit to the building
tenants and users, there is an emerging contrary philosophy. The
availability of convenient off-street parking encourages trip-making by
private automobile. In cities with extensive coverage by public trans-
portation systems, it may be appropriate to discourage the development of
off-street parking, thereby increasing the relative attractiveness of
public transit systems.
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c) Planned unit development. Increasingly, zoning
regulations are giving special treatment to the developers of large-
scale projects, under planned unit development ordinances. Most planned
unit developments involve the construction of a variety of housing
types, including apartments, townhouses, and single-family units on a
single tract of land. Some projects involve the planning and construc-
tion of a complete community, including business districts and indus-
trial plants.
Typically, the developer is required to meet overall density re-
quirements and open space requirements. However, he may be given con-
siderable latitude in the location and design of dwelling units within
the tract. Houses may be clustered together on smaller lots, with the
land savings used for common green areas.
Planned unit developments offer considerable potential for improv-
ing air quality. By their provision of extensive green space, they
promote dispersion of pollutants. More significant, however, is the
potential for reduction in trip lengths and the reduced need
for automotive travel.
d) Transient (dual) zoning. A recent proposal by
Murray Mantel 1 has called for the establishment of so-called transient
zoning: to cover all areas of a community that might otherwise be left
unzoned (ref. 24).
It is argued that zoning decisions not in accord with master plans
are much more likely to occur in relatively undeveloped areas that are
in an unzoned category, sometimes indicated on zoning maps as "Agri-
cultural Use" or "General Use". When the owner of a parcel in an un-
zoned area decides to develop his land, it is likely that the request
for new zoning will be in the property owner's best interest, but not
necessarily in the community's best interest. Because the legislative
body rarely has a studied position on the best use of the parcel from a
community point of view, it usually bows to the wishes of the applicant,
particularly if he is an influential member of the community. The poor
precedents become the basis for court decisions, thus making it
difficult to establish enlightened planning procedures.
To overcome this vulnerability of unzoned land to be zoned to
accomodate a higher density development than may be proper for the
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community good, it is suggested that a thoroughly studied "complete"
zoning of the community in accordance with the comprehensive plan could
be enacted. Because zoning is in force for the entire community, it
is much less likely that "spot" zoning will occur, and there is a strong
reinforcement of the concept that all rezoning should be in the public
interest. Mantell recognizes certain shortcomings with "complete" zoning:
It is difficult to plan too far in the future; therefore land that
is many years away from development may be zoned in a manner that future
developments would show to be detrimental.
Landowners without development intentions would object to the
higher taxables resulting from having their land rezoned to higher
valued uses unless the concept of basing tax rates on present actual
use (described below) is used.
There would be objections to complete zoning by those who prefer to
operate from the vacuum of an "unzoned" category where there are greater
possibilities of pressuring early rezoning to a high profit category.
To overcome the major objections to complete zoning, Mantell
proposes "transient" zoning which would be applied to all areas that
might otherwise be unzoned. Transient zoning could be a prefix to all
normal zoning categories in the community. The transient zoning applied
to a particular tract would be subject to public hearings. The owner
could request (without further public hearings) at anytime a change from
"unzoned" to the ultimate use designated by the transient zoning, which
would then become permanent. Taxes could be maintained as under an
unzoned category, until developed, at which time the property could be
revalued.
Transient zoning, as proposed by Mantell, is not directly related
to air quality maintenance. Nonetheless, by encouraging orderly, con-
trolled growth, transient zoning could be an important element in the
land-use planner's efforts to control the long-range development patterns
in the community and indirectly its air quality.
4) Zoning ordinance administration. The day-to-day
enforcement of the zoning ordinance is normally carried out by a
zoning officer. Nearly all zoning ordinances provide for the review
board to hear appeals on the zoning officer's decisions, and to grant
relief from literal enforcement of the ordinance in certain hardship
cases.
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Unfortunately, in many communities zoning ordinances have been
rendered ineffective by poor enforcement, by improper use of special
exception, by an overwillingness to grant variances and special
use permits, and by the tendency of the legislative body to adopt
unwise amendments based on the applications of individual property owners.
Economic and political pressures have long led to abuses of variance and
special exception procedures. In many communities, zoning ordinances
are distinguished by their nonenforcement.
A candid evaluation of the administration of zoning ordinances was
recently made by a prominent member of a Northern Virginia county's
Board of Supervisors (ref. 25):
It is not realistic to assume, nor to expect, that
officials serving on these zoning boards are always
going to rule with wisdom and the highest motivations.
The outcome of a zoning case is often determined, not
by objective, critical analysis of data, but by such
irrelevant factors as the ambitions of a public official,
personality clashes with the decision-making body, or
even the time of day.
As pointed out by Mantel! (ref. 24):
All too often planning and zoning each go their own way,
and the monthly meetings of the legislative body results
in zoning changes and variances which are not in accord
with the comprehensive master plan. The monthly meetings
represent an ad hoc planning process which very quickly
makes the original comprehensive master plan largely
ineffective.
b. Subdivision Regulations. Subdivision regulations are
locally adopted laws controlling the conversion of undeveloped land into
building sites. They normally apply only when an existing tract is
subdivided into two or more lots. Subdivision regulations govern the
layout and design of new developments to ensure their compliance with
the community plans for the area. This provision often includes require-
ments for the reservation of major street rights-of-way, parks, schools,
recreation areas, and other public facilities planned for the future.
There may be a set of requirements designed to ensure that the proposed
subdivision will be coordinated with adjacent developments with respect
to street connections, utility lines, drainage facilities, and perhaps
open space reservations.
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In addition to regulating the design of a subdivision and requiring
the dedication or reservation of land for certain purposes, most sub-
division regulations require the developer to construct or install
certain improvements, often including streets, gutters, sidewalks, storm
sewers, sanitary sewers, water systems, and other utilities.
Although it is difficult to draw any direct correlation between
subdivision regulations and air quality, certain indirect benefits can
be identified. Because it ensures a rational street system properly
tied in with the community system, subdivision regulation may indirectly
improve traffic flow and thereby reduce mobile source emissions. Per-
haps more significant, subdivision ordinances, by virtue of their
regulatory nature on developers, may in small measure reduce the rate of
development.
When compared to other air quality maintenance techniques, sub-
division regulation must objectively be considered of negligible impact.
c. Capital Facility Ordinances. Because of the rapid growth
of many suburban jurisdictions, the need for capital-intensive facil-
ities is increasing beyond the ability of the communities to pay for
them. Rapid population influxes require additional schools, sewage
treatment capacity, fire stations, and the entire array of municipal
services. Because of the need for capital-intensive facilities, which
require large fiscal outlays today, tax rates have characteristically
been increased to the dismay of long-time residents.
An excellent example of this problem is provided by Sterling Park,
Va., a large-scale development in rural Loudon County, currently at the
fringe of the sprawling Washington, D.C., metropolitan area. The
economic impact of Sterling Park was tabulated by the Virginia Farm
Bureau Federation in a 1970 study which found that even though the
10,000 people then in Sterling Park paid $448,000 in property taxes,
the cost of providing public services to them amounted to $2,400,000
annually. The difference was paid by the remaining 27,000 citizens of
the county (ref. 26).
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In an effort to control the public costs of urban development,
Loudon County enacted a new article as part of its zoning ordinance.
Article 12 requires developers to pay for the public facilities to serve
the residents of their new developments. Other Northern Virginia
counties are developing formulas that would require developers to pay
for at least the major part of the public facility costs.
Montgomery County, Md., recently adopted an Adequate Public Facil-
ities Ordinance, which requires that public facilities adequate to
support and service a proposed development must be existing or programmed
for construction within a defined time period before the Planning Board
can grant approval of a Preliminary Subdivision Plan. The necessary
public facilities and services include: public bus, rail, or other form
of mass transportation, and/or roads adequate to carry the anticipated
traffic generated by the proposed development; public sewer and water
service, or private community systems meeting State and county stan-
dards; schools; police stations; firehouses; and health clinics.
The potential impact of capital facility ordinances is quite
significant. By making the developer bear the full costs of his de-
velopment or by requiring adequate public facilities to be in place,
much of the speculative appeal of real estate development is reduced.
Notably, in Loudon County a proposed 12,000 unit development was dis-
couraged by the enactment of Article 12. Similarly, the requirements of
Montgomery County's Adequate Public Facilities Ordinance permits planners
to exert real influence over the location and size of new development.
The ability of these ordinances to plan for long-term air quality
maintenance in undeniable.
A significant objection to these ordinances is their effect on
housing costs. Since any costs to the developer are ultimately passed
on to the home buyer, the ability of low- and moderate-income persons to
purchase homes may be seriously impaired. This objection is a real
concern which must be weighed against environmental gains.
d. Development Timing Controls.
1) Petaluma, California. In an effort to control rapid
urbanization as a suburb of San Francisco, Petaluma, Calif., adopted a
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Residential Development Control System in 1972 (ref. 27). The system
applied to all residential development except small-scale building,
such as subdivisions with four or fewer lots, four or fewer multiple-
dwelling units on a single lot, or a single family residential unit on a
single existing lot. The system established a 17-member Evaluation
Board comprised of a mix of planners, councilmen, businessmen, school
board members, and citizens at large.
Annual quotas were established on a geographic basis based on the
actual number of single- and multiple-family units called for in the
General Plan. Residential developers were required to apply to the
Board for a residential allotment. The Board reviewed all requests for
each geographic area and published a listing based on the conformity of
each development with a set of public facility and design criteria that
included the capacity of existing public services to supply the needs of
the development. The board then presented its evaluation to the city
council, which had the power to award development allotments. In
practice the system limited growth to 500 units per year, and it ap-
peared that Petaluma was well on the way to controlling growth.
Then on January 17, 1974, a U.S. District Court ruled that the
Petaluma law infringed on the constitutional right to travel. The
ruling stated that "no city may regulate its population growth numer-
ically so as to preclude residents from any other area from travelling
into the region (ref. 28)."
2) Ramapo, New York. The Town of Ramapo in Rockland
County, N.Y., was the focus of considerable national attention when, in
1969, the town amended its zoning ordinance to prevent the development
of land for new housing unless the developer of such housing received a
"special permit", regardless of the existing residential zoning of his
land (ref. 29). The permit is granted only if the land to be developed
is located in an area of the town that will be served by a minimum level
of certain community facilities.
Installation of these facilities is scheduled in accordance with
the town's Capital Improvements Program (CIP). The CIP covers the
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provision of sewerage, drainage, parks and recreation areas, roads, and
firehouses. Permits are granted only if the land qualifies for enough
points computed on the basis of values assigned by the proximity to the
proposed development of the five capital improvement items cited above.
The town adopted a capital budget for a future 6-year period for the
development of these facilities. To govern beyond the initial 6-year
period, the town adopted a capital plan for years 7 through 18 which
established two priorities: facilities to be provided in years 7
through 12 and those to be provided in years 13 through 18. The town
allows the owners of property with deferred development potential to
apply for a tax reduction, in recognition of its reduced development
value.
If the developer agrees to provide any of the facilities himself,
he may advance the time of development if he then earns the required
points for a special permit.
Since the development timing approach represents a powerful land-
use control measure, it can be effective as a tool in guiding the loca-
tion and intensity of future growth. Its major drawback is the poten-
tially regressive effect on the housing market.
e. Moratoria. Many communities, faced with sudden large
increases in in-migration, have enacted various moratoria on sewer
connections, water connections, or building permits to enable the formu-
lation of plans for accommodating growth in an orderly and rational
manner.
Petaluma, Calif., prior to enacting its residential Development
Control System, imposed a freeze on development, rezoning, and annex-
ation that lasted more than a year. The purpose of the freeze was to
postpone major land-use decisions until basic goals and policies could
be set (ref. 27).
Several jurisdictions in Metropolitan Washington have instituted
moratoria of one form or another. Fairfax County, Va., in January 1974
passed an "interim development ordinance" which banned the construction
of all subdivisions, townhouses, and apartment and industrial complexes
not already approved by the county, for a period of 18 months (ref. 30).
The purpose of the building ban was to halt growth while the county pre-
pared a Planning and Land-Use System (PLUS), a complete overhaul of the
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county's land-use laws and procedures, including a new master plan, a
total rezoning of the county, and a 15 to 20 year program for the con-
struction of public facilities. The effectiveness of the Fairfax County
ordinance is dubious, as 54,000 homes and apartments could be built
during the ban because they received prior county approval (ref. 30).
Because of this lead time required for the ordinance to become effec-
tive, any slowing of the growth rate will probably occur after the 18-
month ordinance has expired.
Neighboring Prince William County, Va., had a moratorium imposed on
new sewer connections in a major sanitary district by the State Water
Control Board between September 1972 and August 1973. Again, because of
the connections already approved, there was little noticeable effect on
the county growth rate. Whatever effect there is may be evidenced in
the future, but it has not been immediately apparent. Similar moratoria
imposed in Montgomery and Prince George's County, Md., have met with
similar outcomes.
In summary, the effectiveness of temporary moratoria in controlling
growth is unclear. While moratoria must be viewed at best as temporary
holding actions, their effectiveness is not evident.
f. Transferable Development Rights. A comparatively new
approach to land-use planning is the replacement of existing zoning
administration with a system of Transferable Development Rights (TDR).
Advocates of TDR systems point to the failure of current zoning practice
to implement community land-use plans and objectives. As one environ-
mental newsletter has stated (ref. 31):
...many Americans, whether they live in a city row house
or suburban split level, have come to distrust the zoning
process. By and large, it hasn't resulted in well-planned
communitiesand if you doubt that, look around you. It
has not guaranteed the owner of a half-acre suburban para-
dise that he won't see a high-rise blossom behind his back
yard fence, nor the city dweller that traffic-generating
commercial uses won't be permitted to congest his streets.
An objective observer can hardly argue with this conclusion. The same
source goes on to say that:
Zoning has not done the job because there is money
to be madebig moneyin getting land zoned for the
"highest and best" economic use. County boards and
commissions are notoriously susceptible to the persua-
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sive powers of attorneys promising big-revenue develop-
ments that turn out to be more burden than benefit to
tax-paying homeowners.
In an advocacy document on TDR prepared by Fairfax County Super-
visor Audrey Moore, the basic principles of TDR are spelled out (ref.
25):
Separation of land and use of land for purposes of regulation.
Equal compensation for all landowners for development poten-
tial of a plan at no cost to the public.
Taxation of property by use, while keeping to the standard of
fair market value for assessment purposes.
Provision for purchase of land for public facilities at
minimum cost.
Elimination of lengthy procedures involved in government
approval of development.
Provision of an economic mechanism for total approach to
population distribution.
The basic objectives of TDR could be accomplished through the
following procedures:
The community would adopt a comprehensive master plan that
would establish the total number of residents projected to live in an
area and the total number of commercial/industrial needs projected for
that area.
The community would determine how many development rights are
required for each kind of residential and commercial/industrial develop-
ment. Public facility use, farm use, conservation and recreation use,
and utility lines would require no rights.
The government would assign each property owner of record his
rights in direct proportion to the number of acres of land owned, sub-
tracting any development that may exist or development rights considered
by the community to have been vested.
To initiate development, the landowner would file transferable
rights equal to what is required for that development with his site plan
or subdivision plan.
On assignment to particular parcels of their share of development
rights, those rights would be made freely transferable from one parcel
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to another. In order to build, the developer must not only buy a parcel
of land, but also must purchase enough development rights.
When rights are sold or transferred for development, the land they
were assigned to becomes open space at no cost to local government.
The political difficulties in implementing a TDR system are con-
siderable, and it is unlikely that ft could be enacted in the near
future. Nonetheless, its potential for removing land-use planning
decisions from the ad hoc process characteristic of zoning administra-
tion merits serious attention. Perhaps in the next decade, TDR may find
its way into the land-use planning tools available for controlling urban
growth and improving long-term air quality.
g. Tax Policy. The potential impact of tax policy on shap-
ing future growth can be significant. Two concepts are particularly
noteworthy: 1) Vermont's capital gains tax, and 2) the deferral of
real estate taxes while land is used for low intensity purposes.
Vermont, in addition to the provisions of Act 250, has enacted a tax
reform program which includes a relatively high capital gains tax on
land development. The tax rate is inversely related to the duration of
the land holding. Thus, the buying of tracts for short-term subdivision
and resale is particularly discouraged. While it is impossible to
quantify the impact of this legislation, it clearly exerts some braking
effect on rapid development, which in turn has an indirect effect on air
quality maintenance.
Another commonly used tax policy is the taxation of agricultural or
undeveloped land based on its use, rather than on market value. Thus,
the farmer who chooses to continue farming a tract that is well placed
and zoned for development would be taxed not on the value of the land as
a development site but rather on its agricultural use. An additional
development disincentive can be provided by deferring the difference
between the tax on use and the tax on market value until the time of
development. Thus, a developer would be further discouraged by the
cumulative tax deferrals that he would have to incur in order to de-
velop. These tax reduction and deferral policies provide some incentive
for the landowner to continue using his land for low intensity purposes.
Further, the deferral scheme actively discourages development.
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Because they can provide an incentive for low intensity land-use,
tax policies can have a significant impact on air quality maintenance
planning.
h. Capital Improvements Programming. As mentioned in previ-
ous sections, certain jurisdictions are including the availability of
capital facilities as an important criterion in evaluating development
proposals. Development timing controls, adequate public facility ordi-
nances, and other local policies make capital improvement availability a
condition of development.
While these measures make capital improvements a direct factor in
development decisions, capital improvement programs can drastically
shape development even in the absence of the more powerful ordinances.
As summarized by Croke, et al. (ref. 32):
Public land development or public works has great effect on
shaping and directing urban growth through construction of
transportation systems, public institutions (e.g. state
colleges and hospitals), and utilities. In the past, public
works have usually been constructed in response to development
or market pressures; recent years have brought an increasing
awareness of the impact of public investment decision on estab-
lishing an infrastructure for private decisions. The role of
a new highway or sewer system in influencing development direc-
tion has clearly been recognized, although not fully utilized.
i. Critical Environmental Areas. Many communities have
adopted Critical Environmental Area (CEA) Plans, designed to preserve
environmentally sensitive tracts from incompatible development. The
State of Virginia provides an example of criteria for use in identifying
CEA's (ref. 33):
An area that has unusual natural or manmade features worthy
of protection by State or local governments. The features may include
historic sites, special wildlife habitats, areas possessing unique
geological or physical characteristics, and areas well suited for future
park development.
A natural area that is critical to an ecological system.
Areas might include flood plains, tracts with severe topography, or low
wetlands.
Certain natural, scenic, or historic areas that are presently
endangered because of the activities of man.
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An area appropriate for public use through future acquisition
by State or local agencies.
An area that can be considered to contain a primary State
resource, including wildlife, minerals, and agricultrual production.
While preservation of air quality has not been considered as a
justification for designating critical environmental areas, there would
appear to be sound reasons for doing so. The second and third criteria
listed above would be particularly appropriate for air quality consider-
ations. It is unlikely that designating critical environmental areas
could affect regional air quality unless such designations were of
substantial area. However, as a tool in controlling "hot spots", this
process may be appropriate.
In Virginia, development is not prohibited in CEA's but higher
standards are applied to ensure compliance with the intentions of the
CEA system.
j. The A-95 Review Process. A previous section presented
the need for a regional approach to plan development. Pollution does
not respect geographic boundaries. The impact of locally generated
pollutants is not confined to the area in which they are produced. One
community has little control over the development policies of adjacent
communities. Because of the potentially conflicting air quality goals
of neighboring communities, a need exists to mediate interjurisdictional
conflicts.
In the absence of a regional authority, local communities acting in
their own self-interest can easily subvert the goals and objectives of
regional growth policies and regional AQMP's. It has become apparent
that in many metropolitan areas, neighboring jurisdictions are vying
with each other to determine which one can make itself least attractive
to new residents, while actively seeking light industry for its tax
benefits. The result has been inequity between jurisdictions. Thus,
one municipality may attract a great deal of light industry and at the
same time effectively discourage residential development to serve the
employees of the industry. The result is that neighboring jurisdictions
must carry the financial burden of providing residential services, while
being unable to reap the high taxables of Industry. A notable attempt
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to correct this disparity has been undertaken by the Metropolitan Council
of the Twin Cities. In 1971 the Minnesota legislature passed a law
requiring each local government in the Twin Cities region to contribute
40 percent of the net growth of commercial and industrial property tax
valuations to the Council for redistribution to various local govern-
mental units according to population and need (ref. 32).
The logical agency to review local planning decisions for compli-
ance with regional plans is the regional A-95 review agency. The Office
of Management and Budget (OMB) Circular No. A-95 provides the structure
for implementing sections of three acts: Title IV of the Inter-govern-
mental Cooperation Act of 1968, section 204 of the Demonstration Cities
and Metropolitan Development Policy Act of 1966, and section 102(2)(C)
of the National Environmental Policy Act (ref. 34). The common goal of
these sections is to ensure the coordination of Federal programs and
projects with State, regional, and local programs. State clearinghouses
have been established in every State, as well as in most metropolitan
areas, to administer the provisions of the A-95 Circular. Perhaps the
most significant accomplishment of the A-95 process has been the estab-
lishment of a structure for interjurisdictional cooperation and compre-
hensive planning. Unfortunately, all too often the member governments
tend to view the clearinghouse role not as influencing regional policy, but
rather as a communication forum and an insurance device for the con-
tinued flow of Federal funds to local governments (ref. 35).
Although the A-95 process has established a structure for consid-
ering air quality maintenance at the regional level, because only
federally funded projects are subject to review, many large-scale pro-
jects with significant air quality implications escape review.
The need for regional review of local planning decisions for con-
formity with regional plans is great. The political problems involved
in so doing are also great.
4- The Effectiveness of Land-use Management Techniques in
Maintaining Air Quality
The effectiveness of land-use management techniques in achiev-
ing community land-use objectives has been unimpressive. Since air
quality considerations are at best secondary considerations fn land-use
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management, with few exceptions, the effectiveness of these techniques
in maintaining air quality has been marginal. The anticipated useful-
ness of individual techniques for air quality maintenance is summarized
in Table II-l.
In spite of this rather dismal record, the prognosis offers hope.
The new environmental ethic which has emerged in recent years has
encouraged the strengthening of land-use management techniques. Capital
facility ordinances, development timing controls, and building moratoria
have all been developed in recognition of the failure of traditional
zoning controls. The use of capital improvements programming to direct
future growth is now being recognized. The A-95 review process offers a
potential framework for regional consideration of air quality. The
Vermont Land-use Plan, discussed in a previous section, provides a model
for the statewide or AQMA-scale consideration of air quality impacts of
development.
While land-use management as an air quality maintenance measure has
been relatively ineffective in the past, its potential is considerable.
Under the aegis of a regional or statewide land-use plan with enforce-
ability, the various community ordinances can have an impact on long-
term air quality. However, without a regional review function, it is
doubtful whether these ordinances could be effectively implemented.
E. TRANSPORTATION CONTROLS
1. Description of Transportation Controls
"Transportation controls" is the generic term applied to a diverse
group of measures that, either directly or indirectly, can potentially
reduce emissions from motor vehicles by one of two broad approaches:
Reduce the pollutant emission rate per vehicle-mile of travel
(VMT), or
Reduce the total number of VMT.
Although certain stationary source control measures, such as service
station vapor control, are considered transportation controls within the
context of the strategies submitted in implementation plans, only those
measures associated with reducing motor vehicle emissions are described
here.
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Table 11-1. Summary of selected land-use management measures that may
affect maintenance of air quality standards
en
oo
Measure
Zoning
Subdivision
regulations
Capital
facilities
ordinances
Development
timing con-
trols
Moratoria
Transfer
development
or pollution
rights
Tax
policy
Capital
improvements
programming
Critical
environmental
areas
A-95
review
process
Purpose of
Measure
To control develop-
ment of a city or
county
To ensure subdivi-
sion is compatible
areas and provide
for necessary
facilities
Requires develop-
ers to include
parks, schools.
etc. , in develop-
ment costs
Set quotas for
new developments
Temporary pro-
hibition of new
development
Each parcel of
land is allocated
a pollution right
which can be used
or sold by the
owner
of development
at a desired
level
To control loca-
tion of new
developments
To protect areas
from significant
deterioration of
air quality
To ensure cooper-
ation between
adjoining
political juris-
dictions
Examples of
current applications
Nationwide
Nationwide
Loudon County , Va .
Montgomery County ,
Md .
Petaluma, Calif.
Ramapo , N . Y .
Fairfax County, Va.
Prince William
County, Va.
None
Nationwide
Virginia
Minneapolis-
St. Paul , Minn.
Method of
implementation
Local ordinances
Local ordinances
Local ordinances
Local ordinances
Local ordinances
Local ordinances
State law
Provision of public
funds by local or
state government
Local ordinances
State laws
Designate regional
coordinating
agency
Effectiveness in maintain-
ing air qua 1 i ty
Controls density of development
but may not have significant
effect on air quality
Minimal effect on air quality,
rational street system may
Higher costs may reduce buyer
demand and inhibit growth of
new sources of emissions
Direct effect on air quality
by reduction of growth of new
sources
Because of the temporary nature,
may have no long-term effect on
air quality
The emission allocation can be
set to the level required to
maintain air quality standard
Direct effect on air quality
by restricting growth of new
sources
May not control growth in total
emissions but can control where
new sources are located
Measure can be used to maintain
air quality in selected por-
tions of AQMA
Can be used to protect against
hot spots created by poor dis-
tribution of sources
Sources and
pollutants affected
Stationary sources
TSP, S02, HC, NOX
None significantly
Automotive and
stationary sources
all pollutants
Automotive and
stationary sources
all pollutants
None significantly
Stationary sources
TSP, SO,, HC, NO
Stationary sources-
TSP, S02, HC, NO
Automotive and
stationary sources
all pollutants
Automotive and
stationary sources
all pollutants
Automotive and
stationary sources
all pollutants
-------
Many of the transportation controls that have been proposed or
implemented are listed in table II-2. This tabulation is not meant to
be all inclusive. Because of the wide range of available measures, a
plan for control of automotive emissions may be tailored or designed
specifically for problem areas within an AQMA, whether they are ex-
tensive or extremely localized. However, measures designed to reduce
oxidant concentrations must be areawide. Proper selection from these numerous
measures can minimize the social and economic impacts that are inev-
itably linked to all transportation controls.
It should be noted that gasoline rationing is currently considered
to be infeasible and that it can be assumed that existing transportation
control plans based primarily on gasoline rationing will not result in
attainment of NAAQS.
Transportation control plans were initially developed to attain
standards over the relatively short-term range of 2 to 5 years, and
employed measures aimed at reducing both emission rate and VMT. However,
for maintenance of standards over the longer range, measures that reduce
the emission rates from in-use vehicles will become less effective unless
new control or vehicle-power-technology breakthroughs occur, because
measures such as retrofit and gaseous fuel conversion will be inappli-
cable to post-1975 model year vehicles. As a result, transportation
control strategies needed for maintenance will have to rely heavily on
measures that reduce VMT. An inspection/maintenance (I/M) program is an
important control measure because not only is it capable of achieving
large emission reductions (8-12 percent CO and HC), but also it helps
ensure that the emission reductions claimed for the Federal Motor Vehicle
Control Program are in fact achieved. An I/M program will assist the
State or local government in implementing an effective antitampering
program and can help ensure that owners of vehicles subject to recall
under Section 207(c) of the Clean Air Act have the required work done
prior to the periodic inspection. The Clean Air Act specifically
anticipates that I/M programs will be included in the implementation
plans of those regions that have automobile-related air quality problems.
Many of the measures designed to reduce VMT have already been
employed by traffic agencies for the purpose of eliminating undesirable
congestion in high traffic density areas. It is important that trans-
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Table 11-2. Transportation control measures
Measures to reduce emission rates
Measures to reduce VMT
Federal Motor Vehicle Control Program
(FMVCP)
Retrofit devices
Vacuum spark advance disconnect with
low idle
Air bleed to intake system
Oxidation catalysts
Inspecti on/mai ntenance
Gaseous fuel conversion
Traffic flow improvements
Better highway and interchange design
Signal progression
One-way streets
Reversible lanes
Driver advisories
Loading regulations
Staggered work hours
Traffic restrictions
Street closings
Traffic-free zones
Partial traffic restriction
Limited access zones
Idling restrictions
Gasoline rationing
Traffic restraints
Parking bans
Parking supply management
Parking surcharges
Road use or entry charges
Priority treatment for
carpools
Increased gasoline taxes
Increased vehicle registration
fees
Bikeways
Traffic avoidance
Restricted road building
Urban area bypasses
Control of urban development;
e.g., strategic planning
and planned unit development
Four-day work week
Mass transit improvement
Rapid rail
Community rail
Improved bus service
Reduced mass transit fares
Express bus lanes
Employee mass transit incentives
11-60
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portation control measures have obvious accompanying benefits such as
reduced congestion, time and money savings to' commuters, better public
transportation services, or energy savings, because experience has shown
that significant restrictions of personal mobility are not likely to be
accepted solely to improve air quality. The public reacts negatively to
imposed limitations on travel because many have immediate and substantial
impact on life style, whereas air quality maintenance usually has only
long-term, intangible benefits.
It should be emphasized that not all VMT reduction measures result
in limits on personal mobility or loss of individual freedom of choice.
There are three general means of limiting traffic: restriction, re-
straint, and avoidance. Traffic restrictions include all methods of
preventing traffic by physical obstruction or act of law, thus repre-
senting direct impairment of mobility. Traffic restraints are methods
designed to influence travel choices, such as parking charges or free
bus service. They, too, limit mobility, but without affecting individual
freedom of choice. Traffic avoidance aims neither to prevent nor to
dissuade people from fulfilling travel desires, but rather to avoid the
birth of the desires in the first place. Traffic avoidance appears to
be the most desirable long-range approach to VMT reduction. Because
traffic avoidance measures deal with trip purposes and the relative
locations of homes to trip destination points, they overlap considerably
with land-use planning activities.
The most promising transportation control for producing lasting
reductions in automobile use is probably improved mass transit. In the
major urban areas where long-range transportation controls will be
needed to maintain standards, only about 14 percent of work trips are
now handled by mass transit (ref. 36). Cities that provide high quality
mass transit have demonstrated that this mode of travel can attract much
higher levels of ridership, particularly if auto use is comparatively
difficult or expensive.
2. Historical Review of Transportation Controls
a. Current Applications. As mentioned previously, numerous
kinds of transportation controls have been employed for the purpose of
relieving congestion or improving traffic flow. In some instances, air
quality data taken before and after the implementation of these controls
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have documented air quality improvement that accrued as a secondary
benefit. Selected examples of these existing transportation controls
are listed in table II-3.
Transportation control plans designed to produce specific air
pollutant emission reductions have been adopted for 30 AQCR's,
by the responsible State air pollution control agencies and/or EPA.
Although the control measures were proposed to achieve the
air quality standards by mid-1975 or within 2 years thereafter in cases
where an extension was granted by the Administrator, very few of the
proposed measures had been implemented by mid-1974. Part of the delib-
eration in carrying out these transportation control plans can be
attributed to the need to evaluate medium- and long-term impacts of
existing gasoline shortages, higher prices, and energy conservation
programs on travel patterns before initiating further travel restric-
tions and restraints. Another reason for the delays in implementing
transportation controls has unquestionably been the extensive opposition
to these plans by affected interest groups and citizens (ref. 37).
Transportation control measures most often proposed in the pro-
mulgated plans are summarized in table II-4. The numbers presented in
this table are intended only to show the relative prevalence of the
measures and may not reflect recent revisions in various transportation
control plans.
There are few examples of measures already in progress. Three are
described below: the inspection/maintenance program for the State of New
Jersey, free bus service in downtown Seattle, and the exclusive bus/carpool
lane on 1-95 in the Washington, D.C., area.
The State of New Jersey in July 1972 initiated an idle mode test for
CO and HC emissions, using nondispersive infrared analyzers as part
of the required annual automobile safety inspection (ref. 38). However,
compliance was voluntary until February 1974 in order to provide a
period of familiarization and training. The test is conducted statewide
at all 34 of the State-operated inspection stations with a total of 68
inspection lanes. The cost of performing the emissions and safety test
(not including program administration), approximately $2.00 per vehicle,
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Table II-3. Examples of existing transportation controls
to reduce traffic congestion
Transportation control
Cities presently employing this control
Traffic-free zones
(refs. 39, 40)
Partial traffic restric-
tion by erecting physical
barriers to subdivide the
center city (ref. 41)
Partial traffic restric-
tion by erecting physical
barriers to subdivide the
center city (ref. 41)
Idling restrictions (ref. 42)
Parking ban in central
city (ref. 39)
Parking supply management
(ref. 39)
Improved mass transit
service (refs. 42, 43)
Reduced mass transit fares
(ref. 43)
Exclusive bus/carpool
lanes (ref. 40)
Entry tolls and permits
for center city (ref. 39)
Urban area bypasses
Staggered work hours
(refs. 39, 42)
Over 100 worldwide cities, including
Tokyo, Vienna, Essen, Leeds, The Hague,
Oldenburg, Munich, Athens, Bologna,
Brussels, Florence, Ravenna, Rouen,
Rome, and Verona
Approximately 24 U.S. cities, including
New York City (temporary), Atchison,
Fresno, Kalamazoo, Miami Beach,
Minneapolis, and Providence
Bremen, Goteborg, Bologna, Liverpool
Stockholm
Marseilles
Bologna, Newcastle, Hamburg, The Hague,
London, and Glasgow
Seattle, Atlanta
Atlanta, St. Louis
Metropolitan New York (Long Island
Expressway, 1-495 in New Jersey),
Boston (Southeast Freeway), Washington,
D.C. (1-95), San Francisco (Bay Bridge
toll booths)
London
Most major U.S. cities
New York, Munich, Cologne, Bonn
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Table 11-4. Transportation control measures proposed
in promulgated plans
Transportation control
Inspection/maintenance
Traffic flow improvements
Catalytic retrofit
Other retrofit
Parking restrictions
Pricing policies
Mass transit improvements
Additional stationary source
controls
VMT reduction
Motor vehicle exclusion areas
Gaseous fuel conversion
Carpool locator
Gasoline limitations
Motorcycle restrictions
Idling limitations
Selective vehicle exclusion
Employer mass transit incentives
No. of
State plans
15
7
6
9
6
5
10
11
4
2
2
4
0
0
0
1
0
No. of
EPA plans
25
18
15
13
24
3
8
24
4
2
0
6
11
7
1
9
10
Total no.
of plans*
31
24
16
21
28
8
13
30
8
4
2
9
n
7
1
10
10
*In some AQCR's, the State and EPA have proposed separate or differing
controls of the same type. These numbers are intended only to show
the relative prevalence of the measures and may not reflect recent
revisions in various transportation control plans.
Source: State Air Pollution Implementation Plan Progress Report,
January 1 to June 30, 1973. U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. Publication
EPA-450/2-73-005. September 1973.
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is covered in the annual vehicle registration fee. Allowable emission
rates were originally set to provide for a 10 percent failure rate of
tested vehicles, which were then required to obtain maintenance and be
retested. Later air quality data indicated that more stringent trans-
portation controls would be required to achieve the air quality stan-
dards in two portions of the State, so the vehicle emission standards
are scheduled to be reduced to levels that should result in a 20 percent
rejection rate after July 1, 1974, and finally to a 30 percent failure
rate.
During the first evaluation of the inspection program, a sampling
of vehicles that failed the idle mode emissions test had average repair
costs of $22.50 (ref. 44). In an economic analysis, part of this cost
should be attributed to routine maintenance that would have been per-
formed in the absence of the maintenance requirement.
The Metro Transit of Seattle began offering free bus service in a
105-block downtown section of the city in September 1973. Because the
free rides are all on portions of existing bus routes that pass through
this designated area, no additional equipment or operation costs are
required to provide the service. In fact, this new program replaces a
downtown 10-cents-per-ride shuttle bus system that was operated at a
deficit by Metro; consequently, with a $64,000 1-year subsidy from the
City of Seattle, the service is not a financial burden to Metro.
The incentives to start such a program were primarily to ease
traffic congestion and to reduce pollutant emissions in the critical
center city area. The 5,400 daily bus trips through the area now carry
an estimated 11,000 downtown riders, almost twice the former 6,000
shuttle bus riders. With ridership still increasing, the free service
has the potential to decrease downtown auto traffic by almost 20 percent
during the daytime.hours, based on an origin/destination survey of the
area (ref. 45). Favorable publicity from this program is also credited
with recent increases in patronage on the entire Metro Transit system.
The exclusive bus/carpool land on 1-95 (Shirley Highway) in the
Northern Virginia suburbs of the Washington, D.C., area was designed and
constructed under an Urban Mass Transit Administration (UMTA) demon-
stration grant in 1970, and was originally to be discontinued after 2
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years as that segment of 1-95 was widened and modified. After the
opening of the exclusive bus lane, counts on this corridor showed a
modal shift during peak traffic periods from 27 percent transit riders
in June 1970 to over 40 percent in June 1972. After the UMTA grant
expired, efforts to convert the bus lane into a reversible lane open to
all traffic were strongly opposed by bus commuters and other citizen
groups. The reversible center lane was retained for exclusive bus use,
partially due to the need of the transportation control plan for the
AQCR to demonstrate substantial reductions in VMT.
As a result of gasoline shortages during the simmer months of 1973,
the bus lane was also opened to cars with four or more occupants to
encourage carpooling. A $250 fine for illegal use of the lane was
imposed ($1,000 for a second violation) and the requirement for minimum
number of riders was strictly enforced. The most recent counts available
for January 1974, show that the single bus/carpool lane carried 11,117
persons during the morning peak period while the other four inbound
lanes carried a total of 11,841 persons. The breakdown by mode was 43
percent bus, 6 percent carpool, and 51 percent private car; average auto
occupancies for the two road sections were 4.94 and 1.15, respectively.
Travel times averaged 23 minutes less for the linehaul portion of the
trip on the bus/carpool lane in the morning, and 20 minutes less in the
evening. These advantages make door-to-door travel time and convenience
of a bus or carpool comparable to that of a private car for commuters in
this corridor.
b. Effectiveness of the Measure in Current Applications.
Existing transportation controls have widely varying impacts on emis-
sions and air quality, due in part to the broad range of different
controls that fall into this category. Differences in effectiveness of
individual transportation controls are even more pronounced if impact is
measured on a regional scale, because some of the actions, such as
inspection/maintenance or retrofit, result in emission reductions
throughout a metropolitan area, while many others have a significant
impact only in a single area or corridor of the region. The measures
with a localized effect must produce air quality improvements specifically in
areas where air quality maintenance is a problem if their full effective-
ness is to be achieved.
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The New Jersey inspection/maintenance program recorded impressive
average reductions on vehicles after their initial servicing: about 60
percent for CO and 57 percent for HC (ref. 44). However, these values
apply only to the portion of vehicles serviced (10 percent failure
rate), and to the initial inspection/maintenance cycle; it does not
consider degradation in emission rates that occur after the servicing,
which diminishes its effect. The potential reduction in years following
the initial servicing is lower because the cars are not as much out of
adjustment. Potential reduction also decreases in succeeding years due
to the replacement of older cars having higher emission rates with new,
controlled vehicles. Therefore, the total emission reductions in
regional CO and HC emissions claimed by New Jersey and EPA for the
statewide inspection/maintenance program in the years 1972 to 1977 are
not applicable to future periods for which maintenance controls may be
needed. The percentaae reductions in regional motor vehicle emissions,
as shown in table II-5 may remain fairly constant in future years.
Accurate estimates of effectiveness of inspection/maintenance programs
should be based on calculations that include the following factors (ref.44):
Total vehicles in the AQMA in the year of interest
Distribution of vehicle population by age
Average annual mileage for each age class
Emission factor by age class in the year of interest
Emissions without an inspection/maintenance program
Fractional reductions in emissions after servicing, by
age class
Deterioration rate between inspections, by age class
Anticipated failure rate.
The other two existing transportation controls described above both
have traffic impacts in only a portion of their metropolitan areas. They also
have the common characteristic of reducing emissions by a combination of
reductions in VMT and increases in average speed, plus the non-air-
pollution-related benefit of reduced traffic congestion.
The free bus service tn Seattle has not been in operation long
enough to accurately assess its impact on VMT or air pollution levels.
According to the origin/destination survey data for downtown Seattle,
this action may divert a substantial percentage, up to 20 percent, of
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Table I1-5. Estimated emissions reductions from the
inspection/maintenance program in New Jersey
Estimated by
New Jersey Bureau
of Air Pollution Control
U.S. EPA
Projection
year
1974
1975
1977
1975
1977
Assumed
inspection
failure, %
10
20
30
45
45
Regional reductions Regional reductions
in motor vehicle in total emissions
emissions
CO
3
6
8
10
10
HC
6
8
10
11
11
CO
NA
3
4
NA
4 to 6
HC
NA
2
2
5
4
NA = Data were not available.
-------
daytime auto trips in the center city area where the highest traffic
densities and CO concentrations occur, thus reducing maximum 8-hour CO
measurements.
The exclusive bus/carpool lane on 1-95 in Washington, D.C., is
reducing the number of vehicle trips into the city and back by about
3,500 per day, or about 33 percent of total traffic volume on that portion
of 1-95 and 10 percent of total traffic volume in that
corridor during the peak traffic periods (ref. 46). The impact of these
trip diversions on local air quality should be proportional to the
traffic reductions, or possibly even greater because of increased
average speeds with less traffic. This program definitely proves the
potential for mass transit and carpooling to attract a far greater share
of suburban commuters.
3. Implementation of Transportation Controls
a. Procedure. It may be assumed that control agencies and
motorists in AQMA's that might implement transportation controls as a
maintenance strategy would already be somewhat familiar with them.
Transportation controls for air quality maintenance probably will
be used only in some of the 38 metropolitan areas that already have
transportation control plans to achieve air quality standards. This is
because areawide reductions in emissions projected through 1985 as a
result of the Federal Motor Vehicle Control Program (FMVCP) should
exceed the growth in emissions due to increased VMT even in the fastest
growing metropolitan areas. Hence, if an AQMA has not exceeded air
quality standards for motor-vehicle-related pollutants in 1975 or prior
years, it is unlikely that it will do so between 1975 and 1985. Also,
any new localized violations of the CO standards should be prevented at
least in part by the indirect source review procedure.
Once the need for transportation controls to maintain air quality has
been established, the extent of the area projected to exceed the standards
without a maintenance plan should be determined. If only a localized area
is affected, controls different from those needed for areawide emission
reductions should be considered. For instance, traffic flow improvements
or vehicle rerouting can be very effective in abating localized problems.
Specific measures should then be reviewed in consultation with
regional and local transportation planners, and possibly the public, to
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select those most appropriate for more thorough investigation or pre-
liminary design and costing studies. In most respects, the selection of
appropriate transportation controls is synonymous with selection of
maintenance measures for the comprehensive maintenance strategy, since
the transportation control "measure" is actually a diverse group of
controls for the motor vehicle emission category that could be con-
sidered individually as maintenance measures.
Retrofit, inspection/maintenance, and gaseous fuel conversion
maintenance measures probably would be designed by air pollution control
agencies. For measures other than these three, the design of the actual
traffic control system should be given over to transportation planners,
with the agency responsible for the AQMP providing only such input
constraints as the percent reduction in emissions or VMT needed, the
area over which the controls should act, and the time frame for
initiating the controls. This transfer of the design functions should
minimize several major problems encountered in developing the original
transportation control plans (ref. 47):
Transportation controls in conflict with regional transportation
planning and local development goals,
Inadequate evaluation of mobility limitations resulting from
the controls,
Statements of broad control objectives without adequate con-
sideration of implementation problems or times.
After the design phase, it may be appropriate to also delegate
implementation of the provisions directly to another agency, such as a
State department of transportation or highways. Since the responsibility
for a State-submitted AQMP rests ultimately with the Governor, assign-
ment of plan implementation to a State or local agency other than the
one that directed its development is certainly feasible.
The generally long lead time available before the need for trans-
portation maintenance measures provides the opportunity for incorporat-
ing revisions or modifications into the transportation and land-use planning
process. It also allows for greater use of more acceptable and less disruptiv
measures, such as expanded mass transit service and planned unit
development.
Detailed implementation steps for specific transportation controls
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are too voluminous to be included here. The Strategies and Air Stan-
dards Division has prepared and published documents describing retrofit,
inspection/maintenance, and parking controls. Additional documents will
be developed and published as required. Previously published transportation
control plan resource documents should be used until such time as new ones
become available.
b. Conditions of Applicability. Transportation controls
include a whole spectrum of methods to reduce motor vehicle emissions.
As such, this maintenance measure is considerably more flexible in
application than other measures and can be utilized in some form for any
case in which air quality standards are exceeded primarily due to motor
vehicle emissions.
The conditions most favorable to application of specific trans-
portation controls are described in several publications (ref. 39, 41,
42) and in the EPA documents mentioned above. However, transportation
controls should not be prescribed primarily because of their applicability
from an air pollution control standpoint, but rather based on their accept-
ability as modifications to the urban transportation system. Therefore,
the criteria for applicability are that the proposed measure does indeed
reduce motor vehicle emissions in the area of concern and that it can be
integrated into the urban transportation system with minimal adverse effects,
c. Interaction With Other Measures. Transportation controls
interact with other measures having an impact on motor vehicle emis-
sions. In particular, transportation controls are affected by the
indirect source review process and by energy conservation measures for
gasoline. Indirect source review generally precludes the need to other-
wise consider carbon monoxide concentrations at the very localized,
individual-facility level in transportation control plans. Instead,
these plans can address air quality maintenance for the entire areas or
corridors for which standards are projected to be exceeded. The review
procedure and the control plan do not have any potential conflicts or
overlapping, since indirect source review is concerned with the traffic-
inducing facilities and the transportation controls concentrate almost
exclusively on regulation of the traffic.
Most programs to reduce motor vehicle emissions through gasoline
conservation would also reduce VMT. However, the reductions from fuel
conservation measures could not be confined to primary areas of impact
as they could with transportation controls. In effect, a regulatory
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gasoline conservation program could be thought of as one transportation
control that could be applied with others to obtain the required reduction
in motor vehicle emissions.
Regional development plans or control measures that encourage
dispersed development tend to increase VMT and motor vehicle emissions
and are therefore counterproductive to transportation controls. Urban
sprawl also increases dependence on the automobile and decreases the
potential for expanded use of mass transit, one of the most desirable
methods of reducing VMT.
d- Potential Conflicts Uith Community Development Plans.
Since transportation is one of the most important factors in urban
development, controls on transportation have tremendous potential impact
on all aspects of community development, with those that seriously
reduce mobility being in conflict with many community plans and ob-
jectives. In evaluating possible transportation controls, these impacts
on a city's economy, population growth, employment, and location of new
development should be considered carefully. If proposed construction of
a single urban highway link warrants a comprehensive impact assessment
under the NEPA requirements for EIS's, a transportation control plan for
an entire urban area deserves, comparatively, a multiyear major study of
its potential impact on community development.
Transportation controls are probably most compatible with community
development if they are implemented gradually over an extended period of
time, and if they are incorporated into the decisionmaking process for
transportation system improvements. Urban transportation systems are
always imperfect; they are continously being evaluated and upgraded to
meet changing mobility needs.
The increasing use of motor vehicles for transportation is creating
many problems other than air pollution: disproportionate consumption of
petroleum fuel supplies, noise, traffic congestion, accelerated en-
croachment of development around cities into former rural and agricultural
areas, and injuries and deaths from automobile accidents. These other
problems deserve equal attention in determining changes in the trans-
portation system, and certainly controls imposed to reduce air pollution
emissions should not intensify any of these problems. For example, a
regulation requiring nighttime deliveries by trucks may reduce peak
traffic period emissions significantly, but if the measure is projected
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to cause unacceptable increases in nighttime noise levels in residential
areas near major delivery points, it should not be implemented. Most
transportation controls also produce Improvements in these other auto-
mobile-related problems.
Because transportation controls deal with mobile sources, they can
result in the high air pollution levels being displaced rather than
eliminated. The closing of some streets in the center of Rome caused
worse traffic jams near the bloakades than had previously been experienced
in the cordoned area (ref. 39). The evaluation of potential controls
for specific areas should include a check on resulting traffic changes
in other parts of the AQMA.
e. Practical Limitations.
1) Social acceptability. This discussion of transportation
controls has emphasized throughout that the public will not accept
reduced mobility, which would significantly alter their daily life
styles, in exchange for the intangible benefits of maintaining air
quality standards. The best means of gaining public support is to
provide a positive alternative to the present condition, such as im-
proved mass transit service or a comprehensive traffic flow improvement
plan for the downtown area that includes restrictions on vehicle entry
during certain periods. These improvements in the urban transportation
network that simultaneously act to reduce motor vehicle emissions should
be developed under the auspices of transportation planners with the
cooperation of air quality specialists.
Another means of obtaining public support for traffic restrictions
or restraints is to emphasize the accompanying benefits of the controls,
such as reduced congestion, time or money savings to commuters, better
public transportation services, or energy savings.
2) Economic feasibility. All of the transportation
controls listed in table II-2 have been shown to be economically feasible
in advantageous applications. Obviously, retrofit of all motor vehicles
in an AQMA would not be feasible, but retrofit of just pre-1968 vehicles
might be. Cost-effectiveness of the different controls also varies
widely, depending on specific applications and characteristics of the
urban area.
Some new rapid transit alternatives are economically prohibitive as
transportation system improvements, so they obviously are not feasible air
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quality maintenance measures. For example, underground rail systems such as
San Francisco's BART or Washington, D.C.'s Metro probably could not be
initiated in other cities at current construction costs and escalation
rates. The Urban Mass Transit Administration is now seeking innovative
mass transit designs rather than encouraging new underground rail systems.
Any strategy that proposes to use fiscal restraints and disincentives
to reduce auto travel also risks being opposed or rescinded because of
its discriminatory effects on the mobility of low-income groups. Many
of the proposals for fiscal restraints, e.g., gasoline taxes or higher
auto registration fees, have been accompanied by plans to reduce or
rebate these costs for low-income individuals to minimize the regressive
characteristics of such measures. However, the scaled charges or rebate
plans make implementation of these controls much more complex and
possibly impracticable.
4. Evaluation of Control Measure Effectiveness
a. Ability of Measure to Maintain Standards. This
measure consists of a diverse group of controls, many of which can be
applied concurrently. Thus, a proper mix of these controls should be
capable of maintaining air quality standards for most conceivable growth
patterns in an AQMA. The only circumstance under which transportation
controls may not have the capability of maintaining standards without
the simultaneous application of other measures is the instance of a
large percentage of the CO, HC, or NO emissions coming from nonautomotive
X
sources. In this situation, even restrictive transportation controls
may not offset increases in stationary source or other nonautomotive
emissions.
Transportation controls promulgated in, implementation plans are
projected to reduce CO and HC emissions in particular areas of several
AQCR's by as much as 50 percent, although these reductions are yet to be
demonstrated. The estimated impacts of several of the individual con-
trols are summarized in table II-6. In a few instances, these estimates
may overstate the potential reductions attainable with these controls in
the 1975 to 1985 period, due to the much lower emission rates of post-
1975 motor vehicles and to reductions that may already have been obtained
through transportation controls.
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Table II-6. Estimated motor vehicle emission reductions
from individual transportation controls.
Time to
implement
Transportation
control
Estimated reductions in
motor vehicle emissions,
percent
Short term
2-5 years
Inspection/
maintenance
Retrofit
4 to 15 (ref. 48)
10 to 60 for those vehicles
retrofitted (ref. 48)
Gaseous fuel systems Less than 15
Traffic flow Less than 20 in area affected
techniques
Medium term,
5-10 years
Bypassing through
traffic
Improvements in
public transportation
Motor vehicle
restraints
Less than 5
Less than 5
5 to 25 in area affected
Long term
10-20 years
Work schedule change Less than 3
Control of urban Not estimated
development
Source: Institute of Public Administration, Teknekron, Inc., and
TRW, Inc. Evaluating Transportation Controls to Reduce
Motor Vehicle Emissions in Major Metropolitan Areas.
Environmental Protection Agency, Research Triangle Park,
North Carolina. Publication No. APTD-1364. November, 1972,
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Estimates of emission reductions from transportation controls can
be calculated more accurately with data specific to the AQMA, using
procedures described in appendixes A through G of EPA's publication
APTD-1364, Evaluating Transportation Controls to Reduce Motor Vehicle
Emissions in Major Metropolitan Areas. Controls for which estimating
procedures are described are:
Retrofit
Gaseous fuel conversion
* Traffic flow techniques
Public transportation improvements
Motor vehicle restraints
In the 1975 to 1985 period, average motor vehicle emissions will be
reduced by 55 to 65 percent by the FMVCP without maintenance plans.
Therefore, the need for transportation controls to maintain standards
that have already been achieved should be limited to isolated problem
areas (rather than AQMA-wide). Cities that required large emission
reductions by transportation control plans to initially achieve the
standards may need to retain many of their regionwide transportation controls
throughout the 10-year maintenance period.
b. Relative Efficiency When Compared With Other Measures.,
Transportation controls encompass all the measures used to control motor
vehicle emissions, so there are no alternatives to this measure if the
problem is strictly motor vehicle related. However, if the standards
are projected to be exceeded in an area as a result of both motor
vehicle and stationary source emissions, then a comparison of measures
is pertinent. For implementation plans, transportation controls generally
were to be considered only after all feasible stationary source controls
had been employed. This priority does not persist in developing main-
tenance plans, and the decision should instead be based on a comparison
of cost-effectiveness and social impacts of the alternatives, as de-
scribed in volume 2. Transportation controls have the advantage of
being considerably more flexible than stationary source controls with
respect to the geographical areas over which they are to be applicable.
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F. EMISSION CHARGES
1. Definition
Two types of emission charges have been suggested from time to
time as control measures for air pollution. One is a charge on each
point source, proportional to its emissions, that would be set at a rate
related to the type of emission, the type of damages attributable to
that pollutant, and the concentration of that pollutant in the ambient
air of the AQCR. The other is a tax on the emitters of a pollutant,
either at a flat rate for the entire nation or a rate adjusted for each
AQCR.
Both types of charges are designed to internalize the external
costs of pollution, that is, to place an economic burden on the in-
dividual or firm responsible for the emissions that will make the cost
of pollution a part of the cost of doing business or of consuming goods.
It is argued that the disposal of the residuals of combustion, indus-
trial production processes, and consumption, such as automobile oper-
ation, imposes a cost on the general public but is free to the pollution
source. Therefore, to provide an economic incentive for control, these
costs must be allocated to the pollutant sources, who then will find it
economical to control emissions and who will, in turn, include these
costs in prices to be paid by the beneficiaries of production rather
than by the general public.
Effluent charges on the sources of water pollution can be charged
in proportion to the cost of water treatment downstream from the source.
This procedure obviously does not apply to air pollution emissions. Air
pollution emission charges might be set at rates that are above the cost
of control and thus induce polluters to reduce emissions. Because 100
percent control is not possible for most sources of pollutant emissions,
any such system of charges will tend to ration the remaining emissions
to those sources for which control costs are highest or available con-
trol technology is least effective.
At least in principle, emission charges could be set by an air
pollution control agency for each source of each pollutant, individ-
ually, within an AQMA. If such a system were based on real estimates of
the social costs attributable to emissions, the least cost of control,
or other optimizing criteria, it could conceivably provide a highly
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flexible set of economic incentives for the achievement of an optimal
emission pattern. However, such criteria measurements are not readily
available to policy makers and the more likely prospect is that such a
system would be considered discriminatory, arbitrary, or capricious and
hence unconstitutional. It might also be used as a means of requiring
best available technology that in turn might well not approach optimum
in other senses. Given the administrative and legal problems of such a
system and the lack of effective criteria for application, the remainder
of this section will be addressed to the more likely control measure of
taxation.
2. Historical Review of Measure
Historically, taxation has been one of the means used by
government to control the behavior of individuals and businesses. The
use of taxation as a means of controlling pollution has been widely
discussed in current economic literature. (See, for example, ref. 49.
This article presents a good summary and evaluation of the economic
theory of externalities and the theoretical applicability of taxes
to control pollution.) A tax on sulfur emissions has been proposed
in Congress, but has not received serious attention as yet. One
variation of a tax on sulfur emissions was the subject of a recent
study performed for EPA (ref. 50) As a control measure, taxation is
yet to be tested in practice.
3. Implementation
a. Procedure. A tax could be applied to emissions of any of
the pollutants now subject to standards. The tax could be either a
statewide flat rate tax or graduated at different rates for classes
of sources or geographical areas. Whatever the form, however, the
general effect is assumed to be to induce controls at a level such
that the incremental cost of removing the last unit of pollutant
emission from the gasses released to the atmosphere equals the tax
rate. Thus, controls are applied at that level where the combined cost
of the control system and tax is least. Tax payments continue
to be made on the uncontrolled emissions.
This statement of the way an emissions tax would work is, of
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course, an oversimplification. An electric power company might well
find, for example, that the cost of controlling sulfur oxides emissions
did not vary continuously over the entire range of possible control
rates. Instead, there may only be a small number of possible control
techniques at very different control efficiencies and costs. The
control cost functions may consist of very large steps. As a result,
large shifts in the rate of tax on sulfur emissions might not induce a
change in company behavior until the level is reached that causes the
company to move from one step to another on the cost function. Pro-
ducers would also have to base their control decisions on other factors
as well as the cost function. The time over which investment would be
amortized could be an important consideration. The possibility that new
and more economical technology might soon be available could cause a
firm to pay the tax while deferring investment in control equipment.
Other factors also influence business decisions, but the effect of a tax
may still be approximated by the cost minimization concept given above.
If the reaction of all sources of a pollutant to a tax could be
specified in advance, the tax could be set at a level that would
achieve any desired emission level possible with current technology.
In fact, comprehensive control cost functions cannot be specified
with accuracy at this time and the noncost factors in business decisions
are not amenable to advance estimation. However, if a desired level
of total emissions can be specified, it is theoretically possible
to apply a tax on a trial and error basis, adjusting the rate until the
desired result is achieved.
A procedure that would take out at least a part of the uncertainty
as to the reaction of all sources of a pollutant to a tax is one that
specifies a level of control which must be met and a decreasing tax if
emissions are below the level resulting from the control. The specified
level of control should be selected based on the overall air quality
requirements of the area and an analysis of the control cost function.
If the control cost functions consist of discrete steps, the minimum
control should be at one of the step levels.
In the development of an emission charge procedure, special considera-
tion must be given to those industries having little or no competition.
For example, power plants usually are allowed a specified percent profit
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by the Public Utilities Commission. In such a case management may choose
to ignore pollution control, pay the emission charge, and pass on the
increased cost to the consumer. Providing the requisite legal authority
can be obtained, such a situation may be avoided by a sliding profit
margin based on emissions. Similar considerations apply to other sources
that may have no competition within their trading area.
b. Conditions of Applicability. Emission charges can be
applied to any point source and pollutant within the AQMA. Its greatest
applicability is for pollutants and sources having a wide range of
potential control techniques; e.g., sulfur oxides and particulates.
c. Interaction With Other Measures. A tax could be used in
place of emission standards to achieve a predetermined level of pollution
in the ambient air, e.g., to achieve the NAAQS. It is more probable, however,
that a tax would be used to reinforce the effect of emission regulations
such as those promulgated in the SIP's. Taxes could conceivably be used in
conjunction with other control measures as well. For example, tax rates
could be varied by zones when emission density zoning is employed, or a
high tax rate on emissions of one pollutant might be used to discourage
the location of additional firms emitting that pollutant.
d. Potential Conflicts With Community Development Plans.
Because emission charges would be normally imposed by the political
jurisdiction responsible for the preparation and implementation of
community development plans, any potential conflicts can be resolved
during the development phase. Should conditions warrant the application
of emission tax or charge to only selected portions of the AQMA, close
coordination with the community development plans is essential so that
the impact of the tax on growth and development is consistent with the
desired growth and development patterns.
Emission tax or charge provides a source of revenue that could be
used in the community development process. However, air quality main-
tenance considerations should be the deciding, if not only, factor in
the decision to impose a tax or charge on emissions.
e. Practical Limitations. The apparent advantage of using
taxation as a control measure is that it provides for different behavior
by firms with different processes, control costs, or size of operations.
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By making the degree of control to be achieved by each source econom-
ically determined, the tax approach permits those with high control
costs to apply less control than those for which control is more eco-
nomical and small producers to control at different efficiencies than
large ones. In principle, therefore, taxation provides a control
measure that should provide a much closer approach to an economical
allocation of resources than arbitrary emission standards, while pro-
viding equivalent areawide ambient air quality.
There are, however, a number of other aspects of taxation as a
control measure that should be considered:
1) The method of control is not specified. It may, for
example, be desirable to require a stationary combustion source to
control emissions by the use of stack-cleaning devices rather than by
fuel switching, even if the latter were more economical.
2) If a tax is paid on the uncontrolled emissions, this
increases the cost of achieving that level of control induced by the
tax. Some tax will be paid by each source in each instance.
3) If tax rates are set initially by trial and error
and if they are subject to change from time to time, this introduces a
degree of uncertainty into business decisions that may, at least
partially, defeat the intent of the measure. A firm will not undertake
investment in costly control equipment without reasonable assurance that
it will be acceptable over a reasonable period of time. The wrong
investment could lock it into a control level that would later require
it to pay very high taxes. There would be a tendency to hold back on
control investment to see where the tax will be set during the trial and
error period. But if that occurs, the successive approximation process
cannot reach the appropriate level.
4) A question arises as to the appropriate use of the
revenue generated. This is a problem quite apart from the control
measure itself.
5) Enforcement of a tax measure poses much the same
monitoring problems as does the application of standards, plus the
administration and enforcement problems of the tax itself.
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6) Another question is that of constitutionality. Any
tax measure will have to meet the standards for nondiscrimination and
reasonableness. The question of constitutionality is not presently
pertinent but will arise when any specific proposal is put forth.
7) It appears likely that taxes could be levied at the
State level to control air pollution. However, it is not clear whether
the rate of tax can be varied from region to region. Taxes levied by
the authority administering a single AQMA would almost certainly require
enabling legislation from the State government and, perhaps, change in
the State constitution.
4. Evaluation of Control Measure Effectiveness
a. Ability of Measure to Maintain Standards. Emission
charges in themselves do not result in the maintenance of NAAQS. They
are used with other control measures and contribute through such mea-
sures to the maintenance of standards by providing economic incentives
to predetermined levels of control.
b. Relative Efficiency Compared to Other Measures. An
evaluation of the relative efficiency of emission charges cannot be made
because they are not used to the exclusion of other measures but rather in
a supplementary role.
G. TRANSFER OF EMISSION SOURCE LOCATION
1. Definition of Control Measure
The transfer of emission source location measure involves
the optimum use of terrain, meteorology, and geography of an AQMA from
an air pollution viewpoint. The influence of a given emission source
upon the air quality of an area varies with its location. This control
measure is one that explicitly considers source location and urges
relocation for minimum air quality impact upon all new construction or
expansion.
While this measure has the potential of being effective when
applied to all source categories, it is especially applicable to power
plants. However, because judicious relocation could result in a sig-
nificant improvement in local air quality within an AQMA, all source
categories should be considered as potential candidates for this mea-
sure.
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2. Historical Review
a. Current Applications of the Control Measure. This mea-
sure has often been used in power plant siting. A contemporary example
of the measure is the construction of major power plants including the
world's largest coal-fired generators--!'n the remote areas of the
Southwest that will ultimately supply 60 percent of their output to
Southern California, hundreds of miles removed (ref. 51).
The electrical output of power plants can be transported long distances
with only modest losses. In certain instances, as in the Southwest, the
measure moves the plant closer to the source of fuel so that the
transportation cost of moving fuel is reduced.
While the control measure could apply to other industries as well,
the number of attractive applications is probably limited by the added
transportation costs for employees, raw materials, and plant output.
Consequently, this measure has not been used extensively outside of the
power industry.
b. Effectiveness of the Control Measure in Current
Applications. Experience in the current application of this measure is
not adequate to enable an evaluation of its effectiveness. It
is emphasized that the implementation of this measure is not primarily
for the purpose of emission reduction, but rather spatial
redistribution and better use of atmospheric assimilative capacity.
However, NSPS may also cause lower emissions from the replacement
source.
3. Implementation
a. Procedures. Because this control measure is primarily a
power industry measure, it is most easily implemented by incorporation
into the growth plans of this industry. To a large degree, this has
already taken place. Siting of power plants is a well-studied and much-
discussed subject. Air quality impact statements are now mandatory for
virtually all building permit applications for new power generating
facilities.
Although there is considerable authority and practice in the reg-
ulation of new source admission within a controlled area, the relocation
or removal of an existing source is not clearly defined as a possible
control measure. Air pollution statutes in some jurisdictions
authorize the control board to issue abatement orders which could result
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in court injunctions. These actions, however, have been used to force
compliance with emission standards by application of accepted pollution
control devices. Sources may be relocated indirectly by excluding
specific source types from certain areas or by setting emission limits
so low that they are unattainable.
Transfer of emission source location probably will come about as
obsolete or uneconomical facilities are replaced. While the permit and
review procedures for new and modified sources could serve as a mech-
anism for forcing transfer of emission sources through disapproval of
the request for permission for construction or modification, special
legal provisions should be established for power plant siting.
Some States, e.g., Ohio and Maryland, have enacted power plant
siting legislation. A description of the Ohio legislation is presented,
not as an example to be followed, but as a description of one State's
approach. Other legislation, such as Maryland's, should be studied
prior to developing such a system in States where none currently exist.
Ohio has enacted power plant siting legislation that can serve as a
model. The Ohio law established a Power Siting Commission composed of the
Chairman of the Public Utilities Commission, the Director of Environ-
mental Protection, the Director of Health, the Director of Development,
and a public member, an engineer to be appointed by the Governor.
Prior to construction of a major facility, defined as one having a
design or actual capacity of 50 MW or more, a certificate must be
obtained from the Power Siting Commission. Certificates are obtained
by filing an application containing the following information:
Description and location of the facility,
Summary of any studies of the environmental impact of the
facility;
Need for the facility,
Reasons why the proposed location is best suited for the
facility,
How the facility fits into the applicant's 10-year forecast of
loads, resources, and prospective sites, and
Other information considered relevant by the applicant or the
Commission.
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The application, which must be filed not less than 2 years, nor
more than 5 years prior to planned construction, is subject to public
hearing within 60 to 90 days of receipt. Following the public hearing,
the Power Siting Commission grants or denies the certificate after
evaluating the effect on the environment using its own adopted rules and
criteria. One of the criteria is that the proposed facility represents
the minimum adverse environmental impact, considering the state of
available technology and the nature and economics of the various al-
ternatives.
The certificate is conditional upon the facility being in com-
pliance with the applicable regulations governing air quality. The
certificate applies to the initial 2 years of operation during which time
the facility is subject to the enforcement and monitoring powers of the
Director of Environmental Protection. If it is determined during the
initial period that the facility is unable to operate within compliance
of air quality laws and regulations, a conditional permit to operate may
be issued.
Lead times for power plant construction now exceeds 10 years (ref.
52) so that the measure, implemented in this manner, demands foresight
in planning in order to achieve maximum effectiveness.
b. Conditions of Applicability. This control measure is
highly specialized in that the specific criteria of applicability vary
from one industry to another. The relocation should not result in costs
appreciably more than operation at the original site plus the cost of
improved control equipment required to equivilantly reduce emissions.
Capital costs, other than those involved with land acquisition, should
be essentially the same regardless of the actual new plant location.
If the relocation makes the plant output less expensive, no further
justification is required. Such an ideal condition does not normally
exist except in the power generating industry.
For electric power generation, certain relocations can make the
output cheaper, such as when the power plant is relocated near the mouth
of a coal mine. Coal shipping and ash disposal costs are greatly reduced
and electric power transmission costs are not greatly increased once
the power lines are installed.
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Power plants do not have to be relocated to remote land areas.
Alternatives are possible, including offshore sites. Offshore sites are
attractive for both fossil fuel and nuclear fueled power plants (refs. 53, 54)
This form of relocation, while limited primarily to coastal areas (rivers,
inland lakes, or bays might also be suitable for certain inland sites),
seems likely to be a significant form of this control measure in the
future as land sites everywhere become less available.
Relocation to remote land sites is more and more being viewed as
an inadequate, inappropriate shift of air pollution burden. Somewhat
more pallatable is the offshore site but even here EIS's will be carefully
reviewed and, most likely, excessive emissions (non-state-of-the-art)
will be disapproved regardless of location.
The previously cited examples of relocation involve transfer of the
site outside the area that might be included in an AQMA. The measure
also has applicability to relocation of sources within an AQMA to clean
up "hot spots" or prevent undue clustering that could result in "hot
spots". In these cases, the air quality situation must be analyzed to ensure
the ability of the area in which relocation will take place to assimilate
the increased emissions.
c. Interactions With Other Control Measures. Transfer of
emission source location occurs in the course of implementing other
control measures and consequently can become part of them. For example,
if a community adopts district heating as a control measure, the net effect
is to relocate a multitude of individual space heating sources into one
centralized source. This combination of sources is therefore a relocation
as well. Or, when an industry decides to upgrade an existing operation,
it is often advantageous to move to a new site as part of the plan.
In conjunction with an emission allocation plan, relocation may
be one of the measures used to reduce total emissions in a problem subarea.
d. Potential Conflicts With Other Community Development
Plans and Potential Negative Environmental Effects. The major short-
coming of this control measure is that of itself it does not permanently
reduce air pollution emissions within the AQMA unless the new site is
outside the AQMA boundaries. It can, however, result in maximum uti-
lization of the assimilative capacity of the atmosphere by spatial
redistribution of emissions. In such a case, however, the analysis must
consider the impact of relocation on the new area. Determination must
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be made of the impact of this move on the air quality in the new area
and whether such action would require designation as an AQMA and
preparation of an AQMP. Only when coupled with other control measures
will a net global gain in air quality result.
e. Practical Limitations
1) Social acceptability. Public acceptability of this
strategy is marginal. Small minority groups can block or slow down
proposed relocations and are doing so with increasing frequency. The
EIS's accompanying applications for building permits are now being
regularly challenged. EPA's acceptance of certain EIS's is also being
challenged in the courts.
These objections apply to a lesser extent to offshore relocations
but this concept is still new and untried so that significant opposition
has not yet had a chance to coalesce. As portent of things to come, the
Florida Audubon Society and the Natural Resources Defense Council are
already asking for AEC rulings that could halt the New Jersey floating
nuclear plant program.
2) Economic feasibility. Economic feasibility is a
prerequisite for any serious control measure, including transfer of
emission source location. Both land sites and offshore sites possess
sufficient advantages for power plant relocation to be economically
attractive. When moved nearer their sources of fuel, land sited power
plants become less expensive to operate. Coal becomes cheaper because
of reduced transportation costs; ash disposal is simplified and less
expensive. Offshore sites have obvious cooling advantages in addition
to safety, esthetic, and environmental advantages.
4. Evaluation of Control Measure Effectiveness
a. Ability of Control Measure to Maintain Standards. This
control measure is limited in both effectiveness and applicability. One
limitation arises from the long lead time required for implementation.
A relocation of any type requires advance planning. In the case of
power plants, the required lead time is now approaching 14 years, which
is beyond the time frame covered by the AQMP. Nuclear power plants designed
to be on stream by 1985 must already be well along in their site search
in 1974.
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b. Relative Efficiency When Compared to Other Measures. The
efficiency with which this control measure operates depends on whose
viewpoint is considered. The resident of downtown Los Angeles will find
the measure very efficient in reducing his local power plant emissions.
For the Four Corners resident, however, it is undesirable. This con-
flict of interests will limit the use of this control measure.
Offshore applications, particularly on the East Coast where pre-
vailing winds sweep emissions out to sea, have the advantage of not
grossly disadvantaging local citizenry in the vicinity of the relocated
plant. As the international aspects of air pollution become more
important, the import of emissions on Europe may effect the decision to
construct an offshore plant.
H. INDIRECT SOURCE REVIEW
1. Definition of Control Measure
Indirect source review, in contract with most of the other mainte-
nance control measures, is an integral, not an optional, part of every
AQMP.
The types of new or modified sources that are to be reviewed for
approval under this measure are cited in the regulation for maintenance
of national standards, 40 CFR 52.22. The sources subject to review
include, but are not limited to, the following:
Highways and roads;
Parking facilities;
Retail, commercial, and industrial facilities;
Recreation, amusement, sports, and entertainment
facilities;
Airports;
Office and government buildings;
Apartment and condominium buildings;
Education facilities.
The above sources include most public and large commercial building
projects.
The review procedure is limited, however, to developments above
certain sizes, which are also stated in regulation 40 CFR 52.22 (b)(2).
These size thresholds are specified in terms of daily traffic volumes
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for highways, annual aircraft operations for airports, and number of
parking spaces for most other facilities. Indirect sources smaller than
the threshold sizes are assumed to be evaluated and controlled as part
of overall growth by other maintenance strategies.
The indirect source review procedures apply only to the automobile-
related pollutants. The intent of this review procedure is to ensure
good traffic design so that motor vehicle emissions in the vicinity of
the indirect source are minimized. With few exceptions, the review
should not result in a limitation on the size of the facility or influ-
ence its location.
Emission reductions are achieved through disapproval of deficient
initial development plans, by requiring that modifications be made to
the internal or access traffic handling facilities to improve projected
traffic flow. The reviewing agency is not obligated to recommend the
design modifications or improvements that should be made.
2. Historical Review of the Measure
a. Current Application. The concept of a systematic procedure
for the review of proposed new indirect sources was first presented by
EPA in the April 18, 1973, proposed guidelines to the States for prep-
aration of approvable indirect source review measures (ref. 55). Final
guidelines were promulgated on June 18, 1973 (ref. 56), and the States
were given until August 15, 1973, to submit procedures in accordance
with the guidelines for approval. No States were able to respond within
this strenuous time frame, and only eight States and territories sub-
mitted procedures prior to the proposal of Federal regulations for
indirect source review.* Since the public did not have adequate oppor-
tunity to comment on these eight plans, no State-submitted procedures
could be approved.
Subsequently, the Administrator proposed Federal regulations for
review of indirect sources on October 30, 1973 (ref. 57), to be appli-
cable in the States that submitted nothing or whose plans could not be
approved. The final regulations were promulgated on February 25, 1974
(ref. 58), but are to be applicable to indirect sources that start
construction after December 31, 1974. These regulations are currently
*Alabama, Florida, Guam, Puerto Rico, Maine, New York, Oregon, and
Washington.
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undergoing study and will be revised in the near future. Therefore,
this administrative review procedure has no past history of employment
that can be cited as a case study.
Of the first eight plans submitted, only the Florida and Guam plans
were fully approved at the time that the Federal regulations were promul-
gated. The Florida system for review and approval/disapproval of appli-
cation to construct an indirect source was implemented as of December 15,
1973. Procedures were integrated into the existing permit system of the
Florida Department of Pollution Control, and specially designed application
forms (with instructions for completion) are currently used for two source
categories: highway projects and nonhighway projects.
At the onset of this program, State personnel conducted instructional
seminars in several areas to acquaint developers with the review pro-
cedure and the regulatory requirements. Additionally, the agency has
prepared checklists for use by its field office personnel in reviewing
applications in an effort to ensure uniform processing. In the first 2
months of implementation, the agency received approximately 25 permit
applications dealing with indirect sources. Of these, the 12 that
completed review were all approved as submitted.
b. Effectiveness of the Measure in Current Applications.
This control measure does not have a record of past application.
3. Implementation
a. Procedure. The review procedure must be established and
operated, at a minimum, in accordance with the general guidelines pub-
lished on June 18, 1973, and under one of two possible sets of more
detailed procedures:
1) Those described in an approved plan for review sub-
mitted by a State or
2) Those promulgated in 40 CFR 52.22 on February 25,
1974, to be implemented by EPA or an agency to which it has delegated
the responsibility for conducting indirect source review. Since it is
anticipated that the latter set of procedures will be more widely used,
it is briefly described below. It is expected that these regulations may
undergo revision.
The owner or operator of any proposed new indirect source subject
to the regulations (see table II-7) must submit an application for
approval to EPA or its designated agency prior to construction, by a
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Table 11-7. Indirect sources requiring approval
Location
Sources
Minimum size for review of impact of
carbon monoxide air quality standards
Minimum size for review of impact
on photochemical oxidant and
nitrogen oxides air quality standards
Urban area
(SMSA)
i
10
Nonurban area
New roads and
highways
Modified roads
and highways
New airports
Modified airports
Other indirect
sources, new
Other indirect
sources, modified
Airports
Other indirect
sources, new
Other indirect
sources, modified
20,000 vehicles per day (average)
10,000 vehicles per day over
existing traffic (average)
50,000 operations or 1.6 million
passengers per year
50,000 operations per year
increase over existing level,
or increase of 1.6 million
passengers per year
Parking for 1,000 cars or more
Parking for 500 cars or more
over existing number
Same as in urban areas
Parking for 2,000 cars of more
Parking for 1,000 cars or more
over existing number
50,000 vehicles per day (average)
25,000 vehicles per day over
existing traffic (average)
50,000 operations or 1.6 million
passengers per year
50,000 operations per year
increase over existing level,
or increase of 1.6 million
passengers per year
No analysis required
No analysis required
Same as in urban areas
No analysis required
No analysis required
Source: 40 CFR 52.22 (b) (2), (February 25, 1974).
-------
means prescribed by the Administrator. Information that
must be included in or attached to the application is listed in table
II-8; other information more specific to the type of facility may also
be requested at the time of application. It is anticipated that, when
the specifics of the review procedure are established, the list of
required information, as shown in table 11-8, will be expanded. For
example, the design capacity of proposed highway sections will probably
be required data.
According to the regulations, the reviewing agency must then ful-
fill the following:
1) Notify the applicant within 20 days of any deficiency
in the information submitted;
2) Make a preliminary determination within 30 days
whether the indirect source should be approved, conditionally approved,
or disapproved;
3) Make a copy of information submitted and the agency's
evaluation available for public inspection;
4) Notify the public and specified cognizant agencies of
the opportunity for written comment within an additional 30-day period;
5) Make a final determination after considering the
comments received; and
6) Notify the applicant in writing of the approval,
conditional approval, or disapproval, with the reasons for the decision
stated.
Determination of approvability is to be based on:
1) No interference with the applicable control strategy, if
the source is to be located in an AQCR with a transportation control
plan;
2) No violation of the carbon monoxide NAAQS (also the
photochemical oxidant and nitrogen dioxide NAAQS for proposed major
highways and airports), or no delay in attainment of the applicable
standards if the date specified for attainment has not been reached.
Specific procedures to be used in these determinations are delin-
eated in vol. 9, guideline series, Evaluating Indirect Sources.
Further description of the review process may be found by referring
directly to the regulation, 40 CFR 52.22. The minimum procedures for
implementing this control measure are prescribed by regulation. There-
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Table II-8. Required information for indirect source review
Indirect source type
Required information
All except highways
Ai rports
Highway sections
1. Name and address of applicant.
2. Map showing location of the site.
3. Description of proposed use, hours
of operation, types of activities.
4. Site plan showing buildings, parking
areas, and points of auto ingress
and egress.
5. Identification of access roa'ds and
intersections.
6. Estimate of present average daily
traffic volumes (ADT), peaking
characteristics, and levels of
service on access roads and inter-
sections .
7. Estimate of average daily vehicle
trips and peaking character!st-ics
associated with the source (for its
first full year of operation).
8. Estimate of maximum number of vehicle
trips within 1-hour and 8-hour
periods.
9. Estimate of ADT, peaking character-
istics', and levels of service on
access roads and intersections
aft«r source is operational.
10. Availability of existing and pro-
jected mass transit service at the
site.
11. Any additional information necessary
to determine air quality impact,
including measured air quality data
prior to construction.
In addition to the above,
1. Estimate of average and maximum air-
craft operations per day by aircraft
type for first, fifth, and tenth year
of operation.
2. Description of other development ex-
pected to occur within three miles of
airport.
3. Expected passenger loadings.
1. Average and maximum traffic volumes
for 1, 8, and 24-hour periods within
10 years of completion.
2. Estimate of vehicle speeds for
average and maximum traffic volumes.
3. Maps showing location of the highway
section.
4. Description of general features of
the highway section and right of way.
5. A copy of any environmental impact
statement prepared for the highway
section.
Source: 40 CFR 52.22 (b) (3), (February 25, 1974).
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fore, development of most procedures by the designated agency is not
necessary. A major procedure to be formulated is that of coordination
between the agency performing indirect source review and the agency
responsible for carrying out the AQMP.
b. Conditions of Applicability. This control measure is a
part of every AQMP, regardless of whether the plan is needed
for control of any of the "automotive" pollutants. Thus, a discussion
of conditions under which this review procedure could be applied ef-
fectively is not relevant.
c. Interaction with Other Measures. In the preamble to the
June 18, 1973, promulgation, the Administrator acknowledged that in-
direct source review, while "a necessary addition" to an overall strategy
for ensuring maintenance, could be considered only an additional tactic
in such strategy, "because source-by-source analysis is not an adequate
means of evaluating, on a regional scale, the air quality impact of
growth and development...". Its primary purpose was stated to be to
ensure "that the national standards will not be violated in the vicinity
of a major new facility".
However, its role may be extended beyond that if it is used to
provide a source-by-source check on the consistency of major proposed
public and commercial projects with a regional land-use plan that has
previously been demonstrated to be capable of maintaining air quality
standards. In this capacity, indirect source review would serve as an
enforcement mechanism in conjunction with a prior planning process.
The authority for this extension of the role of indirect source
review is included in the provision that a proposed indirect source can
only be approved if it "will not cause a violation of the control
strategy of any applicable state implementation plan". Applicable
portions of the land-use plan would need to be adopted as part of the
maintenance plan. This combination of measures would not provide a
means of correction if violations of the standard occur after the
indirect source has been approved and constructed.
Indirect source review could be used in a similar manner in con-
junction with a transportation control strategy to assist in its imple-
mentation.
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The relationship between the indirect source review procedure and
an EIS as required by the National Environmental Policy Act should also
be noted. An EIS would not be required of all facilities qualifying as
indirect sources, but would in general provide a more detailed analysis
of air quality impact if it is conducted. Section 52.22 specifically
states that any EIS for the source should accompany the application, and
that information included in the EIS need not be provided separately in
the application. This implies that, if judged to adequately answer all
the points in the review process, the EIS evaluation may replace the
standard analysis. However, the reviewing agency must still follow the
six-step approval/disapproval procedure outlined above. This is par-
ticularly important because the EIS is only one factor in deciding
whether a proposed project should be controlled, and air quality con-
siderations may not dictate the final decision.
d. Potential Conflicts With Community Development Plans.
The indirect source review could have the effect of limiting the size
and/or density of commercial and municipal developments that are reached
primarily by automobile. This could, in turn, result in a greater
dispersion of trip-generation points and more and longer trips. In
contrast, many area development plans favor clustering of these develop-
ments to encourage multiple-purpose trips and to enhance the feasibility
of mass transit systems. To the extent that staged development of these
traffic centers precludes the large-scale use of mass transit during
intermediate stages of development, the indirect source review procedure
may act to discourage plans that might be beneficial on a regional scale
or on a long-range basis.
This potential conflict emphasizes the desirability of performing
the review within the context of insuring compatibility of individual
facilities with an areawide plan that has been found consistent with air
quality maintenance. With a higher degree of planning and coordination
for proposed cluster developments, any dispersive impact resulting from
this review can be minimized.
e. Practical Limitations.
1) Social acceptability. Because the review procedure
has primary involvement only by the developer and the reviewing agency,
general public awareness of this control measure will probably be quite
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limited. The review process does provide for comments by the public, so
it offers a channel for participation for those who feel that they would
be strongly affected by the proposed indirect source or by the results
of the review.
Although the primary intent of this control measure is to minimize
air pollution emissions through better traffic engineering design, it
appears that the secondary benefit of reduced traffic congestion would
have a favorable impact on most persons. Any increased on-site costs of
the improved traffic flow would probably be borne indirectly by users of
the facility, the same persons who would benefit most. Modifications to
access roads or added signalization, on the other hand, would usually be
financed through general tax funds.
Most criticism of the review process prior to promulgation of the
Federal regulation was voiced by developers. Their comments are sum-
marized in the preamble to the final promulgation (ref. 57) and are
considered in the final version of the regulation.
2) Economic feasibility. The costs arising from actions
taken to obtain approval under the indirect source review process appear
to be quite minimal. Any additional cost to the developer to optimize
the traffic and parking facilities, sufficient to reduce the impact of
the source upon air quality, may not represent a true air pollution
control cost. A direct benefit to the patrons of the source may result
in the form of both time and fuel savings.
Data necessary to determine the air quality impact of the indirect
source, as described in table II-7, should be readily available to the
developer. Therefore, the added cost of submitting such data to the reviewing
agency normally should not impose any significant financial burden upon
the developer. Possible exceptions would be in cases where the applicant
either is required to obtain and submit measured air quality data at the
proposed site or chooses to perform atmospheric dispersion model analyses
prior to submitting the application.
4. Evaluation of Control Measure Effectiveness
a. Ability of Strategy to Maintain Standards. The effec-
tiveness of indirect source review in maintaining NAAQS's should be
judged on two different scales of analysisa microscale and a AQMA
scale. If this separation is accepted as a valid, logical distinction,
effectiveness can be adequately discussed in solely qualitative terms
without resorting to any quantitative methodology.
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On a microscale, indirect source review alone should be effective
in preventing the carbon monoxide standards from being exceeded as a
result of motor vehicle emissions. This comprehensive control is limited
only by the ability of the review procedure to accurately predict
traffic volumes, traffic behavioral characteristics, and resulting
maximum CO concentrations associated with the proposed indirect source.
With a few modifications, the procedure as it exists now could also
be used to effectively control maximum short-term concentrations of
hydrocarbons and nitrogen oxides on a microscale, if this were of value.
However, both of these are reactive pollutant groups, and the short-term
"standard" for hydrocarbons is only for use as a guide to levels con-
sistent with maintenance of the oxidant standard. Therefore, limitations
on HC and NO levels in the immediate vicinity of their emission would
probably not have any quantifiable effect on maintenance of NAAQS's
within an AQMA. Only the aggregate effect of emission reductions at
many different locations during time periods prior to the measurement of
peak ambient concentrations can be expected to reduce these maximum
concentrations.
On the AQMA scale, the indirect source review process is not capable
of significantly controlling total emissions of automotive pollutants.
Its resultant effect on CO levels is best described as peak-shaving;
i.e., it acts to limit concentrations in potential "hot spots", or
isolated areas of high traffic density, but probably has no measurable
impact on CO emissions or ambient concentrations in most parts of the
AQMA.
The major shortcoming of the review procedure in maintaining the CO
standards on an AQMA scale is that it cannot consider traffic increases
resulting from an area's population growth that may occur at indirect
sources that were in existence prior to 1975. For example, a new
residential area may generate sufficient traffic on an existing highway
connecting it to a large employment center to result in the CO standards
being exceeded. However, unless the highway is modified, it would not
be subject to the indirect source review procedure.
Only two types of indirect sources are to be reviewed for their impact
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on regional oxidant and nitrogen oxides concentrations: airports (50,000
or more operations/year or 1,600,000 passengers/year) and major highways
(more than 50,000 vehicles/day on an existing one). EPA-recommended
review procedures are forthcoming, so it is not yet possible to
determine what effect this review will have on maintenance for these
two pollutants.
b. Relative Efficiency When Compared to Other Measures. By
the very nature of its evolution, the indirect source review procedure
is intended to be an important part of air quality maintenance within an
AQMA. It serves as a check for air quality maintenance on a very
localized scale. As one component of the AQMP, it may also be struc-
tured to serve as an implementation or enforcement mechanism to ensure
that individual projects are consistent with some broader maintenance or
development program that has been established in the plan.
The review procedure does not offer a prior constraint on planning
because of its postplanning, preconstruction position. Moreover, the
procedure is not capable of evaluating air quality impacts of proposed
or projected growth on a regional scale. Therefore, it appears that
indirect source review is a necessary, but not sufficient, measure in
areas where an AQMP is needed. In developing an AQMP, no credit should
be given for pollutant emission or ambient concentration reductions due
to the existence of the indirect source controls.
I. ENVIRONMENTAL IMPACT STATEMENTS (EIS's)
1. Definition of Control Measure
Section 102(2)(C) of the National Environmental Policy Act
(NEPA) of 1969 requires all Federal agencies to submit an EIS to the
Council on Environmental Quality (CEQ) prior to taking major actions
that may significantly affect the human environment. Furthermore, the
act requires that an EIS be prepared in consultation with those Federal
agencies that have jurisdiction by law or special expertise with respect
to any environmental impact involved. In general, the provisions of
NEPA apply to projects that are administered or funded by the Federal
Government; an EIS must accompany a proposal for action through the
existing agency review process.
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Although NEPA does not explicitly state that a project's effect on
air quality is to be discussed in an EIS, both CEQ guidelines (ref. 59)
and agency regulations for the preparation of EIS's stipulate that air
quality impacts are to be considered. Probably the most significant air
pollution emission sources requiring EIS's are proposed Federal or
federally assisted highways and airports, and power plants.
In addition to Federal environmental legislation, 17 States and the
Commonwealth of Puerto Rico have legislatively adopted or administra-
tively promulgated policies and provisions similar to NEPA (ref. 60).
While most of the jurisdictions make use of an EIS in one way or another,
the applicability and scope of the EIS requirement varies.
2. Historical Review of the Control Measure
a. Current Application. From January 1, 1970, the date NEPA
became effective, through December 31, 1973, 4,783 EIS's were filed with
CEQ. Of these, 2,012 were for highways and roads, 371 were for air-
ports, and 44 were for power plants (ref. 61).
Guidelines for the preparation of EIS's issued by CEQ in 1971
directed each Federal agency to establish its own formal procedures for
complying with NEPA. These guidelines and, in turn, Federal agency
regulations have had to be revised periodically to implement various
Federal court decisions relating to NEPA. Almost all of the approxi-
mately 220 NEPA cases reported between January 1970 and September 1973
focused on some aspect of the EIS (ref. 62). The courts generally have
assumed responsibility for interpreting and enforcing procedures set
forth in sec. 102(2)(C), including: 1) its applicability (i.e., whether
an action is major, Federal, and significantly affects the environment
and therefore requires an EIS); 2) the scope and depth of information
necessary in an EIS, including the extent to which alternatives must be
discussed; and 3) how information in an EIS must be considered in
making a final decision.
Some courts have specifically discussed the need for air quality
assessment in an EIS. For example, in the case of Keith vs. Volpe. July
7, 1972, a California District Court halted work on the 17-mile Century
Freeway (1-105) in Los Angeles County until an EIS was prepared and
considered in accordance with the requirements of NEPA and the California
Environmental Quality Act. Among other things, the court declared that
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the EIS should examine, with as much precision as possible, the impact
of the proposed freeway on air quality in the Los Angeles basin. In
evaluating the air quality impact, the court said the EIS should consider
the effect of wind and weather on the dispersal of pollutants
as well as the effect of other sources of pollution and the extent to
which the freeway would draw more automobiles into the southern Los
Angeles basin (ref. 63).
b. Effectiveness of the Measure in Current Applications.
The sole purpose of an EIS is to alert decision makers and the general
public to the environmental risks involved in major Federal actions. If
the final EIS indicates that there are adverse environmental effects,
including air quality impacts, associated with what is considered to be
the best alternative action, decision makers must evaluate whether the
adverse environmental effects outweigh the benefits of proceeding with
the projects. NEPA, however, does not provide veto power over the
decision that is finally made.
3. Implementation
a. Procedures. An EIS must include the following:
1) A detailed description of the proposed project,
including information and technical data adequate to permit a careful
assessment of the environmental impact.
2) Discussion of the probable impact on the environment.
3) Any adverse effects that cannot be avoided.
4) Alternatives to the proposed action that might avoid
some or all of the adverse environmental impacts, including an analysis
of the cost and environmental impacts of each alternative.
5) An assessment of the cumulative, long-term use of the
environment versus the environment's long-term productivity.
6) Any irreversible or irretrievable commitments of
resources that might result from the action that would curtail bene-
ficial use of the environment.
The preparation of an EIS involves a two-step process. First, a
draft statement is prepared that draws together all the data needed to
inform Federal officials and the general public about the environmental
effects of a proposed project and of possible alternative actions. The
draft statement is circulated for comment to Federal, State, and local
environmental agencies and to the general public, who have a minimum of
45 days to review and comment on the draft statement.
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After all comments made during the review process (and at the
public hearing if one is held) are received, the EIS is prepared in
final form. The final EIS must incorporate all comments and objectives
raised on the draft and indicate how significant issues have been re-
solved. Once a final EIS is completed, it must be filed with CEQ and
made available to the public and those agencies that reviewed the draft
statement.
Section 309 of the Clean Air Act, as amended, requires that the
Administrator of EPA comment in writing on the possible environmental
impacts (i.e., air, noise, water, solid waste) of all proposed Federal
actions to which sec. 102(2)(C) of NEPA applies. After his review, the
Administrator has to make his comments public. If he finds a proposal
environmentally unsatisfactory, he has to publish this finding and refer
the matter to CEQ (ref. 64).
Except for highly controversial projects, most highway and airport
EIS's are reviewed by EPA Regional Offices. The most important
consideration in any EPA air quality review is whether or not the
project adversely affects the attainment or maintenance of the NAAQS.
Such a determination depends, to a great extent, upon the adequacy of
the EIS and the ability of the reviewer to assess the significance of
the material presented.
EPA Order 1640.1, Review of Federal Action Impacting the Environ-
ment, established separate rating systems for project impact and EIS
adequacy. These systems, which are used in reviewing draft EIS's, are
described in table II-9.
b. Applicability. According to CEQ guidelines, major
Federal actions include but are not limited to:
1) Recommendations or favorable reports relating to
legislation and appropriations;
2) New and continuing projects and program activities:
directly undertaken by Federal agencies; supported in whole or in part
through Federal contracts, grants, subsidies, loans, or other forms of
funding assistance; involving a Federal lease, permit, license, cer-
tificate or other entitlement for use; the making, modification, or
establishment of regulations, rules, procedures, and policy (ref. 59).
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Table II-9.
EPA rating systems for project impact
and EIS adequacy
Rating
area
Rating
Definition
Environmental
Impact of the
Action
LO
(Lack of
Objections)
ER
(Environmental
Reservations)
EU
(Environmentally
Unsatisfactory)
EPA has no objections to the proposed action
as described in the draft EIS; or suggests only
minor changes in the proposed action.
EPA has reservations concerning the environ-
mental effects of certain aspects of the proposed
action. EPA believes that further study of sug-
gested alternatives or modifications is required
and has asked the originating Federal agency to
reassess these aspects.
EPA believes that the proposed action is unsatis-
factory because of its potentially harmful effect
on the environment. Furthermore, the Agency
believes that the potential safeguards that might
be utilized may not adequately protect the environ-
ment from hazards arising from this action. The
Agency recommends that alternatives to the action
be analyzed further (including the possibility of
no action at all).
Adequacy of Category 1 The draft EIS adequately sets forth the environ-
tne EIS (Adequate) mental impact of the proposed project or action
as well as alternatives reasonably available to
the project or action.
Category 2 EPA believes that the draft EIS does not contain
(Insufficient sufficient information to assess fully the envi-
Information) ronmental impact of the proposed project or action.
However, from the information submitted, the Agency
is able to make a preliminary determination of the
impact on the environment. EPA has requested that
the originator provide the information that was
not included in the draft statement.
Category 3 EPA believes that the draft EIS does not adequately
(Inadequate) assess the environmental impact of the proposed
project or action, or that the EIS inadequately
analyzes reasonably available alternatives. The
Agency has requested more information and analysis
concerning the potential environmental hazards and
has asked that substantial revision be made to the
EIS.
If a draft EIS is assigned a Category 3, no
rating will be made of the project or action,
since a basis does not generally exist on which
to make such a determination.
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Each Federal agency is responsible for identifying whether the
actions it seeks to undertake are major and significantly affect the
environment. CEQ guidelines state that the words "major" and "sig-
nificantly" are intended to imply thresholds of importance and impact
that must be met before a statement is required. CEQ has directed that
each agency review the typical classes of actions it undertakes and
develop specific criteria and methods for identifying actions likely to
require EIS's.
As noted earlier, the applicability of the EIS requirements at the
State level varies. Most State provisions follow NEPA's lead and limit
applicability to "agencies of the State." Among the exceptions are the
California Environmental Quality Act, which outlines specific responsib-
ilities for local governments, and Washington's Environmental Policy
Act, which applies to all branches of State government, including State
agencies, municipal and public corporations, and counties. North
Carolina authorizes local governments to require an EIS from any public
or private developer of a "major development project" (ref. 65).
In defining major, environmentally significant actions, State EIS
provisions generally parallel Federal requirements. However, there are
exceptions. For example, the courts have extended California's EIS
requirements to private activities requiring public permission; Indiana's
law explicitly excludes licensing activities; and North Carolina limits
its EIS requirements to "actions involving expenditures of public moneys
for projects and programs significantly affecting the quality of the
environment."
c. Interaction with Other Measures. The EIS interacts with
three other control measures in maintaining air quality standards:
regional development planning, indirect source review, and control of
construction activities.
While regional development planning can provide a general guide to
the siting and location of various types of development, it cannot
predict if air quality standards will be exceeded by an individual
project. In addition to assessing whether or not a proposed project is
compatible with an adopted regional plan, an EIS can identify localized
air pollution problems associated with a project that could interfere
with the maintenance of air quality standards.
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If an EIS is prepared for an action subject to indirect source
review, it should accompany the application for approval through the review
process and may substitute for the standard analysis outlined in 40 CFR
52.22.
An EIS is one of the few measures that assesses impacts on air quality
during the construction phase of a project; in addition, an agency preparing
an EIS must indicate what steps will be taken during construction to
minimize those impacts.
d. Potential Conflicts with Community Development Plans.
CEQ guidelines require that an EIS discuss the relationship of a pro-
posed project to approved or proposed Federal, State and local land-use
plans, policies, and controls for the project area. If a conflict or
inconsistency exists, the EIS should describe the extent to which the
project has been reconciled with the plan. If full reconcilation has not
been achieved, the EIS must discuss why the sponsoring agency has
decided to proceed with the project.
e. Practical Limitations.
1) Social acceptability. Public participation as early
as possible in the EIS process is encouraged by CEQ. Some agencies have
actually sponsored extensive community participation programs throughout
the environmental assessment phase of a project in order to ensure that
major community concerns are addressed in an EIS. As a minimum, a draft
EIS must be made available to the public, which has at least 45 days to
comment. Responses to substantive comments received on a draft state-
ment must be incorporated into the final EIS. In general, public re-
action to the EIS process appears to depend upon whether an individual
approves or disapproves of a project. Those who approve often see the
EIS process as an unnecessary delay, while those who disapprove welcome
the EIS as a means of alerting decision makers to the specific social,
economic, and environmental problems associated with a proposed project.
2) Economic feasibility. The preparation of an EIS
does not represent a true air pollution control cost since air quality
impact is only one of many environmental aspects examined in an EIS.
The detail provided in an EIS, and hence the cost of preparation, should
be commensurate with the extent and expected impact of the proposed project
and with the amount of information required at a particular
decisionmaking level. Generally, the sponsoring Federal agency assumes
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the cost of an EIS for a project under its jurisdiction.
4. Evaluation of Control Measure
a. Ability of Measure to Maintain Standards. The EIS alone
would not be effective in maintaining air quality standards. First, the
EIS requirement is not comprehensive enough, particularly in those
States that have not enacted "little NEPA's." Because of the limited
applicability of NEPA, major air pollution sources such as large-scale,
privately funded industrial, commercial, and recreational facilities are
not subject to the EIS requirement.
Second, air quality considerations do not necessarily dictate the
final decision on a project. Although decision makers are required to
consider the environmental impacts of a proposed actionincluding
whether or not it is in conformance with a State's air pollution control
implementation planthey are permitted to balance these impacts against
the project's economic and technical benefits before making a final
decision.
It should be noted, however, that as Federal guidelines and reg-
ulations for the preparation of EIS's are refined over time and as
coordination among agencies improves, mitigation of any serious environ-
mental impacts associated with a project is likely to be accomplished
early in the planning process.
b. Relative Efficiency Compared to Other Measures. An EIS
air quality analysis relates the impact of proposed new emission sources
to the applicable air quality standards; thus, it provides a direct
check for maintenance of the standards. However, the review process
does not apply to all new sources, nor even to entire source categories.
Therefore, it is not a sufficient measure for maintenance by itself. It
is difficult to assign an efficiency to the EIS when it is employed in
conjunction with other measures, since its efficiency depends to a great
extent on the scope of its applicability; i.e., whether a State has an
environmental policy act in effect to supplement Federal environmental
legislation.
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55. Federal Register 38, 9599.
56. Federal Register 38. 15834.
57. Federal Register 38, 29893.
58. Federal Register 39, 7270.
59. Council on Environmental Quality. "Preparation of Environmental
Impact Statements-Guidelines." Federal Register 38, No. 147
(August 1, 1973).
60. Nicholas C. Yost. "NEPA's Progeny: State Environmental Policy
Acts." Environmental Law Reporter III No. 8 (August 1973).
11-109
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61. Council of Environmental Quality. "Summary of 102 Statements
Filed with the CEQ Through 12/31/73." 102 Monitor 3 No. 12
(January 1974).
62. Council on Environmental Quality. "NEPA and the Courts." 102
Monitor 3 No. 9 (October 1973).
63. Keith vs. Volpe. No. 72-355-HP (C. D. Calif., July 7, 1972).
64. Section 309, Clean Air Amendments of 1970, P. L. 91-604
(December 31, 1970).
65. Council on Environmental Quality. "More States Enact Environmental
Impact Statement Requirements." 102 Monitor 2 No. 4 (May 1972)
11-110
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Chapter III: EMISSION CONTROL MEASURES
A. NEW SOURCE PERFORMANCE STANDARDS
1. Definition of Control Measure
This measure encompasses two distinct programs that have
the common characteristic of requiring stringent controls on new sources:
Federal New Source Performance Standards (NSPS), and State and local
requirements for lower allowable emissions for new or modified sources
than for existing ones.
a. Federal Programs. A New Source Performance Standard (NSPS)
is defined in the Clean Air Act as "a standard for emission limitation
achievable through the application of the best system of emission reduction
which (taking into account the cost of achieving such reduction) the
Administrator determines has been adequately demonstrated (ref. 1).
Responsibility for development, implementation, and enforcement of the
Federally promulgated NSPS rests with EPA. Authority for implementation
and enforcement may be delegated to the States upon submission and approval
by the Administrator of adequate procedures for these purposes. NSPS are
applicable only to new or modified sources in specific stationary source
categories proposed and promulgated by EPA. The procedure requires
testing of the source after startup to determine compliance.
The NSPS generally provide more restrictive controls than the SIP
regulations for existing sources, thereby ensuring minimal impact from
new sources in the specified categories. Another aspect of this
measure's air quality maintenance action is the reduction in emissions
that results from obsolete sources being modified or replaced by comparable
new ones that are subject to the lower allowable emission rates of the
NSPS. As more source categories are included under the provisions of the
NSPS, this measure will increase in scope and effectiveness in minimizing
emissions.
Upon promulgation, the emission limitations of the NSPS are manda-
tory on all subsequent new or modified sources. Therefore, this measure
III-l
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is present in all areas independent of AQMP provisions and should be
considered as an integral component of all AQMP's.
While NSPS may be developed for hazardous air pollutants and des-
ignated pollutants, the discussion in this section is limited to the
applicability of NSPS to the criteria pollutants. NSPS controls may be
expressed as process weight, concentrations, or operating parameters.
b. State Programs. Under the Federal program, NSPS are
adopted according to nationwide priority, which may not be the same as
that required for any specific AQMA. Nothing in the Federal regulations
precludes the States from prescribing lower allowable emissions
limitations on new sources in categories not covered by Federal NSPS.
This would permit the tailoring of a program specific to the AQMA. Should
Federal NSPS be subsequently developed and promulgated, the State-
developed emission limitations would continue to be applicable if they
are at least as stringent as the NSPS. If the State-developed emission
limitations are less stringent, the NSPS requirements would take
precedence.
State regulations usually have provisions for review of new sources
prior to construction, and call for disapproval if the applicable emission
regulations or NAAQS would be violated. A State or local regulation with
more stringent emission limitations on new or modified sources would be
implemented through this review procedure. As with Federal NSPS,
State-imposed emission limitations on new and modified sources are based
on demonstrated best available control technology considered in the light
of social and economic feasibility.
2. Historical Review of the Measure
As previously mentioned, most SIP's contain provisions for
more stringent controls on new or modified sources than on sources in
existence at the time the SIP's were prepared. Because it would be
patently impossible to describe the history of State generated and
implemented NSPS, discussion in this paragraph is limited to the
Federal NSPS.
a. Current Application. The promulgation of NSPS serves
as one regulatory path to ensure the application of best technology in
the control of emissions from new and modified sources. NSPS are not
intended to be the sole regulatory path for reducing emissions of these
III-2
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pollutants, but rather to be a control mechanism in the overall strategy
of air pollution control and maintenance.
The Congress directed that the Administrator publish, within 90
days after enactment of the Clean Air Act amendments of 1970, a list of
categories of stationary sources. This list, subject to periodic re-
view, was to include a category of sources "if he determines it may
contribute significantly to air pollution which causes or contributes to
the endangerment of public health or welfare (ref. 1)." The initial
listing of stationary sources for which NSPS were proposed in August
1971 and promulgated in December of the same year covered five source
categories: fossil-fuel-fired steam generators, municipal incinerators,
cement plants, nitric acid plants, and sulfuric acid plants. A second
list proposed in June 1973 and promulgated in March 1974 covered asphalt
concrete plants, petroleum refineries, petroleum storage, secondary lead
smelters and refineries, secondary brass and bronze refining facilities,
iron and steel mills, and sewage treatment plants. Table III-l summa-
rizes the source categories currently covered by NSPS. In addition,
NSPS for primary copper, zinc, and lead smelters are nearing completion.
These NSPS cover S0? emissions from all three primary smelters and particu-
lates from zinc and lead.
b. Effectiveness of the Measure in Current Applications.
Evaluation of the effectiveness of NSPS in current applications involves
the evaluation of the impact of a single source within an area through
individual source review. While such an evaluation may be possible, its
accuracy is limited because in the current state-of-the-art, "ana-
lytical tools that can be used with confidence to predict the air quality
impact of a single source are not now available (ref. 2)."
3. Implementation
Implementation of State NSPS is accomplished through the new
and modified source review procedures specified in the SIP. The discussion
that follows covers the implementation of Federally promulgated NSPS.
a. Procedures. NSPS are automatically implemented without
action on the part of the States. The owner/operator of a facility
falling within the purview of NSPS must provide EPA with:
Notification of the anticipated date of initial startup.
Notification of the actual date of startup.
III-3
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Table III-l. Status of standards of performance for selected source categories (NSPS)
Control equipment
Source Affected facility Pollutant Opacity expected to meet
Regulation performance standard
Steam generators Coal- and oil-fired boilers Partlculates / Precipitator (coal)
(> 250 million Btu/hr) Coal- and oil-fired boilers SO Scrubber or low-S fuel
Coal- , oil- , and gas-fired NO Combustion modification
boilers x
Municipal Incinerators Incinerator Particulates / Precipitator
(> 50 tons per day)
Portland cement plants Kiln, clinker cooler Particulates / Precipitator or fabric
filter
Nitric acid plants Process equipment NOX / Catalytic decomposition
Sulfuric acid plants Process equipment S0x Dual absorption acid
plant
Acid mist / Fiber mist eliminator
Asphalt concrete plants Process equipment Particulates / Cyclone and fabric
filter or venturi
scrubber
Petroleum refineries Process gas combustion SOX H2S scrubbing units
Catalytic regenerator Particulates / Precipitator
CO Waste heat boiler
Petroleum storage Gasoline, crude oil, and Hydrocarbons Conservation vent,
distillate storage tanks floating roof, or
> 65,000 gal capacity vapor recovery systems
Secondary lead smelters Blast and reverberatory Particulates / Fabric filter or high
and refineries furnaces energy scrubber
Secondary brass and Reverberatory furnaces Particulates / Fabric filter
bronze refining
facilities
Iron and steel mills Basic oxygen furnace Particulates / Furnace hooded to high
energy scrubber or
precipitator
Sewage treatment plants Sludge incinerators Particulates / Venturi scrubber
Sources: Based on Table 1, in Gary D. McCutchen. New Source Performance Standards Present and
Future. Paper presented at the Fourth Annual Industrial Air Pollution Control Conference, Knoxville.
Tenn., March 28-29, 1974.
U.S. Environmental Protection Agency, Office of Air Programs. Background Information for Proposed
New Source Performance Standards: Steam Generators, Portland Cement Plants, Nitric Acid Plants,
Sulfuric Acid Plants, Technical Report APTD-07-1, Research Triangle Park, N.C., August 1971.
U.S. Environmental Protection Agency, Office of Air Programs. Background Information for Proposed
New Source Performance Standards: Asphalt Concrete Plants, Petroleum Refineries, Storage Vessels,
Secondary Lead Smelters and Refiners, Brass or Bronze Ingot Production Plants, Iron and Steel Plants,
Sewage Treatment Plants, Vol. 1, Main Text. Technical Report APTD-1352a, Research Triangle Park, N.C.,
June 1973.
Overall collec-
tion efficiency
required, %
98
70-90
65-90
95
99.3-99.7
93
96
98.5
99.7
99+
93
99.5
80
97+
98.7
99.8
99.6
Status of
performance
standard
Promulgated 12/71
"
ii
.i
"
"
"
Promulgated 3/8/74
"
11
"
..
.1
ii
n
"
-------
In addition, the owner/operator shall provide EPA, within 60 days after
achieving the maximum production rate but not later than 180 days after
initial startup, reports of performance tests conducted in the manner and
by the method prescribed in the NSPS regulations. A 10-day notice of the
proposed performance tests is required to permit EPA an opportunity to
observe such tests. In addition to the performance tests asso-
ciated with startup, EPA under section 114 of the Clean Air Act can
require such additional tests as are deemed necessary to ensure com-
pliance with the NSPS.
Under provisions of section lll(d) of the Clean Air Act, States may
develop and submit to EPA procedures for the implementation and enforce-
ment of NSPS for new sources located in the State (except hew sources
owned or operated by the United States). If a State's procedure is
found to be adequate, authority to implement and enforce NSPS can be
delegated to the State.
Upon the publication of NSPS, States may adopt regulations that are
equal to or more stringent as the NSPS. This revision to State regulations
is accomplished through existing procedures within the State. Unless the
States have been delegated procedures to implement and enforce NSPS, the
owner/operator is still required to comply with the Federal requirement and
submit reports to EPA, in addition to the requirements that may be
imposed by the States. This course of action by the States is con-
sidered less desirable than the development of an EPA-approvable pro-
cedure for implementation and enforcement of NSPS and subsequent dele-
gation of authority. The requirement for dual report submission may
constitute a hardship on the owner/operator and may result in differing
interpretation of regulations and test results.
Regardless of the methods by which NSPS are implemented, local
review and enforcement are accomplished through the mechanisms estab-
lished by the SIP. Requests for permission to construct a new source or
modify an existing one are processed through the same system as sources
not covered by NSPS. Surveillance and enforcement procedures are the
same whether or not the source is covered by NSPS. In essence, NSPS
simply supplant State regulatory requirements for selected sources
unless existing State emission limitations are more stringent than NSPS.
III-5
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b. Applicability. NSPS are applicable to any new stationary
source, the construction or modification of which is commenced after the
publication of the NSPS regulations. Promulgation of NSPS does not
abrogate the requirements for the review of new and modified sources as
required by 40 CFR 51.18. If the cognizant State or local agency
determines that the construction or modification will interfere with the
maintenance of a NAAQS, permit to construct or modify must be denied even
if the construction or modification plans provide for the emission control
required by NSPS.
Existing SIP requirements in some States may be more stringent than
those imposed by NSPS. In these cases, the more stringent State re-
quirements must be met by new and modified sources.
c. Interaction with Other Measures. Because NSPS are
applicable to construction or modification of specific sources, they are
implemented without specific interaction with other maintenance measures.
NSPS can, however, be used as the implementing mechanism for other
control measures. For example, NSPS may be used to phase out inef-
ficient domestic oil furnaces or unmonitored on-site incinerators by
specifying emission limitations on new and replacement units. NSPS may
also be used to implement the combination of emission source measures by
requiring emission controls on new and modified sources that can only be
met by consolidation of numerous small emitters into a larger source.
d. Potential Conflicts with Community Development Plans.
NSPS will not result in conflicts with community development plans.
NSPS are implemented after a decision has been made to construct a new
source or modify an existing source. It must be assumed that the AQMP
will contain provisions to ensure that such decisions are made within
the context of the community development plan. Thus, NSPS can be con-
sidered to be not only consistent with such plans, but also complement-
ary thereto. The application of NSPS to sources within an AQMA can
result in overall emission reductions that would permit the growth
envisioned in the community development plan.
e. Practical Limitations.
1) Social acceptability. No problems are envisioned
with the social acceptability of NSPS. Most States currently specify
more stringent controls for new and modified plants. This action has
III-6
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generally been accepted. NSPS merely extends more stringent standards
on new and modified plants to require the best available control tech-
nology. A public information program, especially for NSPS covering
ubiquitous sources, should contribute to acceptance by the public by
informing them of the need for and contribution that NSPS can make to
their welfare through a cleaner environment. Public information pro-
grams are not uniquely applicable to NSPS, but are revelant to all
maintenance measures.
2) Economic feasibility. Economic considerations play
an important role in the development of NSPS. In the detailed study
that precedes the promulgation of NSPS, control technologies are eval-
uated with respect to cost and effectiveness by analyses of field data
obtained from well-controlled plants. Cost-effectiveness analysis, an
integral part of the NSPS development, considers not only the direct costs
of control equipment, but also the benefits that may occur from higher
production efficiency and value of byproducts from the control system,
taking into consideration the cost of achieving such reduction.
4. Evaluation of Control Measure
NSPS impact on air quality by controlling emissions from new
and modified sources. New and modified sources are brought on stream to
replace obsolete facilities or to provide additional production capacity
to meet increased demands. The applicability of NSPS to construction
and modification is shown schematically in figure III-l. The additional
control potential of NSPS for all emissions, however, must consider
other factors such as the portion of growth requirements that can be
satisfied from present unused capacity and the obsolescence and re-
placement rates of existing facilities. Such a comparison can be
expressed mathematically. The following equations can be used to determine
the impact of NSPS on emission rates (ref. 3). The equation is not appli-
cable when E is lower than E^.
Emission reduction by _ ,,/,: r \ /R , r\
application of NSPS (tons) " Mts " V v '
where K = Normal fractional utilization of existing capacity, assumed
constant during time interval
ES = Allowable emissions under SIP, tons per unit capacity
III-7
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INDUSTRY PRODUCTIVE CAPACITY
00
o>
-a
a
o -n
REPLACEMENT OF OBSOLETE
FACILITIES
ADDITION OF PRODUCTIVE
CAPACITY
CAPACITY REGULATED BY NSPS
-------
E = Allowable emissions under NSPS, tons per unit capacity
B = Production capacity from construction or modification
to replace obsolete plants
C = Production capacity from construction or modification to
meet increased demands
where for compound growth, B = A[(l + Pb) - 1]
C = A[(l + Pj - 1]
where for simple growth, B = AiPb
C = AiPc
A = 1975 capacity
P. = Annual obsolescence rate
b
P = Annual growth rate
i = Elapsed time, years
For those sources not covered by NSPS, States have the option
of imposing more stringent controls on new and modified sources than are
currently prescribed in the SIP. In such a case, the methodology for
evaluating the effectiveness of NSPS as described above is applicable.
The term E is redefined as the allowable emissions in tons per unit ca-
pacity, under the more stringent SIP controls. In determining the
appropriate E , States must balance the economic impacts of prescribing
overly restrictive control with the current state-of-the-art of control
technology.
B. REVISION OF EXISTING SIP CONTROL MEASURES
1. Definition of Measure
An early step in the development of the AQMP is the determina-
tion of whether more stringent emission limitations on existing sources
would be adequate to maintain air quality. If more stringent emission
limitations alone would be sufficient, an AQMP is not required. Amendment
of pertinent existing State regulations and demonstration that the revised
control measures would result in the maintenance of air quality is suf-
ficient to satisfy the air quality maintenance requirements. Such
limitations would be all that would be required in the AQMP.
Should more stringent controls not be technically or economically
feasible and/or should such an analysis indicate that these measures would
not, by themselves, provide the control required to maintain NAAQS during
III-9
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the period 1975 through 1985, a more comprehensive AQMP would be required.
Revision of the existing SIP emission limitations then becomes one measure
among many that should be considered in the development of an appropriate
overall maintenance strategy. The extent to which such a measure could be
implemented would depend on the existing level of control and the types of
emission sources present in the area.
2. Historical Review of the Measure
a- Current Application. This measure has been applied in
numerous States, in the development and revision of SIP control strat-
egies or by EPA promulgation of standards for those AQCR's for which the
SIP, as submitted by the State, was inadequate for the attainment and
maintenance of NAAQS.
b. Effectiveness of the Measure in Current Applications.
Evaluation of the effectiveness of this measure in current applications
will have to wait until 1975 or 1977, the target dates for attainment of
NAAQS. However, some estimate of further reduction in emissions can be
obtained by examining the degree of control required to meet current
emission regulations. For example, if control efficiencies in the range of 90-
95 percent are currently required to achieve standards for suspended
particulates, additional reduction of emissions could be achieved by requiring
controls in the range of 96-98 percent. If required controls are already
very stringent, for example, in the 96-99 percent range., then further re-
duction may be more difficult and expensive to achieve.
3. Implementation
a. Procedure. Procedures for revising SIP control require-
ments are described in the various SIP's. Under the assumption that
emission reductions are not needed immediately to maintain standards, it
may be appropriate to provide a period of 5 to 10 years for sources in
compliance with existing regulations to come into compliance with the
new, stricter regulations.
b. Conditions of Applicability. This maintenance measure is
applicable to 1) sources currently under control but for which additional
control is feasible, and 2) sources currently uncontrolled.
c. Interactions With Other Control Measures. Because this
measure is applied to selected sources, it is implemented and enforced
without specific interaction with other maintenance measures. For sta-
111-10
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tionary sources, the emission controls specified by this measure are
superseded for new and modified sources upon the promulgation of NSPS
requiring more stringent control and, conversely, supersede NSPS control
requirements that are less stringent.
d. Potential Conflicts With Community Development Plans.
The imposition of more stringent SIP controls has the potential of
conflicting with community development plans. For example, the impo-
sition of more stringent SIP controls could curtail growth or even drive an
industry out of an area, while community development objectives may
include the encouragement of growth in the same industry.
e. Practical Limitations.
1) Social acceptability. The imposition of more stringent
controls on sources currently under control will probably meet
considerable opposition. Sources that have instituted control programs
or have either installed or contracted for the installation of control
equipment will most likely object to being given a "moving target"
insofar as control requirements are concerned. Furthermore, industry
can be expected to object to being required to spend funds for additional
control when the expected reductions in emissions are to accommodate
projected growth, especially if the growth represents competition.
Because the social acceptability of this measure is relatively low,
its inclusion in the maintenance strategy should be carefully considered.
The imposition of controls on all new or modified that are more
stringent than controls on existing sources can, however, be more
easily achieved.
2) Economic feasibility. Economic feasibility of this
control measure can be determined by an analysis of the impact on classes
of sources. In general, the cost per unit reduction of emissions will be
higher than the cost under the existing control requirements. However,
these added costs do provide large percentage reductions in the remaining
emissions since only a small increase in control efficiency, e.g., 98 to
99 percent, will cut remaining emissions drastically, (increasing from
98 to 99 percent represents a 50 percent reduction in emissions).
4. Evaluation of Control Measure
Potential emission reductions from this control measure can be
III-ll
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evaluated by the following formula:
Potential reduction = (E - E )C
where E = Emission allowances under the existing control
requirements
E^ = Emission allowances under the more stringent
requirements
C = Source capacity affected by more stringent require-
ments during the time frame under consideration
These data should be readily available in the air pollution control
agency having jurisdiction over the area in which the sources are
located.
C. PHASEOUT OR PROHIBITION OF EMISSION SOURCES
1. Definition of Control Measure
Phaseout of emission sources is a measure whereby certain
emission sources are eliminated by prohibiting their incorporation into
new construction or by prohibiting operation of existing sources.
Those sources already in use are not affected until obsolescence requires
replacement or the prohibition date arrives, at which time they become
subject to the provisions of this measure. Phaseout of existing
emission sources can occur as the result of a business decision, as a
result of mandatory prohibition by a specified date, or as a result of
the imposition of stringent performance specifications on emission sources,
Outright prohibition of pollution sources is exemplified by rules
57 and 58 of the Los Angeles County Pollution Control District banning
open firing of refuse and the use of single chamber incinerators.
To be successful, acceptable alternative equipment or services
must be available for whatever is to be phased out. It is desirable
that these alternatives be cost competitive in addition to offering
reduced pollutant emissions.
Two desirable applications of this control measure are the phaseout
of inefficient types of domestic oil-fired furnaces and the elimination
of on-site incinerators. In an AQMA where greater emission reductions
111-12
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are needed to accommodate expected growth, an extreme application would
be the prohibition of new coal- or oil-fired space heating units in a
specified area where maintenance action is required.
2. Historical Review of the Measure
a. Current Application. Regulations to prohibit or phase out
specific types of sources of air contaminant emissions have been adopted
by some air pollution control agencies. Most States have, in one form or
another, prohibitions against open burning. Examples of such regulations
are presented in table III-2.
The Federal Motor Vehicle Control Program is a recent example wherein
specific emission control performance is required on new automobiles to
control emissions from mobile sources. As the nationwide vehicle fleet
ages, older vehicles become obsolete and are replaced by new vehicles
incorporating the emission control equipment.
b. Effectiveness of the Measure in Current Applications. The
effectiveness of this measure toward the maintenance of air quality is
dependent upon the number of sources that will be eliminated and the
spatial distribution of such sources. For a specific AQMA the effec-
tiveness can be determined by adjusting the emissions inventory and sub-
sequent dispersion model.
3. Implementation
a. Procedure. The phaseout control measure is a
measure implemented by law but differing from immediate prohibition of
equipment or technology by allowing a reasonable time lag between en-
actment and complete prohibition. This time lag is normally incorpo-
rated into the measure by restrictions to new products, thereby using
the mean life of the existing product as a transition period. Alter-
natively, the measure could specify a transition period, in which both
new and old equipments are satisfactory, to terminate at a given date
after which only the preferred product is legal.
Specifically for oil-fired furnaces, particulate and NO emission
/\
reduction can be achieved by improved burner design, turbulence control,
staged injection of fuel, tangential firing, etc. If adequate per-
formance standards are imposed on new units with prototype testing
before they are approved for sale, manufacturers can apply known tech-
nology and develop additional design techniques to achieve much better
performance than presently observed.
111-13
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Table III-2. Examples of regulations adopted to prohibit or phase out specific sources of emissions
State
Arizona
Connecticut
Maryland
Massachusetts
Minnesota
New Jersey
New York
Regulations
Tucson Regulation Governing Street
Improvement; August 22, 1972
19-13-615
43P05 Sec. 0603
0605
0605
Boston Reg. 4.3.1
4.3.1
5.1
6.3.1
6.3.2
6.4
APC 7
Chapter 11, 2.1
Chapter 2, 2.1
New York City 1403.2-4.03
1403.2-11.05
General Content
All new roads must be paved
Single chamber incinerators, new flue-fed
incinerators prohibited
Prohibits on-site incinerators, with few
exceptions
New post-January 1971 installations using
residual fuel oil in boilers of <5 x 106 BTU/hr
capacity prohibited
New post-January 1971 installations using
solid fuel in boilers of <250 x 10b BTU/hr
capacity prohibited
Number 5 fuel oil prohibited in all fuel burning
equipment of <4.5 x 106 BTU/hr capacity
Number 6 fuel oil and bituminous coal prohibited
in fuel burning equipment of <9 x 10° BTU/hr
capacity
Application of asbestos fiber to any structure
prohibited
Dry sandblasting prohibited
Wet sandblasting prohibited, except with
written permission
Spray-coating with minerals prohibited, except
with written permission
Multiple chamber incinerators only can be used to
burn refuse
Single chamber flue-fed incinerators prohibited
Open burning for salvage operations prohibited
Installation of new refuse burning equipment
except municipal and pathological prohibited
Use of fuel burning equipment using
bituminous coal without control apparatus
prohibited (99.5% particulate control
required)
-------
b. Conditions of Applicability. Phaseout measures are
appropriate for forcing shifts toward desired technology or
equipment when more direct or drastic action is impractical. These
conditions frequently exist when large amounts of capital investment are
involved or when the equipment is pervasive throughout society so that
changes can only be made gradually without causing unacceptable dis-
ruption or hardship.
When tied to the standard replacement cycle, the added loss in
capital caused by phaseout is zero; all capital is fully amortized. The
replacement equipment, however, may be more expensive.
Phaseout is only appropriate when an equivalent, less polluting
alternative technique exists for carrying out a particular function or
service in society. It offers a minimum cost transition procedure with
little disruption of normal operations. It is most appropriate for
maintaining already achieved air quality standards in that major,
drastic steps would not normally be required.
The two example applications of phaseout fulfill these criteria.
Emissions from domestic oil burners of inefficient design are excessive;
many modern designs have much lower emission rates, but are not any more
expensive than alternative new heating units. The effectiveness of the
measure also depends on the deterioration rate of the replacement. A
low maintenance oil burner should be designed and built for perhaps a 15-
year operation within specified performance limits. EPA is presently
funding development projects for such equipment. The replacement equipment
does not have to be specified in the regulation, and probably should not
be unless it is mandatory that a particular replacement technology be
employed. However, unless proven alternatives do exist, any phaseout
regulation will probably encounter considerable opposition.
Similar comments are valid for the phaseout of on-site inciner-
ators. They can be eliminated from new construction by law. Their
function can be handled by conventional community garbage/trash collec-
tion and disposal services, possibly including use of refuse compactors
in some buildings.
111-15
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c. Potential Conflicts. Agreement as to when phaseout of a
specific source is desirable will not be universal. The optimum tech-
nology may not be as debatable as the evaluation of the desirability or
need to take steps to switch to it. The economic value of any given
phaseout is difficult to quantify when key benefits center around
improved air quality.
The most important negative environmental impact is the time lag
inherent in this control measure. Phaseout does not have immediate
impact on the maintenance of air quality. Rather, it is a long-range
control measure that with proper planning yields long-term benefits in
air quality.
d. Practical Limitations
1) Social acceptability. Well-conceived timed replace-
ment programs have always been well received by the public, who readily
perceive these actions as progress. Public hearings on proposed phase-
outs and careful presentation of the impact on air quality will continue
to be requisite for public acceptance and the enactment of appropriate
regulations.
The current petroleum shortage makes phaseout of oil burners socially
acceptable. Reserving fuel oil for uses other than space heating would
be accepted by society today as a desirable long-term goal from an energy
allocation viewpoint. Obviously, an alternate source of heat must be pro-
vided for, such as natural gas, electricity, or gas made from coal.
2) Economic feasibility. A major attraction of this
measure is that it makes otherwise uneconomic modifications and tran-
sitions economically feasible. One simply does not scrap all automobiles
without emission controls. By phasing out such vehicles, the same result
is eventually accomplished. The phaseout now underway in the automobile
industry causes no disruption to the consumer. Similarly with oil
burners and on-site incinerators, a timely phaseout will be economically
acceptable and will prevent more drastic measures from being needed later.
4. Evaluation of Control Measure Effectiveness
a. Ability of Measure to Maintain Standards. The impacts of
phaseout and prohibition are dependent on the percentage contribution of
emissions from the affected source category and the emission rate of the
equipment that replaces the obsolete or prohibited equipment. For
111-16
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example, a source category that contributes 5 percent of emissions may
be totally eliminated by phaseout of equipment over a 10-year period and
replaced by other sources that contribute only 1 percent of base-year
emissions. In this case, the measure would cause a 4 percent reduction
in total emissions. Generally, these will be area source categories, so
their impact on air quality may be even greater than their relative
contribution to total emissions in a problem area.
Due to the attrition period normally associated with this mea-
sure, its full effect would be spaced over the phaseout period. This
long-term, continuing emission reduction is consistent with the intent
and needs of maintenance measures.
b. Relative Efficiency When Compared to Other Measures. If
the measure is capable of providing a significant part, or all of, the
necessary emission reductions to offset projected growth according to
emission inventory calculations, it should certainly be considered in
the evaluation process. Identification of candidate source categories
for phaseout or prohibition should be on a local basis.
D. FUEL CONVERSION
1. Definition of Measure
The discussion in this section is limited to processes whereby
one fuel is converted to another form that has a lower pollutant emis-
sion rate per Btu. Fuel switching by individual sources, the ultimate
result on a regional level of increased availability of cleaner fuels
from fuel conversion processes, is described in Ch. Ill Section E,
Energy Conservation and Utilization. Processes in which fuels are
converted directly to thermal, electrical, or kinetic energy are not
considered here. Some of the conversion processes currently of in-
terestmost of which involve coal conversionare:
Coal gasification
Coal liquefaction
Coal desulfurization
Oil desulfurization
Additional processes may become prominent within the initial 10-year air
quality maintenance planning period or thereafter.
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Most of the fuel conversion plants to be built in the United States
will probably be located outside AQMA's. Therefore, the fuel conversion
process itself is not really an air quality maintenance measure within
the jurisdiction of the AQMA, although the maintenance area will benefit
by using the converted fuel. In effect, a remote fuel conversion process
will enable an AQMA to benefit from fuel substitution measures.
It is likely that the coal and oil companies will be the owners of
most fuel conversion plants that may be built, but present coal con-
sumers such as electric utilities may build the plants to ensure a clean
fuel supply for themselves. It is also possible that some other sector
of private industry will invest in such plants.
For power plants, fuel conversion serves mainly as an alternative
to flue gas desulfurization. It was recently reported (ref. 4) that
about 30 percent of projected coal-fired generating capacity will need
flue gas desulfurization systems by 1980 to meet emission standards.
Since coal conversion plants will probably not be available commercially
on a significant scale before 1985, timing requirements alone will
probably dictate much more widespread use of flue gas desulfurization
techniques than fuel conversion.
2. Historical Review of the Measure
a. Current Application. At the present time, fuel con-
version processes are being employed commercially to a limited extent,
especially in Europe. Some of the approaches that are presently being
considered and the status of development for each approach are discussed
briefly below.
1) Coal gasification. Two modes are under consider-
ation at the present time; low Btu gas for utility use and high Btu gas
to supplement natural gas for pipeline use.
Commercial coal gasification processes such as the Lurgi and
Koppers processes for the production of low Btu gas are available, but
no such plant has been constructed in this country to produce gas for
electric utility use. Because of the loss of sensible heat necessary
for gas cleaning, overall thermal efficiency for a single-cycle plant is
20 to 25 percent lower than for a conventional coal-fired plant. How-
ever, if the thermal content of the gas is recovered and if a combination
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cycle utilizing a steam turbine and a gas turbine is employed, it may be
possible to obtain 20 to 50 percent more electric power from a ton of
coal than in a conventional coal-fired power plant. At the present
time, certain technological problems remain. High temperature gas
cleaning methods and reliable high temperature gas turbines must be
further developed (ref. 5). In addition, lead times on the order of 5
years are required to design and construct a gasification plant after a
large supply of coal is committed for use. The effects of such a plant
could not begin to be realized within an AQMA until the early 1980's
even if coal gasification commitments were made immediately. It is
estimated that gas costs would be on the order of $1.00 to $1.80 per million
Btu's (ref. 5). This relatively high cost seems to make the process
unattractive; however, costs of other competitive fuels are also rising
rapidly.
High Btu gas production to supplement pipeline nature gas can
affect air quality maintenance in an AQMA only insofar as the gas supply
in the area could not otherwise be sustained or increased. It does not
appear likely that such gas will be available in sufficient quantity to
permit switching from other fuels until after 1985. At best, the
substitute gas may prevent additional industrial switching to dirtier
fuels. Present estimated high Btu gas costs range from $1.00 to $2.00
per million Btu's. El Paso Natural Gas Co. has a $270 million plant
under construction in New Mexico, due for completion in 1976, so the
process may be considered to be commercially available.
2) Coal liquefaction. Processes are now on a pilot or
laboratory scale only. It is not expected that technology will be
available for commercial use before 1980 and will not make a significant
impact on the availability of clean fuel until after 1985.
3) Coal desulfurization. Coal cleaning methods are
available and are widely used to reduce the sulfur content of coal.
Potential results vary considerably with coal characteristics. For
example, a coal washability study by EPA (ref. 6) indicated that a group
of coals ranging between 0.6 and 4.4 percent sulfur could be cleaned to
obtain sulfur reductions between 4.5 and 68.1 percent. Btu yields
ranged from 91.3 to 99.6 percent of that for the unwashed coal.
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About 3 percent of the heat content of the coal would be lost in the
washing process. Coal cleaning costs, not including value of cost lost
in washing, were between $1.00 and $2.00 per ton. In general, it is not
feasible to clean coal having less than 1 percent sulfur. Cleaning also
reduces fly ash emissions for a given furnace and electrostatic precipitator.
Deep cleaning methods for coal are now in the pilot plant stage of
development. One process produces solvent-refined coal either in
liquid or solid form. It is estimated that the process can yield low
sulfur fuel at a cost of 81tf per million Btu (ref. 5). Commercial
technology is expected to be available sometime after 1980.
b. Effect of the Measure in Current Applications. Since the
various fuel conversion techniques are generally not in commercial use,
the effectiveness of the techniques cannot be determined. The potential
effectiveness of fuel conversion on AQMA air quality is discussed later
in this section.
3. Implementation
a. Procedure. Fuel conversion measures generally cannot be
implemented on a local level by.a control agency. Stringent regulatory
requirements on allowable fuel characteristics or emission rates may
lead indirectly to the practice, but it still must be justifiable
economically in comparison with the use of acceptable natural fuels or
emission control systems before it would be undertaken. Thus, an AQMA
may be able to take credit for the increased availability of cleaner
fuels resulting from a fuel conversion facility, but those responsible
for air quality maintenance cannot influence that availability signif-
icantly without major subsidization.
b. Conditions of Applicability. This measure has its maximum
potential in areas where the consumption of coal and heavy fuel oils is
high, and where fuel combustion emissions from area sources are signifi-
cant. However, since the measure will not be available for several years,
applicability is also limited to areas where the control measure is not
needed in the near future.
c. Interaction With Other Measures. The effect of this
measure in relation to other maintenance measures is to provide a larger
supply of clean-burning fuels to an AQMA at prices competitive with
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existing supplies. Therefore, negative interactions are not expected.
Some administrative measures, such as emission density zoning, may be
assisted by the availability of synthetic clean fuels from fuel conversion.
d. Potential Conflicts With Community Development Plans.
Fuel conversion would act to supplement clean fuel supplies, so it is
not expected to conflict with community development plans. This measure
would be implemented by the companies and utilities who must plan for
and provide the fuels, so their operations would not be adversely
affected.
e. Practical Limitations.
1) Social acceptability. Overall public reaction is
expected to be favorable since these processes provide a new supply of
fuels that are presently being rapidly depleted. Negative aspects would
probably be relative to the locations of the conversion facilities,
which in this discussion are assumed to be outside the AQMA.
2) Economic feasibility. Cost estimates show that
these processes are not currently economically competitive with naturally
occurring gaseous fuels. However, increasing fuel prices will alter the
situation in the future, especially as natural gas and oil prices increase.
4. Evaluation of Control Measure Effectiveness
a. Ability to Maintain Standards. This measure has a low
potential for maintaining standards for two reasons:
The planning and control agencies have no power to require
fuel conversion, nor to specify the amount or type of clean fuels to be
produced; also,
If a supply of converted fuel is made available in a metro-
politan area, mechanisms may not be readily available to allocate this
cleaner fuel to areas within an AQMA where it would be of most benefit
for air quality maintenance. This is because the distributor, presumably
the natural gas utility in this case, has established procedures and
criteria for accepting new customers and installations. The addition
of customer location to the list of criteria would require active partici-
pation of the utility in the maintenance effort and approval of the
appropriate State regulatory commission. Even if these two requirements
were fulfilled, the allocation scheme still may be subject to challenge
by rejected applicants.
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Coal cleaning will probably find only limited additional appli-
cations because washed coals are not capable of meeting S02 emission
regulations in many jurisdictions. For example, Ohio regulations re-
quire emission rates of 1.0 to 3.2 lb/106 Btu of S02 after 1978 for
combustion sources greater than one million Btu/hour input, limits
generally unattainable with just coal washing.
b. Relative Efficiency of the Measure. Based on the non-
availability of fuel conversion processes on a significant scale within
the initial 10-year planning period, fuel conversion cannot be relied upon
to provide clean fuel in this time frame. The longer term applications
of these processes are, however, almost unlimited, especially in view of
the recent increased emphasis on fuels research.
Fuel conversion, as industrial process, may have direct
impact on air quality within an AQMA. Economics normally dictates that
the conversion process take place at the source of coal, oil shale, or
other new material. The buildup associated with the plant and the
plan itself may generate emissions that could threaten NAAQS in areas
where present air quality is much better than secondary standards.
Many of these remote areas have been AQMA proposed as Natural Resource
Development Areas in the AQMA designation process.
E. ENERGY CONSERVATION AND UTILIZATION
1. Definition of Control Measure
Optimum use of fuel and energy resources to reduce air pollution
emissions encompasses both energy conservation and the redistribution of
currently available fuels to combustion sources. Conservation measures
are aimed at the reduction of energy demands through more efficient use
of energy, as for example, better insulation of buildings to reduce
thermal losses. A reduction in energy requirements will decrease the
quantity of fuels used by combustion sources, thereby reducing the
emissions of pollutants to the atmosphere. A fuels redistribution
policy is not intended to reduce the total quantity of fuel used by
combustion sources, but rather to reduce the pollutant emissions directly
through the use of emission control devices. This can be accomplished
through the use of incentives whereby those combustion sources for which
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control devices are readily available are encouraged to use so-called
dirty fuels. Clean fuels are directed to those sources for which control
devices are either not available or are economically impractical.
Specific measures which may be considered in the development of an
overall energy utilization measure are listed below. This list should
not be considered to be exhaustive, as additional measures may be
appropriate for a specific AQMA.
Energy Conservation Measures
Revision of building codes to reduce thermal loss
Reduction of heating and cooling requirements
Greater use of multiple family structures
Energy conservation in industrial processes
Revised scheduling of industrial activities
Vehicle use restraints
Fuel consumption restrictions on new vehicles
Fuels Redistribution Measures
Incentives to change fuel type
Prohibition of specific fuels
2. Historical Review
a. Current Applications. Energy utilization measures have
had only minor consideration in the development of strategies for achieving
and maintaining air quality standards. Prior to the energy
crisis, the proposed method of meeting emission regulations for many
large combustion sources was a switch to low sulfur fuel oil or natural
gas. Many control agencies even adopted regulations prohibiting the use
of fuels with sulfur content in excess of specified values. For ex-
ample, the District of Columbia Air Quality Control Regulation Section
8, par. 2-704 prohibits the burning of fuel oil having greater than one
percent sulfur by weight. After July 1, 1975, the D. C. regulation will
reduce the allowable sulfur content in fuel oil to 0.5 percent. Because
of the energy crisis, there is some doubt as to the feasibility of
enforcing this regulation upon users of large quantities of fuel.
Energy conservation measures have come into sharp focus as the full
impact of the energy crisis has been realized. In this context, con-
servation has meaning as a means of satisfying energy requirements in
the face of reduced fuel supplies. The Nation has been asked to reduce
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its fuel usage through lower indoor temperatures during the heating
season and higher temperatures during the summer months when air con-
ditioners are being used. Additionally, the public has been requested
to reduce the consumption of electricity, especially for ornamental
lighting. The higher costs of energy are forcing industrial users to
search for production methods with lower energy requirements and to
evaluate the economics of reclaiming energy presently being wasted.
Finally, by law, drivers of motor vehicles have been required to reduce
driving speeds as a means of conserving fuel.
Prior to the energy crisis, a proposal to practice energy con-
servation as a means of maintaining air quality standards would have
been viewed with disfavor by the public. As a result of recent sen-
sitivity, the public reaction to conservation should be much more
favorable. It is now apparent that the quality of life need not be
adversely affected when energy demands are lowered.
b. Effectiveness of the Measure. Because energy utilization
measures have not been adopted by control agencies, there is little
information upon which effectiveness can be evaluated. There is some
limited information available regarding the effectiveness of some of the
individual measures previously identified (refs. 7-10).
* Revision of building codes to reduce thermal loss. At the
present time some electric utilities provide rate incentives for elec-
trically heated homes that comply with recommended thermal insulation
requirements. The National Conference of States on Building Codes and
Standards has recently drafted a model code emphasizing construction
that results in reduced energy consumption throughout the life of the
building. At least one prototype office building has been constructed
to demonstrate a 20 percent reduction in energy consumption in com-
parison with typical modern buildings.
Reduction of heating and cooling requirements. Information
made available by the Federal Energy Office indicates a 3 to 6 percent
savings in heating fuel requirements for each one degree of reduction in
indoor temperature during the winter months. Similarly, a one degree
increase in temperature during the summer months will result in approxi-
mately a 4 percent savings of electricity for air conditioning.
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The inclusion of energy conservation measures, such as insulation and storm
windows, as mandatory measures in building walls would result in a
reduction of energy required heating and cooling. These measures could
be made applicable to existing structures by requiring their application
during major modification of the structure.
Greater use of multiple family structures. The goal of many
Americans has always been to own their own individual home. From a
standpoint of energy conservation, this type of construction is least
efficient due to the thermal loss from all four walls, the floor and
roof. The use of housing structures with common walls reduces energy
requirements by approximately 5 percent for dwellings with a single
common wall and up to 40 percent for comparable-sized housing units in
large apartment buildings. The enactment of a preferred personal
property tax for multiple family structures is one incentive for greater
use of this mode of housing.
Energy conservation in industrial processes. Many energy
conservation and recovery techniques for industry are described in the
following section, "Combination of Emission Sources," as applications of
total energy systems.
Revised scheduling of industrial activities. Electrical power
generating facilities are designed to meet the demand for electricity as
it occurs. In many areas, there are generating plants used for base
load and others used for peak loads. In some instances, the peak load
plants are older units that have been consigned to such duty because of
their higher pollutant emission characteristics. Peak load plants are
often in the core area while baseload plants are in isolated areas. It
may be possible to reduce some of the peak load requirement by scheduling
industrial operations with large electrical demands at off peak hours,
thereby reducing emissions in urban areas. The net effect upon air
quality resulting from such actions must be determined on a case-by-case
basis.
Vehicle use restraints. The net reduction in vehicular emis-
sions resulting from various use restraints are discussed in chapter II,
section E,"Transportation Controls."
Fuel consumption restrictions on new vehicles. Minimum gasoline
mileage requirements for new motor vehicles on cursory examination appear
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to provide an additional reduction in average vehicle emission rates
beyond the FMVCP, due to the combustion of less gasoline per mile of
travel. However, the Federal certification test results for the 1974
model year vehicles, published in 39 CFR 7663, indicate that vehicles
that are more efficient in gasoline usage do not produce significantly
lower emissions of hydrocarbons, carbon monoxide, or oxides of nitrogen
than vehicles with high gasoline consumption rates. Therefore, it is
doubtful whether this particular energy conservation program will have
corresponding emissions reductions.
Incentives to change fuel types. Conceptually, it should be
possible to provide an incentive of some type to encourage some fuel
combustion sources to change fuels. Ideally, the plan would be to burn
dirty fuels in large sources for which control hardware is feasible.
This, in turn, would allow the smaller and more numerous sources to burn
clean fuels. The incentive, in the form of a tax break, would then help
to offset the added cost of control hardware. Because of contractual
arrangements with fuel suppliers and the tremendous costs that would be
entailed in establishing meaningful incentives, in many cases it is not
advisable for State and local pollution control agencies to become involved
with this problem. The application of stringent emission limitations on
small sources could provide an incentive for use of clean fuel by making
it less costly than the installation of emission control equipment.
Conversely, the selective application of a tax on clean fuel used in large
units would provide an incentive for the use of emission controls, thereby
releasing the cleaner fuel for use elsewhere.
Prohibition of specific fuels. The prohibition of specific
fuels is now a part of some control agency regulations. The effective-
ness of such regulations must be evaluated on a case-by-case basis.
Dispersion modeling and rollback methods can be used to determine air
quality resulting from changing emissions of point and area sources.
3. Implementation
In this period of rising fuel costs, which will certainly persist
into the foreseeable future, the control agency can expect great assistance
from the populace for an energy utilization policy. In the short run,
energy conservation through reduced heating and cooling demands can be
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nurtured by an active public relations campaign. A program designed to
keep the public aware of the savings in fuel cost by the proper control
of indoor temperatures should suffice. Compulsory energy conservation
programs for air quality maintenance have not yet been proposed.
The implementation of energy utilization measures beyond that described in
the preceding paragraph requires the air pollution control agency to
depend heavily upon other governmental and official planning agencies.
Revision of building codes obviously requires an effort upon the Build-
ing Inspection group to modify existing codes. A move toward the con-
struction of multiple family structures with common walls requires
cooperation with community planners, builders' associations, and real
estate brokers associations. To effect revisions of industrial activ-
ities requires the support of Trade Associations, Chamber of Commerce,
Electric Utility Companies, and the affected industries.
a. Conditions of Applicability. Energy utilization measures
should be directly applicable to any AQMA. Certainly, the driving force,
especially relative to conservation, will be from the users of energy
who are being required to pay continually increasing costs for energy.
b. Interactions with Other Measures. This measure does not
have a significant interaction with most other maintenance measures.
The one exception being that the concept of greater use of multiple-
family units must be incorporated into community development plans.
c. Potential Conflicts with Community Development Plans.
Energy utilization measures are not clearly in the domain of a single
regulatory agency. It is not clear that such measures will be regulated
by a single authority in the future. On the assumption that energy
utilization measures will be controlled by more than one jurisdictional
body, it is inevitable that conflicting aims of these bodies will create
regulatory difficulties. On a national level, it is obvious that the
aims of the Environmental Protection Agency, the Federal Energy Office,
the Department of Agriculture, the Labor Department, and other departments
have interests that would affect energy utilization policies in dif-
ferent ways. On a regional level, diverse counterpart agencies will
also have particular self-serving interests that may not be entirely
compatible.
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d. Practical Limitations.
1) Social Acceptability. A commitment to energy conservation
efforts will probably be received well by the general public. Such a policy
will tend to hold costs down and will impose no particular burden on the
general public as long as the policy does not result in a deterioration
of the quality of life.
Voluntary commitments to energy conservation by the public will
probably also be received well, as long as the commitments do not
significantly affect the living conditions to which an individual is
accustomed. The least acceptable strategies will probably be those that
commit the public to an austerity measure on a regulatory basis, but
such strategies will likely be the ones that yield the greatest benefit.
2) Economic Feasibility. These activities must be evaluated
on a case-by-case basis. Some approaches may be adopted voluntarily
because the approaches are feasible. Others may be nearly impossible to
implement because they are inherently uneconomic, and because the
environmental returns cannot be predicted with sufficient reliability to
justify economic investment that might be necessary.
4. Evaluation of Control Measure Effectiveness
a. Ability of Measure to Maintain Standards. The activities
that may be viable in this measure will each probably have small capa-
bilities in themselves. It is, therefore, doubtful that the measure can
generally be used by itself to maintain standards. In most successful
applications, several measures will have to be used collectively.
The ability of enery conservation measures to reduce emissions is
dependent on the specific nature of the measure. However, the following
general model can be used to estimate the emission potential of energy
utilization measures.
For Fuel Redistribution Measures
Potential Emission Reduction = [E - E.][Btu]
a D
Where:
Efl = Controlled emission rate per 10 Btu heat input
under existing conditions
Eb = Controlled emission rate per 10 Btu heat input
under changed conditions
Btu = Energy requirements (10 Btu) for the time frame
under consideration
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For Energy Conservation Measures
Potential Emission Reduction = E[Btua - Btub]
Where
E = Controlled emission rate per 10 Btu
Btu = Energy requirements (10 Btu) under existing
a
conditions for time frame under consideration
Btu, = Energy requirements (10 Btu) under control
measure for the time frame under consideration
Data available within the State can serve as a source of infor-
mation for determining emission rates. Design specifications may also
provide such information. Should these sources not be adequate, emission
rates can be estimated using data in AP-42 and actual or expected ef-
ficiency of the control equipment.
For fuel redistribution measures, total energy requirements can be
obtained from NEDS, local fuel consumption records, or from the facility
itself. For energy conservation measures existing, total energy re-
quirements can be obtained from the sources listed above. Engineering
estimates can generate the energy requirements under the energy re-
distribution measures.
b. The various activities within this measure may be cost-
effective in terms of pollution control. The magnitude of the reduction
will be dependent on the contribution to the total emission inventory
by the source categories to which this measure is applied.
F. COMBINATION OF EMISSION SOURCES
1. Definition
The underlying assumption of the combination of emission sources
(CES) measure is that it may be beneficial from an air pollution view-
point to combine a large number of small uncontrolled emission sources
into one large, well-regulated, and well-monitored emission source,
emitting from a taller stack. Such combinations not only result in
better emission control but also simplify enforcement as well. Com-
bination of emission sources may produce an economic advantage because
of the increased efficiency that usually results from economies of
scale. As a part of sound air quality management, however, it must
result in a net emissions reduction of pollutants into the atmosphere.
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Two applications of this measure are emphasized in this section:
a) district heating, and b) district incineration. These applications
are complementary in that the facility used to provide one service may
also provide the other; e.g., a district power plant can be built that
furnishes heat, hot water, and electricity to a neighborhood and at the
same time uses the solid waste of that neighborhood as part of the fuel
charge to generate these consumable energies. This combination of
emission sources involves dissimilar types of sources (power generation
emissions and solid waste disposal emissions). A more conventional com-
bination of sources involves the replacement of a large number of
similar sources by a single source of the same generic type. This plan
is less attractive when applied to home heating, as will become evident.
It is not until the properties of a total energy power plant combination
are considered that the air pollution advantages of this measure become
compelling.
As might be expected, the optimum strategy often depends upon
independent assumptions. For example, if natural gas is assumed to be
readily available to meet the requirements for most urban residential/
commercial growth, the concept of district heating is not nearly as
attractive as if coal must play a significant role. A brief discussion
of existing residential/commercial sources puts the problem in a re-
alistic perspective.
In 1970, stationary combustion accounted for significant fractions
of total particulates («*25 percent), sulfur oxides («80 percent), and
nitrogen oxides (~45 percent). Carbon monoxide (»0.06 percent) and
hydrocarbons H-6 percent) emissions from stationary combustion sources
were relatively insignificant as a fraction of nationwide totals (ref. n)
Reducing the carbon monoxide or total hydrocarbon output from station-
ary sources would have very small impact on total air quality.
Consequently, any strategy for reducing emissions from stationary
sources must pay off in improved air quality with respect to partic-
ulates, SCL or NO .
c. x
Particulate emissions from stationary sources are classified
according to fuel type (coal, oil, or gas) and source category (electric
utility, industrial, or residential/commercial). The CES measure
applies primarily to the residential/commercial source of emissions,
since electric utilities and industrial sources already consist of
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large, centralized power stations. Further combinations or central-
ization of these sources are not the objectives of this measure, al-
though such combinations may be economically very attractive as well as
beneficial to air quality. It is primarily the combination of various
fossil fuel combustion sources in the residential/commercial sector that
will be emphasized.
Particulate emissions from the residential/commercial sector con-
stitute about 8 percent of the nationwide particulate emissions. Of this
small fraction, coal contributes about 59 percent (oil, 29 percent; gas,
12 percent) but, at the same time, furnishes only about 3.5 percent of the
total energy needs of the residential/commercial sector (oil, 44 per-
cent; gas, 52.5 percent)(ref. 12). Clearly, coal is a dirty fuel and gas
is a clean fuel. Replacing all coal burners with natural gas would be a
most effective measure for reducing particulate emissions from sta-
tionary sources.
In 1970, the total energy generated by stationary sources was
approximately 3.45 x 10 Btu's. Coal accounted for only about a fourth
of this energy but about 93 percent of the particulate emissions. Re-
placing all coal combustion processes with natural gas combustion would
have reduced total particulate emissions in 1970 to about 617,000 tons,
or less than 10 percent of their actual value. If all stationary combustion
processes used only natural gas (replace both coal and oil with natural
gas), the total particulates emitted in 1970 by stationary sources would
have been about 334,000 tons or about 5 percent of what they actually
were. A more effective control measure is hard to imagine. But it is
also hard to imagine a measure less likely to be implemented.
Natural gas is growing less plentiful in comparison with the de-
mand. Gas suppliers are now declining to accept new customers in
certain parts of the country. Utilities are switching from either
natural gas or oil to coal. Fuel availability dictates such conver-
sions, but these switches may have an adverse effect on air quality,
unless accompanied by suitable process control.
Comparison of S09 and NO emissions from the three fuel sources
£ A
also shows coal to be the greatest polluter. It is not likely that air
quality would be improved by replacing domestic natural gas-fired
furnaces with centralized coal-burning power plants. Indeed, quite the
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reverse is true. Even with the best controlled combustion processes and
state-of-the-art effluent scrubbing, the total emissions would be in-
creased by such a change in equipment.
Switching from a large number of individual residential gas
furnaces to a single source of power, burning that same gas, does not
produce a significant change in SCL or particulates emitted, while the
NO would be increased by up to an order of magnitude because of the
A
higher temperatures employed in the larger combustion unit.
The same general conclusions apply to replacing individual oil
furnaces by either a central or coal-fired power station or a central
oil-fired station. Simply combining a large number of small, individual
residence space heaters into one large, centralized district furnace is
not necessarily an attractive measure based upon simple combustion/
pollutant considerations. This conclusion can be changed, however, if
the combination of sources is such as to improve the overall efficiency
of fuel utilization. This concept, called total energy utilization,
reduces air pollution by tetter utilizing the energy content of fuels so
that less total fuel has to be combusted. Consider the utilization of
waste heat during the generation of electirc power. Most power plants
generating electricity from fossil fuels do so at an efficiency of about
30 percenttypically 30 percent of the energy content of the combusted
fuels leaves the generating station as kilowatthours. One large source
of lost energy is waste heat discharged into the atmosphere or cooling
water. In the total energy concept, a significant portion of this waste
heat is used to heat the water and living spaces of the same community
that uses the electricity.
This total energy concept is the application of the measure that
appears most promising for the district heating/cooling of residential/
commercial areas and is the version of source combination recommended
here. Similar CES measures apply to many industrial situations but
these are too varied and specialized to be considered in any detail.
A conventional electric utility operates at an efficiency of up to
39.2 percent (this efficiency is the highest reported, being attributed
to Marshall Unit No. 3 of Duke Power Company, Marshall, N.C., ref. 10).
Nevertheless, when transmission losses are also included, the net energy
delivered to the customer corresponds to 36,400 Btu's equivalent elec-
trical energy for 100,000 Btu's of fuel consumed.
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In the total energy system, the power plant is located in the
neighborhood that utilizes its output and delivers both electricity and
steam, the latter being used for both space heating/cooling and hot
water heating. This double duty achieves an impressive gain in ef-
ficiency of fuel utilization as represented by the 77 percent efficiency
estimate. The waste heat from power generation, if fully utilized, is
even now more than sufficient to heat every home in America (ref. 14).
This maintenance measure achieves an impressive gain in efficiency
by moving the power plant into the neighborhood so that normally wasted
heat can be substituted for individual home space and water heating and
cooling. At the same time, air quality considerations dictate that the
fuel used to fire the neighborhood power plant have low emissions. The
reduction in air pollution comes about not because of greatly reduced
emitted pollutants per unit quantity of fossil fuel consumed but pri-
marily because of the reduced total fuel requirements of the neighborhood
which in turn corresponds to reduced total pollutants.
Another very desirable feature of a total energy power plant is
design of the combustion chamber so that it can accept at least part of
the solid waste of the community as part of its fuel charge.
2. Current Applications
The CES measure is becoming more popular because it conserves
energy, reduces costs, and reduces total emissions. Numerous illus-
trations of CES in practice now exist. They range in size and scope
from industrial applications involving one or two companies to large
area residential applications involving a large number of apartment
dwellings or even a whole city. Some examples of each are reviewed in
this section.
Perhaps the simplest implementation of the CES measure is the
relatively common industrial application in which an extraction turbine,
used to generate plant electricity, is also used to furnish low pressure
steam for in-plant use. High pressure steam is generated in a boiler
which drives the turbine. Low pressure steam is bled off or extracted
and circulated through the plant distribution system for use in indus-
trial processes or space heating.
This measure is widely used in industry and has evolved into coop-
erative ventures between separate companies such as a steam user and an
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electric utility. By locating the separately owned and operated steam
generating and steam-using facilities adjacent to each other, the waste
of one industry becomes an input to the other.
The economic benefits that occur from a total energy facility can
be illustrated by comparing the overall fuel use efficiency of such a
plant with that of a conventional steam-electrical plant. Standard Oil
of Kentucky operates a steam generating plant at Pascagoula, Miss.,
which in addition to providing electricity to the Mississippi power grid
also supplies steam to the refinery. Overall efficiency, in terms of
utilization of energy input, is 61.5 percent. This is compared with the
Gulfport plant of Mississippi Power Company which has an overall
efficiency of 27.6 percent operating in the conventional mode.
Many examples of similar utility-industry partnerships exist, but
many more industrial opportunities could be developed to take advantage
of this largely wasted energy source. Any industrial process using high
temperatures is a potential candidate for the CES measure.
A technique still being developed by the power generating industry
is the use of a combined gas turbine/steam turbine generator in which the
exhaust gas of the former serves as the primary or sole heat source for the
latter. Conventional steam generators use fossil fuel to generate steam
which in turn drives a turbine to generate electricity. In a gas tur-
bine, the expanding, burning fuel serves as the primary driving fluid
for the turbine (lilce a jet aircraft engine). The exhaust gases of the
gas turbine exit at very high temperatures and can be used to heat water
for steam. This two-stage combination Cboth the gas turbine and the
steam turbine generate electricity) operates at efficiencies exceeding
50 percent, a significant improvement over either one alone.
In most potential applications of waste heat, the temperature of
the exhaust fluid from a generator that is most useful in industrial or
even residential/commercial applications is not that which corresponds
to the most efficient power plant operation. Steam or hot water gen-
erally must be drawn off at a higher exhaust temperature than would be
chosen for highest generating efficiency alone.
Use of power plant heat in district heating of residential/com-
mercial living space is also currently operative. Consolidated Edison
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supplies Manhattan with a peak of about 3,000 MW of heat, a major
portion of which is obtained from extraction and back-pressure turbines.
Hospitals, university complexes, and military/government installations
have employed central/ district heating concepts for years.
The total energy concept to be described here as an optimal CES
measure is an updated version of centralized district heating for the
residential/commercial user. As the name implies, total energy plants
furnish all required energy to their customers. The prime justifica-
tion for such a scheme is still economic, but there are significant
secondary advantages, including reduced air pollution.
Union Electric Company in St. Louis now consumes 300 tons of solid
waste per day with which it generates 12.5 MW (ref. 15). This facility
has been in operation since May 1972. The process mixes residential
solid wastes with pulverized coal to generate electricity. The only
refuse processing is the removal of magnetic metals and the pulverizing
of the remainder in a hammermill. The milled refuse has a heat content
of roughly 5,000 Btu's/lb., about 40 percent that of good quality bitu-
minous coal.
The combination of solid waste fuel with a district heating/cooling
power plant should be in operation in Nashville, Tenn., in early 1974.
This project is designed to provide central heating and air conditioning
to 27 office buildings in downtown Nashville and has the capability to
service 16 more buildings should initial results warrant expansion.
Tokyo plans disposal facilities that will use garbage to provide
heat and hot water for homes near the incinerating facility. Paris now
operates steam-electric plants with an annual charge of 1,600,000 tons
of garbage. Both electricity and steam are thereby generated in in-
cinerators equipped with pollution controls.
On the industrial front, Goodyear Tire and Rubber has developed a
boiler that utilizes old tires for fuel.
The advantages of using solid waste as a direct fuel are that two
significant emission sources can be controlled in one facility, and refuse
is a low sulfur fuel. Solid waste disposal is a major source of air
pollution. By incinerating it in a we11-monitored power plant, its
emissions can be limited, and at the same time the total fresh fuel
requirements of the community can be reduced. The total energy version
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of CES is economically advantageous not only in fuel costs but also in
reducing the disposal costs of solid wastes. Transportation of solid
waste to distant disposal points is costly. Using it on-site or in the
neighborhood in which it is generated greatly reduces these moving costs
and reduces emissions that would result from the transportation of solid
waste to remote disposal areas.
3. Implementation
a. Procedure. The CES measure is primarily a feature to be
incorporated into new urban development. Since heat distribution re-
quires the installation of either buried or overhead high-pressure
plumbing as well as compatibility with fixtures in the individual resi-
dence, retrofitting existing neighborhoods is prohibitive. For new
construction, however, it is quite easy to incorporate the plumbing and
compatible fixtures into each residence or separate structure as it is being
built. The necessary outside plumbing can be installed along with conven-
tional water and sewer service. In certain areas the existence of a
district power plant may be planned as a future facility, but all new
construction could be required to incorporate the necessary tap-on lines
and compatible distributing equipment. For the time period prior to the
availability of central power, the space heating/cooling requirements
can be met by the conventional gas or electric equipment now used in
individual residences.
Coal-fired power generators should be restricted to remote sites.
Again, the waste heat should be used in conjunction with industrial
processes that are also located remotely. A very acceptable arrangement
would be to locate the coal-fired generator at the mouth of a coal mine
and utilize the byproduct heat as process energy for coal gasification--
the production of synthetic gas which can be piped to urban areas for
use in total energy power plants.
A guiding rule for the CES measure is that no future power gen-
erating equipment should be constructed without either utilizing its
"waste" heat or justifying its failure to do so.
b. Criteria for Applicability. The conditions under which
this measure are applicable can be very broad; it can apply to all new
residential/commercial development or it can be restricted to only
certain types of new construction. It is clearly well suited for
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densely populated urban areas being developed. It has been used in
Vasteras, Sweden, to supply the needs of 90 percent of the city's
120,000 people and has "blessed the town with 'Sweden's purest city
air'" (ref. 16). This particular installation is oil-fired and employs
high temperature hot water for transporting home heat. Return hot water
is 55° to 70°C, sufficiently warm to melt the ice and snow from the
center of the city's main streets. This system, operating in a cold
climate, produces cleaner air than the individual coal- and oil-heating
systems it replaces at a lower cost to the subscribers.
It is also applicable to urban developments in temperate or warm
climates, for the steam generated can be used to power absorption-type
cooling equipment, thereby providing centralized space heating/cooling
on a year-round basis.
Housing developments under the design of one builder can easily
adopt this measure. Smaller developments under multiple sponsorship can
be combined into one power plant district by municipal planners, much
like present city sewage and water services are planned.
The measure applies to industrial users who are already highly
motivated to reduce operating costs and at the same time already possess
the authority and technology to incorporate the CES measure into the
design of new facilities.
The CES measure can also be implemented in the design of individual
homes. The waste heat from the furnace flue could be used to preheat
the charging water for the hot water heater, or the exhaust from the
clothes dryer or dishwasher could be used to heat and humidify the home
during the winter, etc. This approach could serve as a secondary
strategy for rural or remotely located dwellings, which may be judged to
be too far away for direct heat transfer and inappropriate for all-
electric service. The common strain unifying all these examples is the
combination of emission sources by designing one piece of equipment to
do the job now performed by two or more. The desired result is less
total energy required and, hence, less emitted pollutants.
All CES measures have the common advantage of reducing total fuel
consumption. This end result, which is highly desirable with respect to
energy conservation, produces less net emissions of pollutants simply
because less fuel is burned.
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No specific numbers are yet available to show that a given density
of living space per unit area of land is necessary to justify a certain
size total energy power plant. Quite likely, some form of this strategy
applies to all new construction. New construction of all forms should
be reviewed with the CES measure in mind.
c. Interaction with Other Measures. The CES measure that
removes fossil fuel combustion from the individual residential unit and
replaces it with a community plant is either compatible or complementary
with most other strategies discussed in this planning document. CES
provides a well-controlled source of combustion for home heating with
minimum air pollution.
Typical interactions of the CES measure with other measures dis-
cussed in this guideline document are:
1) Transfer of emission source locations. A primary
example of this measure is the shifting of power plants from central
locations in the midst of populated urban areas to more remote sites sup-
porting few other emission sources. For purposes of using off-gases of
power plants as a source of steam for space heating or water heating,
transfer of emission source locations would be counter to many CES
applications unless it were feasible to locate industries that could use
the waste heat in the neighborhood of the power plant. However, such
location of a labor intensive industry could result in an increase of
emissions from the housing and service facilities that would be attracted
to the area.
2) Phaseout of specified sources. Two specific sources
that are candidates for phaseout are on-site refuse incinerators and
inefficient oil burners. The CES measure is compatible with both. Not
only would inefficient oil burners be replaced by an efficient heating
plant but all home heaters, inefficient or otherwise, that depend upon
fossil fuel combustion would be phased out. The replacement of many
small individual heating units by a single large capacity unit operated
and maintained by heating professionals is the heart of the CES measure.
Extending the function of the combustion chamber to serve as a
central refuse incinerator for the same area is a bonus, if and when
implemented. On-site incinerators would be replaced by a well-con-
trol led municipal-type incinerator. The CES measure can therefore act
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as a phaseout measure as well.
3) Stack height regulations. The CES measure facil-
itates implementation of a stack height regulation. The stack height,
plus a definition of the minimum acceptable effluent scrubbing and
monitoring, become part of the centralized power plant plan. Not only
will a large number of small furnace discharges be replaced by a single,
well-processed effluent but the height of the emission source can be
much greater than would be practical for the many small sources re-
placed.
4) Energy conservation and utilization. The CES
measure recommended here really is an energy conservation measure. CES
works primarily because it reduces total fuel needsconserves energy
by combining many separate energy conversion units into a single, more
capable and versatile unit that can do the jobs of all units replaced at
lower fuel cost.
d. Potential Conflicts with Other Community Development
Plans and Potential Negative Environmental Impacts. The CES measure
reinforces present trends toward urbanization of the population.
Adoption of the CES measure could make population dispersal more dif-
ficult and costly, although not prohibitively so. An effective CES
measure would influence growth patterns in addition to centralizing
population. Those areas most attractive for new building would be those
already incorporated into a master plan for total energy plant location.
Central power plants with tall stacks are difficult to make into
esthetically appealing structures. In a few cases, the tall stack can be
inside a tall building and thus not be unsightly. In high density areas,
where their justification is greatest, the real estate they would occupy
would be expensive. Present zoning ordinances may prohibit the building
of power plants in many areas where they would be needed to implement the
CES measure.
e. Practical Limitations
1) Social acceptability. Social acceptability of CES
is probably good, although some objection to "losing control" of a vital
home comfort feature such as heating might be voiced. This loss of
control is not real, fo/ individual control of unit or even room heat
could be maintained. The subscriber would buy heat from the central
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plant much like electricity or natural gas is metered into a home.
Eventually, subscribers would realize that there is considerable ad-
vantage in turning over all maintenance and operating responsibility to
the facility's engineering staff.
The overall impact of the CES measure upon the community's life-
style is minimal. CES favors closely grouped high rise multiunit
dwellings, a residential form that has been growing in popularity.
2) Economic feasibility. When implemented at the
community planning stage, the CES measure would almost always prove
economically advantageous. The costs of the services and utilities
received (space heating/cooling, hot water, electricity) invariably
prove to be less than if delivered by the conventional means. Indeed,
the major impetus for this type of plan in the past has been reduced
costs, and, more recently, energy conservation. Reduced air pollution
comes as a bonus.
While no record can be found of an economic or technological
failure of communities or residential units adopting a CES measure, all
these published accounts reflect careful planning under optimum cir-
cumstances. Often, these well-publicized projects have been publicly
funded as demonstration models, and the size of the community and its
location have been carefully selected as near ideal settings for suc-
cessful operation. Before compelling all new construction to follow
this measure, experience in less ideal or marginally suitable locations
should be considered.
Widely dispersed, rural settings are not appropriate customers for
processed energy other than electricity. The question then arises as
to the economic feasibility of supplying all remotely located consumers
with electricity for home heating/cool ing, hot water and cooking; that
is, should all homes outside the steam or hot water range of a cen-
tralized energy plant (that this range is not well defined compounds the
problem) be required to be totally electric homes? Should rural homes
just be declared beyond the scope of the CES measure and ignored?
A key piece of information for resolving these questions is the
economic feasibility of electric home heating. If electric heating were
as efficient and economical as direct steam heating, fewer problems would
exist. The CES measure could be implemented on a 100 percent basis for
111-40
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all new residential construction, urban or rural. Growth patterns would
have to be anticipated or controlled so that a market always existed for
the waste heat accompanying electric power generation, but the chief
decision would be to size the power plant and the range of its steam or
high temperature hot water lines. The technical/economic decision would
be simply one of determining the range at which energy is more eco-
nomically transmitted as steam than as electricity.
Electric home heating at present uses about twice as much fossil
fuel as do direct heating methods such as gas or oil furnaces in which
combustion takes place on site. The relatively low efficiency (30
percent) for converting Btu's of fuel into Btu's of electricity at a
typical utility power plant accounts for most of the higher fuel re-
quirements. Consequently, energy conservationists criticize the growth
of total electric homes on this basis. If, however, much of the waste
heat used in generating electricity can be recovered in a useful in-
dustrial, commercial, or residential application, the penalty for
electric heating is greatly reduced or eliminated. In addition, electri-
cally heated homes usually can be better insulated and sealed up than a
combustion heated home, which requires ventilation for the combustion
process (this advantage also applies to all total energy homes). The
superior insulation reduces the cost penalty of an all-electric home.
In most cost comparisons between electrically heated homes and oil-
heated homes, the energy required to deliver the oil to the home is
neglected. Transportation costs for providing a home with oil are
eliminated in the electrically heated residence (as in a gas-heated
residence).
And, finally, the totally electric home is compatible with the
nuclear age in which low cost electricity will be generally available.
In this sense, the all-electric home will help smooth the transition
from the fossil fuel age to the nuclear age. The compatibility of
electric home heating with all types of fuel and power sources is a
distinct advantage for future community growth.
The availability of improved and more reliable heat pumps may
influence the energy/cost balance and is already accelerating the
popularity of total electric homes. Heat pumps are single units that
can both heat and cool space. They transfer heat from one location to
111-41
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another and the direction of heat transfer is reversible.
Heat pumps are powered by either heat (vapor absorption) or by
electricity (vapor compression). They are compatible with the CES
measure, and provide a convenient, point-of-use equipment suitable for
both heating and cooling in either the steam-heated zone or the elec-
trically heated zone of a CES area. They are more economical than
electrical resistance heating and comparable in energy demands to direct
heating with gas or oil (ref. 17).
4. Evaluation of Control Measure Effectiveness
The CES measure is most effective for urban areas with high
heat volume requirements per unit land area. Consequently, if, as
predicted, 90 percent of the population lives in urban areas by the year
2000, the CES measure becomes increasingly relevant in the 1975-1985
period. It can be implemented only in new construction and therefore
requires a long lead time to achieve full impact.
a- Ability of Measure to Maintain Standards. The effective-
ness of the CES measure can be determined by a comparison of total fuel
requirements for the combined system versus the conventional facilities
to be supplanted, assuming that the same fuel is used in both cases.
The CES alternative can then receive further credit for air quality
improvement due to:
A lower emission rate per unit of fuel burned;
More efficient control equipment; and/or
Taller stack height and higher exit velocity.
Data already available from those communities or installations now
employing some form of CES measure show greater than 60 percent efficiency
of fuel utilization, compared to 25 to 40 percent for conventional
systems and an average of 25 percent reduction in costs. Data to show
air quality improvement are not generally available, but the reduced
fuel requirements clearly correspond to reduced total emissions.
The net emission reduction that can result from implementation of
CES can be determined from the following formula:
Net reduction = N H (E - ces)
S K
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where
N = Number of individual units to be replaced by a central
system during the time frame under consideration
H = Average capacity of individual units
E = Controlled emissions from the average size individual
unit expressed as tons of pollutants per unit capacity
E = Controlled emissions from the central system expressed
as tons of pollutant per unit capacity
K = Factor representing transmission losses
Potential sources of input information are:
N - Growth pattern from land-use planning agencies
Population projections
State planning data
H - Manufacturers' design data
Fuel consumption data for district heating
E - Manufacturers' design data
l*c. o
EPA publications
K - City and County engineers
Consulting engineers
Industry
The CES measure has the desirable advantage of reducing a large
number of uncontrolled and largely uncontrollable sources to a man-
ageable number of sources under much better control and direction. It
can be applied to virtually all new fuel combustion sources, so it is a
feasible measure for at least three pollutants and can be quite ef-
fective in growth areas where maintenance of any standard is endangered
by fuel combustion sources. Also, the measure can be employed specif-
ically in those areas within the AQMA where air quality maintenance is
most difficult (hot spots).
The CES measure offers the opportunity for community growth at
minimum additional pollution load and lends itself to easy monitoring
and control.
b. Relative Efficiency Compared to Other Measures. One
alternative measure to CES is to upgrade the reliability of home-sized
fossil-fuel-burning equipment. Like the auto industry, manufacturers
could be compelled to guarantee a minimum life of unattended operation
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during which time emissions are not permitted to exceed certain levels.
Equipment would be inspected before leaving the factory and possibly
spot checked periodically after being in service.
The CES measure recommended here is easier and less expensive to
implement. Because of the anticipated higher efficiency of fuel uti-
lization, less total pollutants would be emitted than with an alter-
native measure such as outlined above.
CES is almost entirely limited to new and modified sources, so it
affects the growth component of regional emissions rather than requiring
additional control of existing sources. While this is normally an
advantage for maintenance measures, it does limit the regional impact of
a control measure to only a portion of the total emissions.
G. SPECIAL OPERATING CONDITIONS
1. Definition of Measure
The measures described in this paragraph can be used to reduce
emissions from sources on an intermittent basis or to minimize emissions
under atypical conditions in order to maintain air quality standards
that otherwise might be exceeded for relatively short periods of time.
Two principal types of activities are discussed: a) supplementary
control systems and b) procedures applicable to malfunction, startup,
and shutdown operations.
A supplementary control system is a system "whereby the rate of
emissions from a source is curtailed when meteorological conditions
conducive to high ground-level pollutant concentrations exist or are
anticipated" (ref. 18). A typical application would be a coal-fired
power plant that can reduce its load during adverse meteorological
conditions so that unsatisfactory ambient S02 levels do not result.
Specific operating procedures frequently must be followed in order
to minimize the pollutant emissions from particular industrial sources
during periods of startup or shutdown and when malfunction of process or
pollution control equipment occurs. With respect to new sources, the
Federal law provides that under these conditions, industrial processes
will be considered to be in compliance on the basis of most recent com-
pliance tests, as long as opacity regulations are not violated during
atypical operating conditions. However, the process may not be eligible
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for such consideration in cases where an upset condition can be shown to
be an avoidable situation. This provision is clearly indicated by the
EPA definition given for "malfunction":
'Malfunction1 means any sudden and unavoidable
failure of air pollution control equipment or
process equipment or of a process to operate in
a normal or usual manner. Failures that are caused
entirely or in part by poor maintenance, careless
operation, or any other preventable equipment
breakdown shall not be considered malfunctions
(ref. 19).
A specific reporting procedure to be used in conjunction with mal-
function operations, applicable to new industrial sources, is included
in 40 CFR, part 60, "Standards of Performance for New Stationary Sources".
It appears that a procedure requiring all reasonable means to minimize
emissions during startup, malfunction, and shutdown of existing sources
would be appropriate on a State level as a maintenance measure.
2. Historical Review of the Measure
a. Current Applications. Supplementary control systems
function to curtail emission sources on a temporary basis, so that air
quality levels remain satisfactory under adverse meteorological condi-
tions. Useful applications are probably limited to specific isolated
industrial S02 sources, such as coal-fired power plants and nonferrous
smelters. Enforcement is not feasible in areas where there are multiple
sources of a given pollutant.
The Tennessee Valley Authority (TVA) has undertaken to limit S02
emissions from several power plants by reducing generating load and/or
burning low sulfur coal during adverse plume dispersion periods (ref.
20). At the Paradise steam plant, early tests determined that the
addition of a third unit, at full-load operation, would cause the 3-hour
standard for S02 to be exceeded during certain meteorological condi-
tions. Three methods of noncontiguous SOp emissions control were tried.
Plans using low sulfur coal and the addition of lime to the coal prior
to conveying the coal to the bunkers were discarded in favor of plant
generating load reduction.
Nine meteorological and plume dispersion criteria were established
to determine the critical atmospheric conditions that cause high S02
levels. When all nine criteria are met, as determined by on-site measure-
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ment, generating reductions are determined and initiated. The only
limitation on the system is that reductions that would cause power
system instability cannot be made. The frequency distributions of
measured S02 concentrations before and after the implementation of this
supplementary control system are given in table III-3.
A supplementary control system for SCL is also being used at a
copper smelter in the State of Washington. The Puget Sound Air Pollution
Control Authority reported that at one monitoring station near the
smelter the frequency of 1-hour S02 concentrations exceeding 0.25 and
0.5 ppm has dropped significantly since initiation of the supplementary
control system (ref. 18). Seven other monitoring stations in operation
since 1971 showed similar declines. The frequency of SOp levels exceed-
ing 0.25 and 0.5 ppm are given in table III-4.
Proper maintenance and operating procedures have been established
for many industrial operations. When maintenance procedures are not
followed, it is likely that excessive emissions will result, especially
during periods of startup, shutdown, or malfunction.
For example, maintenance requirements for coke ovens are partic-
ularly severe. If coke-side and push-side doors are not cleaned prop-
erly, the doors will not seal. Smoke will then be emitted from the oven
throughout a large portion of the coking cycle. If flues become plugged,
"green pushes" may result in a substantial increase in particulate
emission rates.
Since maintenance of air quality is highly dependent on adherence
to proper maintenance policies and operating procedures, it seems proper
that the local agencies should require industries to demonstrate the
adoption and use of such policies. New sources are required by Federal
law to file quarterly reports of all periods of excess emissions due to
startup, shutdown, malfunction, or other causes. The report must also
include an indication of corrective measures that are taken and of pre-
ventive measures adopted. Owners and operators are required to use
acceptable operating and maintenance procedures. Such use may be
determined by Federal authorities on the basis of monitoring results,
opacity observations, review of operating and maintenance procedures,
inspections, and other information. An equivalent State or local reg-
ulation, applicable to all sources, would be useful.
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Table III-3. Frequency distribution of measured SOp concentrations
before and after implementation of supplementary control systems
at Paradise steam plant
3-hr average S02
concentration distribution
0
0
0
0
0
0
0
0
3-hr
average
S02 cone.
range
(ppm)
0
.01-0.10
.11-0.20
.21-0.30
.31-0.40
.41-0.50
.51-0.60*
.61-0.70*
.71-0.80*
*Above
Frequency
Before After
(1/1/68- (9/19/69
9/19/69) 6/25/71
51 ,097 55
10,574 9
443
102
37
16
7
2
1
air quality limits
,961
,363
275
59
28
10
2
0
0
Source: T. L. Montgomery, J. M
"Controlling Ambient S00." Journal
Table
Before
After
After
<-.
I I 1-4. Smelter monitor 1
for three selected
Year
control 1969
control 1972
control 1/73-
5/73
24-hr average S02
concentration distribution
24-h
avera'
S02 co
rang<
) (ppm
0
0.001-0
0.021-0
0.041-0
0.061-0
0.081-0
0,101-0
0.121-0
0.141-0
0.161-0
r Frequency
nc- Before After
e (1/1/68- (9/19/69-
) 9/19/69) 6/25/71)
3,064 3,752
.02 4,248 4,043
.04 400 305
.06 92 73
.08 24 19
.10 14 9
.12 6 3
.14 4 2
.16* 7 0
.18* 1 0
. Leavitt, T. L. Crawford, and F. E. Gartrell.
of Metals, June 1973.
-hour SOg concentrations
time periods
Greater than
0.25 ppm
102
7
1
Greater than
0.5 ppm
25
1
0
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b. Effectiveness of the Measure in Current Applications.
Supplementary control systems can be used effectively only under the
particular restrictive conditions that are cited in part 3(b), below.
The measure can be very effective in reducing ground level concentrations
if properly designed and administered. In the TVA power plant example
cited above, State regulations require that a maximum 3-hour S(L
concentration of 0.5 ppm shall not be exceeded more than once per year
at any point. In the year before controls were initiated, 10 excessive
levels occurred within the data network (table III-3). After the controls
were initiated, the 0.5 ppm standard was exceeded only two times. Further-
more, the two readings occurred at separate sampling stations.
For the copper smelter discussed above, the supplementary control
system reduced the number of incidents when,1-hour ground level concen-
trations exceeded 0.5 ppm from 25 in 1969 to 1 in 1972 (table III-4).
The primary ambient standard for S02 in the State of Washington pre-
scribes that levels exceeding 0.4 ppm (1 hour) shall not be exceeded
more than once per year; therefore, it is not readily apparent from
table III-4 whether the supplementary control system was successful in
maintaining the State air quality standards.
The effectiveness of a procedure applicable to malfunction, start-
up, and shutdown operations cannot be determined readily. It is likely
that such a measure in itself would not contribute significantly to the
maintenance of long-term air quality standards.
3. Implementation
a. Procedure. A proposed revision to regulation 40 CFR 51
permits selective use of supplementary control systems as a temporary
means of attaining and maintaining NAAQS only in cases where permanent
production curtailment, shutdown, or delays in attainment of NAAQS are
the only alternatives. Sources meeting the criteria set forth in part
3(b) below would probably be issued an operating permit with
specific operating restrictions attached. Special provisions may have
to be made to issue such permits on a case-by-case basis.
Regulation 40 CFR 60 provides that each source allow performance
tests to be made on the facility. These performance tests, along with
opacity tests, are the basis for determining whether good maintenance and
operating procedures are being followed. Review of operating and
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maintenance procedures and on-site inspections are also used as checks.
In addition, the source must, at the end of each calendar quarter,
report emissions measured or estimated to be greater than those allow-
able under standards applicable during performance tests.
b. Conditions of Applicability. Criteria for use of supple-
mentary control systems are as follows (ref. 18):
Each candidate source must demonstrate that adequate constant
emission reduction techniques are not available to attain and maintain
NAAQS.
Techniques that are available must be applied to permanently
reduce emissions to the maximum extent practicable prior to application
of supplementary control systems.
A dispersion model must be used to estimate the maximum air
quality concentrations that are expected after application of the control
strategy, unless application is shown to be inappropriate.
The owner or operator must be willing and able to accept full
legal responsibilities for maintaining the NAAQS throughout the area in
which emissions from that source significantly influence ambient air quality.
Each source must support and participate in an appropriate
research, development, engineering, and demonstration program to ensure
that the supplementary control system can be replaced by constant emis-
sion limitation techniques as soon as possible.
It is estimated that fewer than 50 coal-fired electric generating
plants would qualify under these criteria (ref. 18).
Because allowable emissions and associated air quality are tied to
specific meteorological conditions, the regulation requires that
a source must be isolated from other sources to qualify for this type of
control. This requirement for enforceability precludes the use of
supplementary control systems to control HC and NO emissions, which are
A
emitted by mobile sources. Supplementary control systems to control CO
and particulate emissions are also precluded because good constant
emission reduction techniques for these pollutants are available.
Federal regulations regarding emissions during startup, shutdown,
and malfunction presently pertain only to new sources. The adoption of
local regulations could extend this to include existing sources.
111-49
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c. Interaction With Other Measures. Stack height regula-
tions may restrict the use of supplementary control systems since tall
stacks, up to good engineering practice, may be required in order to
avoid high ground level concentrations. Zoning approvals may affect
whether a source can accept a long-term responsibility for maintaining
NAAQS. This is a necessary condition for the use of supplementary
control systems.
d. Potential Conflicts With Community Development Plans.
Because supplementary control systems can be used only in a few isolated
areas, there is little foreseeable conflict with other community devel-
opment plans. Any negative environmental impacts are probably regarded
to be less severe than the available alternatives, which include cur-
tailment, shutdown, or delays in attainment of NAAQS.
Startup, shutdown, and malfunction procedures are not likely to
conflict with community development plans or to produce negative environ-
mental impacts.
d. Practical Limitations
1) Social acceptability. Due to the restrictive
requirements for use of supplementary control systems, including
isolation from other sources and acceptance by the owner/operator of
complete responsibility for maintenance of air quality standards, this
measure is expected to have only limited applications. Therefore,
the public should not be greatly affected nor widely aware of the
measure. The interim nature of supplementary control systems and their
inherent flexibility both tend to negate the possibility that this measure
could prevent other development within the area of influence of the source.
2) Economic feasibility. Supplementary control systems
generally would be inexpensive relative to the costs of conventional
control equipment (if such constant emission control techniques were
available), so they may be economically attractive for eligible sources.
One important economic consideration in the selection of a supplementary
control system for maintenance is that it does not provide a long-term
solution, and must be replaced when feasible constant control techniques
are demonstrated to be available.
Special startup, shutdown, and malfunction procedures probably
represent small additional costs of operating a process, and they may
111-50
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be required only at infrequent intervals. However, if the procedures are
are not justified by lower repair costs or longer equipment life, and if
they do cause an increased cost of production, it is unlikely that they
will be implemented unless they are required. By requesting the sources
to submit maintenance and operating procedures for approval, rather than
specifying certain procedures, the sources may develop procedures that
have low costs and still are effective.
Both of these measures require extensive surveillance efforts by
control agencies for enforcement.
4. Evaluation of Control Measure Effectiveness
a. Ability of Measure to Maintain Standards. Supplementary
control systems are desired specifically to maintain air quality stan-
dards, but it is doubtful that they could ever be employed in an AQMA
because of the requirements that they can only be applied if a single
source in an area is emitting the pollutant.
The procedures covering startup, shutdown, and malfunction con-
ditions will probably not ensure that air quality standards can be
maintained in a given AQMA for an extended period of time. If defin-
itive maintenance and operating procedures are not adopted, source
emissions will tend to increase as control and process equipment dete-
riorate with age.
b. Relative Efficiency Compared to Other Measures. Supple-
mentary control systems can be used only in instances where constant
emission controls are not feasible for attaining or maintaining SCL air
quality standards. Furthermore, the systems are to be used only until
other measures become available. Therefore, a discussion of relative
efficiency is not appropriate for supplementary control systems. En-
forced adherence to prescribed operating and maintenance procedures can
be effective in maintaining minimum emission rates during all operating
conditions.
H. STACK HEIGHT REGULATIONS
1. Definition of Measure
The use of tall stacks as a maintenance measure is intended to
be applied in addition to, rather than in lieu of, stationary source
emission regulations. It is recognized that, even though all sources
111-51
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may be operating in compliance with allowable emission rates, it may be
necessary to effect a further reduction of ground-level concentrations
of air pollutants as growth in the AQMA results in increased emissions.
The use of a tall stack to decrease ground level pollutant concentra-
tions is based on the following fact:
Under any given set of meteorological conditions, the
ground-level concentrations of a gaseous pollutant emitted
at a constant rate into the atmosphere will become smaller
as the effective height of emission of the pollutant into
the air is increased (ref. 21).
Increasing the height of stacks can:
a. Reduce the frequency of occurrence of high ground-level
concentrations that are experienced with shorter stacks under the
following meteorological circumstances:
1) Neutral stability, high wind situations,
2) Inversion break-up situations, if the stack is sufficiently
high for the plume to penetrate the simple radiation inversion caused by
noctural cooling of the earth's surface, or
3) Looping situations, where the taller stack may enable slightly
greater dilution.
b. Reduce the frequency of occurrence of high ground-level
concentrations due to the plume being engulfed in wakes, eddies, and
aerodynamic downwash associated with the facility, nearby structures, and
terrain features.
Increasing the height of stacks cannot:
c. Reduce the frequency of occurence of high ground-level
concentrations that are experienced with shorter stacks under the following
meteorological conditions:
1) Limited mixing situations, or
2) Inversion break-up situations, when the plume does not pene-
trate a ground-based inversion or during an inversion aloft.
d. Reduce the peak short-term concentrations beyond 5-6 miles
from the source.
e. Reduce the amount of pollution emitted.
Based on these facts, it is considered good engineering practice to
construct a stack sufficiently tall to:
f. Minimize the effects of the plume being entrapped by
wakes, eddies, and aerodynamic downwash at any facility whose emissions
111-52
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are great enough to threaten air quality standards when such conditions
exist, or
g. Minimize the threat to air quality standards during
neutral stability, high wind conditions.
Emission regulations that have been adopted take into account the
use of stack heights based upon good engineering practice.
While tall stacks can be effective in the maintenance of acceptable
air quality on a localized basis in an AQMA, tall stacks do distribute
emissions over larger areas. If acceptable air quality is not being
attained in these more distant areas, emissions from tall stacks can add
to the existing pollutant burden.
2. Historical Review of the Measure
a- Current Application. In 1966, the Air Pollution Standards
Committee of the ASME developed its first standard; APS-1, Recommended
Guide for the Control of Dust Emission-Combustion for Indirect Heat
Exchangers. Following the development of the second edition of APS-1
(November 1968), the committee produced ASME Standards APS-2. Recom-
mended Guide for the Control of Emissions of Oxides of Sulfur
Combustion of Indirect Heat Exchangers in January 1970. The procedures
in the APS documents enable one to estimate the amount of each pollutant
that may be emitted from a stack and/or the height of a stack required
for any given-sized unit for specified maximum ground-level concen-
trations.
EPA has recognized that increasing the height of stacks plays a
useful but limited role in attainment and maintenance of NAAQS. Since
1960, there has been a pronounced trend toward increasing the height
of stacks. Simultaneously, there has been a trend toward substantially
greater emissions at single locations. The principal application of
extremely tall stacks has been for large oil- or coal-fired
electrical generating boilers and major ore smelting operations.
Increasing stack heights beyond that judged to be good engineering
practice is not an acceptable control measure except in very limited
instances. The exceptions are presented in Vol. 38, No. 178, Federal
Re9ister. September 14, 1973, pp. 25697-25703. An extension of a stack
to a height exceeding good engineering practice may be a part of a
control measure to achieve air quality standards if: (1) the source is
isolated, i.e., a source that accepts responsibility for all ambient
111-53
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S02 found in its vicinity, and (2) action to increase the stack height
is taken in conjunction with the development and operation of a supple-
mentary control system.
Increasing stack heights may be an acceptable maintenance measure
to decrease the effect upon ground-level pollutant concentrations of
sources already in compliance with emission regulations. It must be
considered, however, that tall stacks have the effect of spreading
pollutant emissions over a much larger area.
b. Effectiveness of the Measure in Current Applications.
The effectiveness of increased stack height in reducing ground level
concentrations of sulfur oxides and particulates can be determined
through the use of atmospheric dispersion models (ref. 22). It is
generally agreed that the accuracy of pollutant concentrations deter-
mined by dispersion models is within a factor of about 2.
There are environmental insults, as yet unidentified, that may make
it undesirable to use tall stacks. The effects of atmospheric loading
of pollutants, particularly of sulfur oxides, are as yet unknown. In
particular, the impact of sulfur oxides on the formation of suspended
sulfates, acid rainfall, acidification of soil and water, visibility
reduction, changes in the colloidal stability of clouds and changes in
the transmission of radiant energy through the atmosphere have not been
determined. For these reasons, in addition to the implications of the
Clean Air Act, emissions reduction, rather than the use of tall stacks,
is the preferred method of reducing the ground-level impact of emis-
sions.
3. Implementation
a. Procedure. The use of tall stacks as a maintenance
measure may be implemented by modification of existing emission reg-
ulations to include minimum stack height requirements. It must be
emphasized again, however, that the use of tall stacks as a maintenance
measure is not the same as the use of tall stacks as a condition to
obtain a variance for compliance with emission regulations.
b. Conditions of Applicability. The use of minimum stack
height requirements to maintain acceptable ambient air quality is applicable
to all point sources provided that:
111-54
-------
1) Sources are in compliance with existing emission
regulations, and
2) Further constant emission reduction methods are not
available to individual sources.
When NAAQS can only be attained by utilization of a tall stack, the
height of which is constrained by good engineering practice, it is
advisable that its use be accompanied by an approved supplementary
control system.
c. interaction With Other Measures. Where this measure is
applied it will have an additive effect on assisting interaction with
the following maintenance measures:
Emission allocation,
Emission density zoning,
Emission charges,
More restrictive source limitations and NSPS, and
Combination of emission sources.
d. Potential Conflicts With Community Development Plans.
Due to obstacle height limitations imposed by FAA requirements, the
presence of tall stacks will restrict certain areas from airport develop-
ment. Additionally, most State Power Plant Siting Commissions would have
to approve a stack height extension.
e. Practical Limitations. In a ruling handed down February
8, 1974, the U.S. Court of Appeals for the Fifth Circuit disapproved
two pertinent provisions of the Georgia implementation plan, including
its variance provision and its reliance on dispersion techniques rather
than emission regulations. The Court held that emission reduction tech-
niques are clearly the preferred control methods under the Clean Air
Act, and that "other measures" referred to in section 110(a)(2)(B), such
as dispersion techniques, are allowed only if emission reduction techniques
sufficient to meet the national ambient air quality standards are
unavailable or unfeasible. The Court held that Georgia's reliance on a
tall stack control technology was untenable under the act.
4. Evaluation of Control Measure Effectiveness
a. Ability to Maintain Standards. In specific cases the
ability of a tall stack to maintain acceptable levels of currently
111-55
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established standards has been demonstrated. Requirements for minimum
stack heights as a maintenance measure should be based on the demonstra-
tion of reduced spatial and temporal impact of the dispersed emissions
using acceptable diffusion modeling techniques.
b. Relative Efficiency of the Measure. Use of tall stacks
will reduce ground-level pollutant concentrations on a localized basis.
Stacks up to the height of good engineering practice are acceptable in
all cases.
Provided that a source is sufficiently isolated and that its emissions
are sizeable (greater than 1,000 tons per year), increasing the height
beyond good engineering practice to dilute emissions can be as efficient
as engineering limitations on height will permit. As previously noted,
the acquired ground-level control effectiveness of the stack must be
guaranteed by a concurrent supplementary control system. This supplementary
control system is a procedure to limit the rate of pollutant emission
when meteorological conditions conducive to ground-level concentrations in
excess of national standards exist or are anticipated.
Construction of tall stacks does not require materials or skills in
short supply and can usually be accomplished in months rather than
years. Obviously, its total effectiveness is limited by the number of
source applications in any AQMA. However, if and when ambient standards
are set for materials such as sulfates or fine particulates, tall stacks
will only serve to compound the environmental insult.
I. CONTROL OF FUGITIVE DUST SOURCES
1. Definition of Measure
Construction activity is the most significant fugitive dust
source in most AQMA's. The primary construction sources are highway,
residential, commercial, and industrial construction projects. In
addition, fugitive dust emissions from unpaved roads and agricultural
activities indigenous to the arid and semiarid areas of the Great Plains,
Far West, and Southwest, can have a considerable effect on the air
quality of AQMA's in these regions. Other fugitive dust sources, such
as material storage piles and unpaved parking lots, may have a localized
impact on air quality but rarely are widespread enough to affect AQMA air
quality. Total suspended particulates is the only pollutant resulting
111-56
-------
from fugitive dust sources.
Several methods have been employed to reduce the dust emissions
from construction sites, including those listed below (ref. 23). Expected
average control efficiencies are shown in parentheses.
Watering (50%)
Chemical stabilization of completed cuts and fills (80%)
Treatment of temporary access and haul roads on or adjacent to
site (50%)
Minimal exposure periods for active construction areas (50%).
While these measures have relatively low control efficiencies compared
to other particulate controls, they are proven techniques that
can be enforced as regulatory requirements. Rigorous control of con-
struction activities and other fugitive dust sources provide emission
reductions from a source category that is presently controlled through
nuisance provisions. Hence, it can be considered as a maintenance measure,
Control measures to reduce the particulate emissions from agri-
cultural sources consist of the same measures presently employed for
conservation of topsoil from erosion. These measures consist of:
Continuous cropping (25%)
Limited irrigation of fallow fields (20%)
Windbreaks (5%)
Interrow plantings of grain on widely spaced row crops (15%)
Stubble, crop residue, or mulch left on fields after harvest
for wind protection (10%)
Spray-on chemical stabilization (40%)
Fugitive dust emissions from unpaved roads have been controlled by:
Paving and right-of-way improvement (85%)
Surface treatment with penetration chemicals (50%)
Soil stabilization chemicals worked into the roadbed (50%)
Speed control (10 to 40%).
2. Historical Review of Control Measure
a. Current Applications. Several local and State control
agencies, including Pima and Maricopa Counties in Arizona, have passed
regulations requiring permits to construct on a property. The permit
applications must state the dust control method to be used, and it is
subject to revocation for failure to implement the control.
111-57
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The State of Colorado requires that a control plan be submitted by
any construction source if a visible plume is observed at the property
line or if a plume of greater than 20 percent opacity is observed at any
point on the site for more than one minute duration. The control plan
must contain one of the "recognized control methods" endorsed by the
agency.
The State of Nevada has specifications written into State construc-
tion contracts requiring stabilization of all completed cuts and fills.
Most states have had regulations for dust control on highway projects as
an integral part of their highway construction standards for some time.
EPA has conferred extensively with the U.S. Department of Agriculture in
attempting to develop enforceable means of reducing the contribution of
agricultural dust emissions in arid areas. However, the only recom-
mendation to date is a program of education in soil conservation and
dust control methods. The State of Colorado's Air Pollution Control
Division has excluded agricultural sources from its fugitive dust con-
trol regulations.
b. Effectiveness in Current Applications. Isolation of the
impact of stringent dust control regulations on both regional and
localized particulate concentrations is difficult because of the many
fugitive dust sources in most of the areas where these controls have
been implemented.
Based on emissions data, construction may account for up to 10
percent of particulate emissions in metropolitan areas (ref. 23); con-
sequently, a comprehensive control regulation could reduce emissions by
as much as 5 percent.
3. Implementation
a. Procedure. Most of the measures to reduce air pollution in
highway construction or building construction could be controlled by
additional provisions to construction specifications and building codes or
by air pollution control regulation. Several agencies have passed
regulations requiring permits to construct on a site. In order to obtain
and keep a permit, the contractor must have an approved plan to control
dust. This is an enforcement aid, since the permit can be revoked if a
dust problem is observed on the site.
111-58
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Use of the permit system could be extended to provide another con-
trol techniqueminimal exposure of barren areas. Part of an approved
plan for large sites would provide for grading and other earth-moving
work on portions of the site followed by treatment of the finished por-
tion prior to opening a new section to clearing and regrading. Long-
duration development of large tracts could also be effectively regulated
to prevent windblown dust problems. Any permit program requiring
minimal exposure periods should require submittal of detailed plans and
schedules. Subsequent field inspections by enforcement personnel would
be essential to ensure adherence to the plans.
Implementation of control measures for unpaved roads would require
coordination with highway departments and provision of funds to pave or
otherwise upgrade unpaved road surfaces. One effective measure in rapid
growth areas is to prohibit the construction of new unpaved roads.
b. Conditions of Applicability. Fugitive dust control
measures are applicable whenever the particulate emissions from these
sources contribute significantly to the total particulate concentration
of an AQMA.
c. Interaction With Other Measures. The temporary and
intermittent nature of most fugitive dust sources would cause these
sources to interfere with some of the approaches to air quality main-
tenance such as emission allocation or emission density zoning.
Therefore, control of this often-ignored source category could make
these approaches more workable.
d. Potential Conflicts and Negative Impacts. Implementation
and enforcement of fugitive dust control measures necessarily involve
the interaction of air pollution control agencies with such groups as
highway departments, building departments, highway patrols (for speed
control on unpaved roads), and the Department of Agriculture. For this
reason, whenever the activities and goals of these cooperating organiza-
tions are divergent from those of the air pollution control agency, a
potential conflict is created. For example, rigorous dust control mea-
sures on a highway construction project might cause construction delays
and subsequent failure to meet deadlines.
e. Practical Limitations.
1) Social acceptability. Social acceptability to con-
111-59
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struction activity control measures would be favorable, since the re-
sulting decrease in airborne dust from these projects would be tangible
evidence of improved conditions to the surrounding populace.
Acceptance of the unpaved road dust control measures would be
mixed. Reaction to a decrease in road dust would be good; however, the
inconvenience to the motorist of the control measures, e.g., speed
control and detours, would certainly cause a negative reaction. Keeping the
public educated on the advantages of such control measures greatly enhances
their acceptability.
2) Economic feasability. Cost data for most fugitive
dust controls are presented in ref. 23. In general, the cost of dust
control programs on construction sites is a very small portion of total
construction costs and can be included in those costs. However, because
of the extent of unpaved roads and agricultural activities, the total
costs to control emissions from these categories may make these in-
feasible.
4. Evaluation of Control Measure Effectiveness
The effectiveness of the measure is dependent on the percent
contribution from fugitive dust emissions in the AQMA projected emission
inventory. Specific construction sources and their locations change
with time. Since new development is occurring in the AQMA (by defini-
tion), emissions from these sources should continue, even
though they are continually changing in location. The problem of
construction activities in a "hot spot" causing the standards to be
exceeded would be minimized by other measures of the maintenance strategy
that would discourage further permanent development in that area. If it
is denoted as a problem area, special dust control requirements might be
placed on construction activities.
REFERENCES
1. The Clean Air Act, Section 111(b)(l)(A).
2. "Review of New Sources and Modifications (Preamble)." Federal
Register 38, No. 116 (June 18, 1973).
3. G. W. Walsh. Priorities for Development of Standards of Perform-
ance (Draft). Environmental Protection Agency, Durham, N.C.,
November 13, 1972.
111-60
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4. Report of the Hearing Panel, National Public Hearings on Power
Plant Compliance with Sulfur Oxide Air Pollution Regulations,
October 18, 1973 - November 2, 1973, submitted to Environmental
Protection Agency, January 1974.
5. Coal Conversion Processes. PEDCo.
6. Edward A. Zawadzki. EPA Region IV, Coal Cleaning Study. March
1974.
7. C. A. Berg. "Energy Conservation through Effective Utilization."
Science 181. No. 7 (July 1973): 128-138
8. J. C. Moyers. The Value of Thermal Insulation in Residential
Construction: Economics and Conservation of Energy. Oak Ridge
National Laboratory, Report ORNL-NSF-EP-9.Oak Ridge, Tenn.,
December 1971.
9. D. P. Gregory. A Techno-Economic Study of the Cost-Effectiveness
of Methods of Conserving the Use of Energy. Institute of Gas
Technology, Chicago, 111., 1971.
10. P. R. Achenbach, et al. A Feasibility Study of Total Energy
Systems for Breakthrough Housing Sites. National Bureau of
Standards Report 10 402, Appendix A, Washington, D.C., August
1971.
11. C. D. Stahl, quoted in Electronic News, February 4, 1974, p. 32.
12. E. Vandergrift. Particulate Pollutant System Study. Vol. III.
Handbook of Emission Properties, Environmental Protection Agency,
CPA 22-69-104 CPB 203 5221, May 1971.
13. Joint Hearings Before Certain Subcommittees of the Committees on
Government Operations and Science and Astronautics, House of
Representatives, "Conservation and Efficient Use of Energy (Part
4)" 93rd Congress, 1st session, July 12, 1973, p. 1858-61.
14. H. Perry and H. Berkson. "Must Fossil Fuels Pollute?" Technology
Review 74. No. 2 (December 1971): 34-43.
15. Joint Hearings Before Certain Subcommittees. "Conservation." Part
3, July 11, 1973, p. 904.
16. Joint Hearings Before Certain Subcommittees, Part 3, p. 907.
17. S. L. Jacobs. "More Homes are Using Electric Heating; Claim that
It Wastes Energy Is Disputed." Wall Street Journal, February 14,
1974, p. 1816.
18. Title 40. Code of Federal Regulations, Part 51, The Use of Supple-
mentary Control Systems and Implementation of Secondary Standards.
September 14, 1973.
ni-61
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19. Title 40, Code of Federal Regulations, Part 60, Standards of Per-
formance for New Stationary Sources, November 14, 1973.
20. T. L. Montgomery, J. M. Leavitt, T. L. Crawford, and F. E. Gartrell
"Controlling Ambient SO,,." Journal of Metals, June 1973.
21. Tall Stacks, Various Atmospheric Phenomena, and Related Aspects.
NAPCA Publication No. APTD 69-12, Arlington, Va., May 1969.
22. Workbook of Atmospheric Dispersion Estimates. PHS Publication No.
999-AP-26, Cincinnati, Ohio 1969,(Revised).
23. PEDCo-Environmental. Investigation of Fugitive DustSources,
Emissions and Control. Contract No. 68-02-0044 Task Order No. 9,
for Environmental Protection Agency, Cincinnati, Ohio, May 1973.
111-62
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Chapter IV: INTERRELATIONSHIPS AMONG MEASURES
Many of the measures proposed for maintaining air quality standards
are not completely independent of one another, but have either beneficial
or detrimental effects if they are implemented concurrently. It is
important that these interactions be recognized when maintenance strate-
gies are being formulated so that, if combinations of measures are neces-
sary, those that are compatible can be supported and those that are not
can be avoided.
The most significant interrelationships, for each measure were des-
cribed in some detail in chapters II and III. The purpose of this
chapter is to present a more systematic procedure for assessing inter-
actions. This procedure (ref. 1) utilizes a matrix of all the measures
under consideration, as shown in table IV-1. Four symbols are used to
qualitatively describe the different relationships, that may exist
between two measures:
AThe measures assist each other either by facilitating imple-
mentation or by increasing their combined effectiveness.
C--The measures are complementary; they act on different sources
or in a different manner to mutually produce combined improve-
ments. One measure may be a component or instrument of the
other.
I--The measures are independent of each other; neither will
enhance nor deter the effectiveness of the other.
0~The measures have some overlapping in their emission reduction
or location objectives, are competitive, may preempt each
other, or be otherwise incompatible.
Theoretically, two measures could also be counterproductive to each, other.
However, none of the maintenance measures were observed to have this
relationship, so it has been omitted.
The interrelationship between emission allocation and emission
density zoning is an example of how one measure can assist in the
IV-1
-------
Table IV-1. Interrelationships among maintenance measures
f
K3
EMISSION ALLOCATION
Z
Z
0.
i
3
Q
z
o
ID
Z
z
o
t-
o
o
£
LJJ
ZONING APPROVALS 8 OTHER
INDIRECT REGULATORY CONTROLS
0
o:
i
tj
Z
o
l-
o:
O
Q.
Q;
EMISSION CHARGES
TRANSFER OF EMISSION SOURCE
LOCATIONS
INDIRECT SOURCE REVIEW
ENVIRONMENTAL IMPACT
STATEMENTS
NEW SOURCE PERFORMANCE
STANDARDS
MORE RESTRICTIVE SOURCE
EMISSIONS LIMITATIONS
PHASE-OUT OR PROHIBITION OF
SPECIFIED SOURCE CATEGORIES
FUEL CONVERSION
Q
3
O
1-
ar
LJ
z o
o
"s
Is
z t-
UJ 3
Z
t-J
LAND-USE AND PLANNING MEASURES
EMISSION ALLOCATION
REGIONAL DEVELOPMENT PLANNING
EMISSION DENSITY ZONING
ZONING APPROVALS & OTHER INDIRECT
REGULATORY CONTROLS
TRANSPORTATION CONTROLS
EMISSION CHARGES
TRANSFER OF EMISSION SOURCE
LOCATIONS
INDIRECT SOURCE REVIEW
ENVIRONMENTAL IMPACT
STATEMENTS
c,o
A
0
c,i
0
A
C, 1
1
C.O
C.O
A
C,0
0
c
c
A
A
c,o
0
1
0
A
1
1
0
A
0
1
0
c
1
1
C,l
C.O
1
1
c
1
A
C
0
0
0
0
c
0
1
1
A
C
A
C
1
0
C,l
c
1
1
A
1
1
A
A
1
c
1
A
C
c
c
1
1
1
1
1
1
c,o
c
c
1
1
0
c
1
1
C
c
c
1
1
1
c
1
1
A
C
A
1
1
1
1
1
1
c
c
c
1
1
1
1
1
1
c
A
C
1
1
C
Z
o
1-
H
i
Z
i
o
(_»
UJ
Q.
t/3
U
1
0
1
1
1
1
1
1
STACK HEIGHT REGULATIONS
C
1
c
1
1
c
1
1
1
CONTROL OF FUGITIVE
DUST SOURCES
C
1
c
1
1
1
1
1
A
EMISSION CONTROL MEASURES
NEH SOURCE PERFORMANCE
STANDARDS
MORE RESTRICTIVE SOURCE EMISSION
LIMITATIONS
PHASE-OUT OR PROHIBITION OF
SPECIFIED SOURCE CATEGORIES
FUEL CONVERSION
ENERGY CONSERVATION AND
UTILIZATION
COMBINATION OF EMISSION SOURCES
SPECIAL OPERATING CONDITIONS
STACK HEIGHT REGULATIONS
CONTROL OF FUGITIVE DUST SOURCES
C
c,o
c
A
C
C
0
C
C
C
C
C
C
C
A
1
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LEGEND: A - MEASURES THAT ASSIST EACH OTHER IN MAINTAINING AIR QUALITY,
C - MEASURES THAT ARE COMPLEMENTARY IN MAINTAINING AIR QUALITY,
I - MEASURES THAT ARE INDEPENDENT OF EACH OTHER IN MAINTAINING AIR QUALITY,
0 - MEASURES THAT MAY OVERLAP OR PREEMPT EACH OTHER IN MAINTAINING AIR QUALITY,
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the implementation of another. Emission allocation prescribes the total
allowable emissions in an area. Emission density zoning provides a means
of implementation by distributing the allowable emissions throughout the
area on the basis of land use. More restrictive source emission regula-
tions and stack height regulations are examples of complementary measures,
Implementation of the first results in a reduction of emissions, the
second in a spatial distribution of the reduced emissions. An example
of measures that are independent of each other is found in the combina-
tion of Environmental Impact Statements (EIS's) and New Source Perfor-
mance Standards (NSPS). The EIS's are applicable during the planning
and preplanning stages, NSPS to the construction and implementation.
Zoning approval and emission changes are examples of measures that may
overlap or preempt each other. Zoning restrictions could prohibit the
construction or modification of a source that, if built, would produce
emissions subject to emission charges.
This approach to evaluation of interactions involves some sub-
jective categorizations, but it provides a simple method of organizing
the evaluation results for grouping of the measures. Some of the
measures are so broad in scope and may interact in such complex manners
that a single descriptive categorization may not be adequate. For
example, a regional land-use plan could encourage high-density corridor
developments in an urban area to increase mass transit usage and reduce
VMT. In one AQMA, this may be interpreted as assisting transportation
controls in maintaining standards, while in another it may be considered
overlapping. The analysis of interrelationships should be made specif-
ically for each AQMA based on local conditions. The results may be
different from those shown in table IV-1. In general, the same inter-
actions will exist regardless of whether the two measures are being
used for control of the same pollutant or for two different pollutants.
Although the following conclusion is not evident from the results
of the matrix analysis, most of the land-use and planning measures
(except the review procedures) represent comprehensive approaches to air
quality maintenance and, as such, are mutually exclusive alternatives.
The generalization can also be made that most of the emission control
measures can usually be implemented within the framework of different
IV-3
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land-use and planning measures, and may be the specific actions taken to
effect emission reductions that are needed under a land-use and planning
measure.
In cases where implementation of a single maintenance measure
involves several actions, e.g., transportation controls, an analogous
matrix for intrameasure relationships should be developed, so that these
are adequately considered in designating the actual actions to be
implemented. The intrameasure interactions are highly dependent on
local conditions, both in determining which individual controls are
applicable and what the impacts are among them.
REFERENCES
1. The procedure was adapted from a procedure for evaluating
interrelationships between energy reduction actions presented
in a draft report entitled Guidelines to Reduce Energy Con-
sumption Through Transportation Actions, prepared for U.S.
Department of Transportation, Washington, D.C., by Alan M.
Voorhees and Associates, March 29, 1974.
IV-4
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TECHNICAL REPORT DATA
(Please read Instructions on tlic reverse before completing)
1 REPORT NO.
EPA-450/4-74-003
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Guidelines for Air Quality Maintenance Planning and
Analysis, Volume 3, Control Strategies
5. REPORT DATE
July 1974
6. PERFORMING ORGANIZATION CODE
7 AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Studies Center
10. PROGRAM ELEMENT NO.
Research Triangle Institute
Research Triangle Park, N. C. 27709
PEDCo Environmental Specialists, Cincinnati, Ohio 45246
11. CONTRACT/GRANT NO.
68-02-1386 Task No. 1
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 REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Part of a 12 Volume series.
16. ABSTRACT
This report describes 18 different measures that have been used or proposed
for use in maintaining air quality standards in regional areas. For each measure,
information has been assembled on current applications (case histories),
recommendations for implementing the measure, estimates of potential effectiveness;
and conditions under which the measure is most applicable. Many of the measures
land-use or regional planning, and are concerned primarily
These include: emission allocation procedures,
emission density zoning, zoning approvals,
transportation controls, emission charges, transfer of emission source location,
indirect source review, and environmental impact statements. Other measures
are technological in nature: new source performance standards, more stringent
control of existing sources, phaseout or prohibition of emission sources, fuel
conversion, energy conservation and utilization, combination of emission sources,
special operating conditions, stack height regulations, and control of fugitive
dust sources
reviewed
with new
regional
are based on
sources of emissions.
development planning,
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Regional Planning
Urban Planning
Land Use Zoning
Air Pollution Control Equipment
Atmosphere Contamination Control
Air Pollution
Air Quality Maintenance
Plans
Air Quality Maintenance
Measures
Land Use Controls for Air
Quality Maintenance
"'ssion Co.ntrpls for Air
I ".
13-B
imiss:
Qua
19. SECl
y Maint.pnanrp
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
188
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
V-l
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