450R80106
P/EPA
Prepared by the National League under a grant from the
of Cities and the National U.S Environmental Protection
Association of Counties Agency.
Air
March 1980
Parallel Goals:
Clean Air and
Economic
Development
Exploring New
Strategies for Urban
Areas
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In the past three decades, problems of rising
unemployment and decaying industrial and
commercial centers in America's urban com-
munities have been accompanied by aban-
donment or deterioration of old neighbor-
hoods. As urban inhabitants—often followed
by business —leave cities, seeking a cleaner,
healthier and safer environment in which to
live, property values drop, the tax base is
depleted, and business decline accelerates.
Air pollution has contributed substantially
to the general degradation of the quality of
life in urban centers. The adverse health ef-
fects suffered by urban residents are wide-
spread and the medical treatment is costly—
as much as $10 billion annually according to
one study.* Another study** estimates that
a 60 percent reduction in particulates could
result in a $36 billion annual savings to in-
dustry from lost time-on-the-job and lower
worker productivity. Air pollution damages
buildings and vegetation. Studies also show
that air pollution decreases property values.
In the Los Angeles area, a study*** found
property values for similar homes were
substantially lower in areas with high pollu-
tion levels.
Because air pollution exacts such a heavy
toll, public support for environmental im-
provement remains high. Two recent nation-
wide polls found that about half the public
favors enforcement of the strictest environ-
mental standards, even if that would mean
higher costs to business and to consumers.
*Health Costs of Air Pollution, American Lung
Association, December 1977.
**Methods Development for Assessing Air Pollu-
tion Control Benefits, Report developed for EPA
Office of Research and Development, February
1979.
***lbid
And according to a recent Gallup poll con-
ducted for the National League of Cities, 60
percent of urban residents feel that not
enough is being done to reduce air pollution
in their communities.
Responding to these needs, in March
1978, President Carter announced a National
Urban Policy that committed the federal
government to the long-term goal of making
America's urban communities more attrac-
tive places in which to work and to live.
New federal initiatives under this policy are
helping local governments plan and imple-
ment growth opportunities in a manner that
addresses urban problems in a coordinated
fashion.
As part of this policy, the Air Quality
Technical Assistance Demonstration
(AQTAD) program is a unique federally-
funded effort to integrate two national goals
of direct concern to cities and counties:
cleanup of air pollution and revitalization of
urban economies. It is an attempt to demon-
strate that reduction of air pollution to levels
scientifically determined to be healthful, as
required by the Clean Air Act, is fully com-
patible with urban recovery efforts. The
AQTAD program is an opportunity to show
communities across the country how to in-
corporate air quality requirements into their
economic development decisions.
Under AQTAD, the U.S. Environmental
Protection Agency (EPA) and the Depart-
ments of Housing and Urban Development,
Commerce, and Transportation are providing
$3.5 million directly to the following eight ur-
ban governments: Boston, Mass.; Erie Coun-
ty (Buffalo), N.Y.; Philadelphia, Pa.; Chicago,
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III.; Minneapolis and St. Paul, Minn.;
Bridgeport and Waterbury, Conn.; Elizabeth,
N.J.; and Portland, Ore. While these areas all
share characteristics of distress such as job
loss, inadequate tax base, and environmental
degradation, they also all have aggressive
economic development programs. With
AQTAD funding, they will work to coordi-
nate such programs with air quality plan-
ning. The ways in which they propose to ac-
complish this are summarized in this book-
let. The information should help other
jurisdictions devise innovative strategies
suitable to their own situations.
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Economic Growth and the
Clean Air Act
Air Pollution: An Urban Public Health
Problem
Even in healthy individuals air pollution has
been directly linked with lung, throat and
eye irritation, breathing difficulties and in-
creased respiratory problems. Scientists are
convinced that air pollution is a very real
contributing factor to three major types of
diseases that cause sickness and death in
our society — heart disease, lung disease and
cancer. Research has shown that air pollu-
tion will accelerate the rate of disease in
those people already afflicted, and earlier
death is a very real possibility. Air pollution
is particularly burdensome on the very old
and the very young.
The most common pollution problems in
urban areas are ozone (the principal compo-
ment of smog) and carbon monoxide. Both
come primarily from cars, trucks and buses
(ozone is not emitted directly, but is formed
by a chemical reaction between nitrogen ox-
ides, volatile organic compounds [generally
referred to as hydrocarbons], and sunlight).
Industry also contributes substantially to the
ozone problem. Sulfur oxides and par-
ticulates are two other urban health hazards.
These pollutants come mainly from coal and
oil burning in industry and utility power
plants. A less severe pollution problem in
most areas is the level of nitrogen oxides
which come from both vehicles and in-
dustry.
Urban areas generally have higher levels
of dangerous air pollutants than rural areas
because of the concentration of industry and
the large number of motor vehicles.
The Clean Air Act, as amended in 1977,
requires all areas to restrict the concentration
of these pollutants to levels determined not
to be unhealthful for humans. These levels,
called National Ambient Air Quality Stand-
ards, must be achieved by the end of 1982,
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Air Planning in Nonattainment Areas
although areas with severe auto-related
pollution can receive an extension to 1987
for ozone and carbon monoxide. In order to
keep clean air clean, Congress also man-
dated the Prevention of Significant Deteriora-
tion (PSD) of air quality where levels of the
regulated pollutants do not violate the na-
tional ambient standards.
Areas that do not meet national standards
for any one of the regulated pollutants are
called nonattainment areas for that pollutant.
Each State is required to develop and up-
date a State Implementation Plan (SIP) iden-
tifying measures the State and its subdivi-
sions will take to reduce existing emissions
in order to meet and maintain national stand-
ards in accordance with the Act's deadlines.
By law, the State is required to consult with
local governments when revising this plan,
and in areas that are nonattainment for
ozone or carbon monoxide, must "jointly
determine" with local elected officials the
planning and implementation roles which the
State and localities will play.
To allow for continued economic growth
in nonattainment areas, the Clean Air Act
permits States and localities to develop
mechanisms that will permit new sources of
air pollution to locate in nonattainment areas.
However, the new pollution must not inter-
fere with reduction of emissions to levels not
harmful to health within the Act's time
limitations.
To accomplish growth, new sources of
pollution can be considered on a case-
by-case basis, using an "emissions offset"
mechanism. For example, if a factory that
will emit sulfur dioxide wants to locate or
expand in a nonattaiment area, sulfur dioxide
emissions from other existing facilities must
be reduced by at least the amount that will
be added by the new factory. The reduc-
tions, called "offsets," can be made within
other facilities operated by the owner of the
new or expanding facility, or at plants
operated by others. To create an offset, ex-
isting industries would have to control pollu-
tion beyond what is required by state and
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Air Planning in Clean Air Areas
federal regulations. Offsets might also be ob-
tained by reducing pollution from cars or
other "areawide" sources of pollution such
as dust on city streets.
Another way to move toward clean air
while allowing growth is to provide a built-in
"growth cushion." In this case, the state air
plan must require extra pollution control '
measures on existing sources that go
beyond federal requirements.
Regardless of whether an emissions offset
system, a growth cushion or some other
combination of the two approaches is used,
as long as total air pollution from both old
and new sources continues to decrease, the
nonattainment area will be making the re-
quired progress toward meeting ambient air
standards.
To keep clean air, Congress included a
separate regulatory framework for PSD in
the Clean Air Act. It is important to note that
most urban areas, even center cities, have
attained standards for some pollutants, and
are, therefore, subject to both nonattainment
requirements for certain pollutants and PSD
requirements for others.
The law permits a clean air area only
limited increases in emissions. Just how
much pollution may be added depends on
the nature of the area. So-called Class I
areas—mainly large national parks—are
allowed almost no pollution. Most clean air
urban areas are Class II for PSD pollutants,
and are permitted moderate emission in-
creases. If more industrial growth is desired,
however, an urban area can petition for
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What Can Local Government Do?
reclassification as a Class III area. (If it wants
more protection of its air quality in order to
foster tourism and recreation, reclassification
to Class I can also be requested.) In no case,
of course, can air quality become poorer
than national standards.
The levels of additional pollution allowed
are referred to as PSD increments. Each time
a new pollution source is constructed, a por-
tion of the increment is used up. Additional
major new sources cannot receive construc-
tion permits where total new emissions will
exceed the increment.
Most often, permits have been distributed
on a first come, first serve basis; this insures
clean air, but may limit the type and amount
of a community's economic growth in the
future. Without local involvement, increment
allocation by the State or EPA will not
necessarily be consistent with local and
regional long-term economic growth plans.
States and communities may also want to
make room for more economic growth by
reducing existing emissions through tech-
niques similar to emission offsets or growth
cushions.
The Clean Air Act and federal policy permit
various mechanisms to cities, counties and
States for integrating air quality and
economic development. Any such mecha-
nisms must be compatible with, and, in
many cases, incorporated into SIPs.
The urban areas in the AQTAD program,
often in conjunction with state agencies, are
investigating, and in many cases implement-
ing the following strategies:
Technical and Financial Assistance to In-
dustry. Some businesses may lack the
financial or technical resources to control their
pollution, and may be threatened by the
maintenance or installation costs of pollution
control equipment required by law. New in-
dustries may also need help in meeting
pollution requirements if they are to locate in
an area.
Other companies may be able to meet
federal air requirements, but will need
technical or financial incentives if they are to
invest in the additional emission reductions
needed for an area's growth. If growth is to
be accommodated on a case-by-case basis,
new development cannot occur unless there
are enough offsets on the market.
Cities and counties can help private in-
dustry by identifying potential emission
reductions, accumulating information on
state-of-the-art pollution control technol-
ogies, and analyzing the cost-effectiveness
of alternative pollution control techniques.
A local one-stop permitting or referral
service can cut red tape for companies
wanting to expand or locate in the area.
Tax-free municipal industrial bonds for
pollution control equipment have been a
popular tool in recent years to help com-
panies meet the costs of pollution control.
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Other local financial benefits, such as re-
duced property tax assessment or municipal
loans or loan guarantees for pollution abate-
ment equipment are also being investigated.
A city or county with limited resources
may want to target this assistance to firms
meeting certain criteria such as need, size,
type of industry and consistency with long-
term development objectives. When used to
create offsets needed to attract new in-
dustry, a portion of the revenue lost can be
recovered as taxes paid by the new industry.
In addition, local governments can en-
courage firms to take extra measures to
reduce pollution by promoting the profit-
making potential of producing offsets for the
use of others.
Emissions Offset Clearinghouse. One of
the major problems for a new or expanding
industry in a nonattainment area is finding
emissions offsets and estimating their value.
An emissions offset clearinghouse run by a
local government or coordinated with the
State can locate potential emissions reduc-
tions and accumulate information on control
technologies and costs.
The clearinghouse would actively link up
firms that need offsets with those that have
or can produce them. A clearinghouse can
also estimate the cost of generating each
offset to establish its value. It would certify
offset transactions and keep continuous
track of them to make sure projected emis-
sion reductions are accurate and permanent.
Questions about public vs. private owner-
ship of emissions offsets and the costs of
administering a clearinghouse remain to be
investigated.
Emissions Offset Bank. An offset gener-
ally is not created until there is a use for it.
That is, an industry will not reduce pollution
further than required by law until it wants to
expand, or until another industry offers to
finance the reduction for its own expansion.
However, under the emissions banking con-
cept, an industry could reduce its emissions
now and deposit that offset in a bank to use
later—when it wants to grow or wants to
sell that offset to another industry.
In addition to reducing delays and uncer-
tainties associated with locating reasonably
priced offsets, an emissions bank can result
in considerable long-run savings to com-
panies with emission reduction potential.
Because most state plans in nonattainment
areas require companies to install some
pollution control equipment, initial purchase
of more sophisticated equipment capable of
greater-than-required pollution abatement
may be more cost-effective than purchasing
additional equipment later, when an offset is
needed for expansion or sale.
In order for local governments to become
involved in emissions banking, the State
plan must provide a sufficient legal
framework.
Publicly-Owned Offsets. There are
several potential sources for publicly-owned
offsets: those actually produced by public
facilities, those produced by private industry
but bought by or accrued to the public, and
those resulting from reduction of emissions
from small private sources such as motor
vehicles.
Local governments can reduce their own
emissions by such activities as switching to
cleaner fuels or cutting fuel use in public
buildings through energy conservation
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measures. They can take intensive measures
to reduce the public automobile driving, or
encourage energy conservation from small
sources. To be considered an offset,
however, all these measures must go
beyond what is required by the state plan.
Local governments could also buy offsets
created by private industry, or assume
ownership of offsets, for example, from
companies that close facilities. It is possible
that local governments may be able to
assume at least partial ownership of private
offsets which they helped to finance or
create.
Allocation of Air Quality Offsets or PSD
Increments. Local governments may want
to allocate offsets or an increment of allow-
ed pollution only to industries that further
local economic or social goals. The ability of
cities and counties to integrate these goals
into air quality programs will be tested by
several grantees in the AQTAD program.
Local governments can rank the industries
or industry types which they would like to
have or retain in their area. Criteria for rank-
ing could include such things as number and
type of jobs, income of employees, property
or income tax generation, and quantity and
type of pollution generated.
A city or county could then either directly
allocate the available offsets or increments
to high-ranking industries, or alternatively
control the information about offsets and in-
crements and agressively market it to
desired businesses.
Emission Fees. The theory of emission
fees is that placing a fee on each unit of
pollution will encourage the polluter to con-
tinue adding controls until the cost of further
controls exceeds the fee, at which point the
polluter will opt to pay the fee. The fee can
theoretically be set to produce any level of
emissions control desired for an area—a
higher fee results in more control and less
emissions; a lower fee results in fewer con-
trols and more emissions.
Although emission fees have the advan-
tage of maximizing innovative and cost-ef-
fective control techniques, a number of
serious questions remain. The fee may
discriminate against companies whose in-
dustrial processes result in higher emissions,
and require more expensive control tech-
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riiques than other industries. The fee must
be carefully set to produce the desired
amount of emission reduction without undue
costs to industry. Difficult and costly
monitoring and enforcement problems may
be involved.
One city in the AQTAD program,
Philadelphia, is experimenting with emission
fees (see page 19).
Siting/Zoning Mechanisms. Ambient air
quality information can be incorporated with
other characteristics of a site to determine
the suitability of a given location for
development. This description could be used
to identify the kinds of offsets needed for
development or the growth margin available
in each area.
In "emission density zoning," a metro-
politan area would be divided into a grid, or
a series of zones. Each zone or combination
of zones can be assigned a ceiling level of
pollution based on projections of future
emissions. This sort of approach relies on
computer models which use current emis-
sions data, economic development projec-
tions, current land uses and land use plans,
and climatic and geographical data to
predict how air pollution will disperse
throughout the area. Density limits for new
or expanding plants can then be set which
will assure progress toward clean air.
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10
Taking the Initiative
Former Senator Edmund Muskie, a chief archi-
tect of the Clean Air Act, said, "A community
which chooses to languish in its current
economic situation will need to make few of
the really tough decisions...." However, a
community that wants to attract new economic
activity will have to take an aggressive role.
Trying new strategies means many unresolved
issues will have to be addressed. The
AQTAD cities will be among the first to face
these questions squarely:
• How are air quality factors best integrated
comprehensively with other local programs
such as economic development, housing,
transportation and public facilities invest-
ment?
• What can a local government undertake on
its own and what is best done on a regional
or statewide basis?
• How much control can and should a local
government wield over allocation of that
scarce resource—the capacity to pollute?
How will the decisions of one local govern-
ment affect the entire region? How should
local governments work with the State to
address these interlocal problems?
• How can state and local governments en-
sure that a private offsets market works
equitably? That enough offsets are available
to accommodate new economic activity? To
what extent should an offset be regarded
solely as property of the owner?
• What will be the effect of local govern-
ment initiatives on locational preferences of
industry? What sort of assistance will be
most valuable to industry and to which in-
dustries should it be provided?
• Are there economic incentives to replace or
supplement regulation thaf. will work more
efficiently toward clean air?
• Who should bear the burden of making ,
room for new industry? Existing industries?
New development? Area commuters? Or the
community at large?
The AQTAD projects will result in an in-
tegration of federal and local development
programs with state and locally-devised air
quality programs in these eight communities.
Federal development programs, such as
Community Development Block grants, Ur-
ban Development Action Grants and the
Public Works and Economic Development
Act programs, are a cornerstone of growth
management strategies in each. At this time,
many state air quality plans have only vague
outlines of growth management mecha-
nisms. Local officals have the chance now to
help the State form policy acceptable to
them.
A successful air quality growth manage-
ment program will not, of course, ensure
economic development; other factors may
intervene. However, by establishing a body
of experience and knowledge, the air quality
technical assistance demonstrations in the
eight communities should encourage other
local governments to formulate their own
strategies.
The decisions involved are tough, but
without aggressive action by cities and
counties, they will be made by others.
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11
Local Programs The Boston Program
In the last 25 years, Boston's service in-
dustries have grown, but a severe decline in
the manufacturing, trade and construction in-
dustries left the city with a net employment
loss and a growing unemployed force of less
skilled, lower income workers. To reverse
this trend, the city launched a major effort in
the 1960's that has attracted a billion dollars
a year in public and private sector invest-
ment.
Recently, Boston was also selected by the
U.S. Department of Commerce to develop a
Comprehensive Economic Development
Strategy (CEDS) program to encourage job
creation for Boston's existing unemployed
blue collar workers and to preserve the
stability of neighborhoods in the city.
Autos and many of the industries Boston
is trying to attract and retain are major emit-
ters of hydrocarbons, a primary ingredient of
smog. Extensive efforts to reduce hydrocar-
bons from cars have been underway since
the mid-1960s. Thus, the emphasis of the
Boston technical assistance grant is on sta-
tionary sources of pollution which contribute
about 30 percent of the area's hydrocarbons.
Existing air pollution control programs re-
quire "reasonably available" controls for ex-
isting stationary sources. But this leaves a
good deal of room for Boston's new pro-
gram to create offsets for growth by pro-
moting pollution reductions beyond the
minimum control level.
Boston's program, administered by the
Boston Redevelopment Authority (BRA) wilt
create and bank offsets, publicize their
availability, allocate them to new industries
and assist industries in crossing any en-
vironmental hurdles to expanding or locating
in the city.
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12
To create offsets, the city will take direct
action with city-owned hydrocarbon
sources. After a thorough analysis of costs
and benefits, Boston will select from such
measures as cutting fuel use in public
buildings and installing vapor recovery
systems at city-run garages. Many measures
will require only small or one-time outlays
which can be partially recouped by the sale
of the resulting offsets.
Getting privately-owned pollution sources
to reduce emissions beyond the minimum
required by law is also an important part of
the plan. The city may provide tax benefits
for existing sources that reduce pollution.
Then when the offset is sold or given to
new industry, the city could recover its costs
through increased tax revenues from the
new source. Technical and financial
assistance on energy conservation will also
be provided to small private consumers. In
return, the city would gain ownership of the
offset.
Once the offsets are created, Boston
wants to allocate them to industries and
other sources that promote its economic
goals. The BRA will develop an industrial
ranking system that considers such factors
as:
• Retention of existing, expanding industries;
• Attraction of new industries to provide
new manufacturing jobs;
• Evaluation of proposed plants to relate
costs in terms of air emissions to benefits
such as the number of new employees and
increased payroll and municipal tax
revenues.
The city will try to facilitate the sale of
privately-owned offsets by establishing a
clearinghouse at the Boston Air Pollution
Control Commission. Industries will be en-
couraged to get together to generate and
market their own offsets.
Finally, BRA will provide technical
assistance to industries. Initially, this will
take the form of a handbook outlining the
steps for participating in Boston's offset
program.
Later, when BRA identifies existing
sources that need help in reducing pollution
to create offsets, BRA will provide more
comprehensive advice. The city could help
existing industries find the most cost-effec-
tive pollution controls based on the market
value of the offset, improve a plant's pollu-
tion control engineering and management
skills, and evaluate investment options for
buying controls. The city may concentrate
on groups of industries with similar emission
characteristics so that purchase of pollution
control equipment could be done collectively.
Boston's plan is characterized by a con-
cern for preserving existing firms as well as
attracting new ones. The mechanisms
developed in Boston could help other cities
do the same.
Contact: Vivian Li, Director, Air Quality
Technical Assistance Project, Boston
Redevelopment Authority, 1 City Hall
Square, Ninth Floor, Boston, Mass, 02201.
(617)722-4300, Ext. 381.
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The Bridgeport and Waterbury Program
13
In the Naugatuck Valley of central Connecti-
cut, intense development and a high popula-
tion concentration as well as pollution blown
in from other areas have resulted in the
worst air pollution in the State. The area
does not meet health standards for ozone,
carbon monoxide or particulates.
Although the cities of Bridgeport and
Waterbury are still major manufacturing
sites, the area has experienced a decline in
economic activity over the last generation.
Employment is clustered in old facilities
along the Naugatuck River. Five major com-
panies have left the area since 1970. Both
cities have initiated major economic develop-
ment programs to change this trend.
The air quality technical assistance grant
will draw upon the commitment and exper-
tise of nine agencies at three levels of
government in an intense cooperative effort
to reach the parallel goals of clean air and
economic revitalization.
Small and mid-sized municipalities, the
cities of Bridgeport and Waterbury, regional
planning agencies, the state Departments of
Environmental Protection, Transportation and
Commerce all have essential roles to play. A
Management/Advisory Group will be made
up of representatives from each of these
agencies to oversee the project. The
Naugatuck Valley Task Force, which was
established by the Governor to promote
economic development and includes
business representatives, has also made a
firm commitment to the program.
The Connecticut Department of En-
vironmental Protection (DEP) will determine
the ambient air quality and potential offsets
in the valley from stationary and mobile
sources, including those that are not current-
ly regulated. The survey will include cost
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14
estimates for each type of potential offset.
The Department of Transportation will assist
with identification of mobile source offsets;
the state Department of Commerce will iden-
tify offsets from shutdowns and other sta-
tionary sources.
The resulting inventories can be broken
down into small geographical areas. The
growth margins available to individual com-
munities in the valley will then be known.
This information will enable each local
government to have specific data for land
use and growth management decisions.
The Valley Regional Planning Agency will
study the rights of local communities under
the Connecticut SIP to manage the growth
margins available to them, and will suggest
how municipalities can control and regulate
the sale of privately-owned offsets or in-
crements. It will also recommend an efficient
system for keeping records of offsets
created, banked and transferred.
The Central Naugatuck Valley Regional
Planning Agency will evaluate 21 industries
already identified as having a competitive
advantage in a Connecticut location to deter-
mine the balance between jobs and pollution
in a given firm. The results of this study
would be used to further target marketing
efforts for local industrial parks.
DEP will work with the cities of Bridge-
port and Waterbury to produce case studies
of possible air quality constraints on three in-
dustrial park projects to show the alternatives
that are possible for full development.
The transportation, community and
economic development and environmental
protection agencies of the two cities will
consider specific measures to create emis-
sion offsets for the future—for example, the
coordination of residential with industrial
development to reduce commuter trips, or
financing by cities to pay for private offsets.
The local governments and regional agen-
cies can then incorporate air quality re-
quirements into their economic development
planning.
Waterbury will implement some of the
more advanced pollution reduction measures
to demonstrate their effectiveness in pro-
viding a margin for greater economic
growth. The Waterbury demonstration pro-
gram will also test the feasibility and legality
of an offset banking system.
The Greater Bridgeport Regional Planning
Agency will assist smaller communities in
the area and study whether some develop-
ment projects might be diverted to nearby
suburbs where air quality considerations or
the availability of offsets are more favorable.
This could be done with minimal harm to
Bridgeport if there is public transit to the
jobs and if there is a sharing of tax revenues
generated by the development.
The Bridgeport-Waterbury effort may
show how regional cooperation in both
economic development and air quality can
eliminate institutional and government bar-
riers. City officials are confident that new in-
dustries are ready to move into the area; the
AQTAD program will help the Naugatuck
Valley realize its full economic potential.
Contact: Ned Moore, Director, Air Quality
Technical Assistance Project, Office of Com-
munity Development, City of Waterbury,
Waterbury, Conn. 06702. (203) 547-6777.
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15
The Erie County (Buffalo) Program
Thorny environmental problems combine
with severe economic decline and frag-
mented local governments to make Buffalo
and surrounding Erie County a tough test for
reconciling clean air and economic revital-
ization
The county includes rural, suburban and
urban land —clean air as well as nonattain-
ment areas. Much of the county's densest
urban center has severe air pollution prob-
lems and does not meet standards for
ozone and particulates. This area includes a
large part of the traditional industrial zone, a
fact that places limits on the expansion
potential of the Buffalo area's heavy industrial
base, especially steel, coke, chemicals and
grain milling.
The selection of the Erie County Depart-
ment of Environment and Planning (ECDEP)
as principal coordinating agency for an air
quality demonstration grant will provide a
regional forum for cooperative solutions to
these problems. Three different units of
government will be working together:
ECDEP, the Erie County Industrial Develop-
ment Agency (ECIDA), and the city of Buf-
falo. A policy committee and a technical ad-
visory committee guiding much of the proj-
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16
ect activity will ensure region-wide represen-
tation and commitment to the program.
The goal of the Erie County (Buffalo) proj-
ect is to use a package of government serv-
ices as an incentive to industries for expand-
ing or locating in the county.
The project will develop a system for
identifying, tracking, expanding and
distributing available air pollution offsets,
relying as much as possible on private
economic incentives to spur development.
The ECDEP will administer an offsets infor-
mation center which will combine air quality
data with other site information. Computers
will be used to provide officials and business
people convenient access to accurate air
quality data. A possible addition to the serv-
ice would be the creation of an offsets bank.
ECDEP will also consider ways to create
additional air quality capacity to accom-
modate growth, including public sector
emission reductions. The county wants to
develop the capacity to measure the effects
of changing federal, state and local policies
on regional development goals.
ECIDA, the regional economic planning
body, will participate as a full partner in
achieving AQTAD goals. In addition to help-
ing to develop and administer the offsets in-
formation center or other trading mecha-
nisms, ECIDA will develop a one-stop air
quality, financial assistance and technical ad-
visory service for industrial firms targeted as
high priority in the regional development
plan. After assessing the financial needs of
industry, ECIDA can put together federal,
state and local loan packages, including
sources such as the Small Business Ad-
ministration, Economic Development Ad-
ministration and the county's own industrial
revenue bonds. Special emphasis will be
placed on assisting as many as 600 small
and medium-sized firms, industry with the
greatest local growth potential, to relocate or
expand in Erie County.
The city of Buffalo will be developing a
land reuse plan for the southern industrial
half of the Lake Erie waterfront. Although of-
fering some of the finest economic growth
opportunities in the county, much of the
waterfront currently is a nonattainment area.
Buffalo will be looking at the existing land
uses and the proposals for redevelopment as
well as the interrelationships of the public
and private sector in the area. After analyz-
ing the effects of different development
alternatives, the city's Department of Com-
munity Development, working with ECDEP
and ECIDA, will devise a long-term land
redevelopment strategy that makes best use
of both air resources and economic devel-
opment potential. ECDEP will eventually re-
examine municipal land use and zoning
ordinances in the whole county.
Involving the diverse local, special,
regional and state units of government will
minimize legal, political or administrative
roadblocks in the future. A regional ap-
proach is implicit in any clean air or
economic development strategy; in Erie
County, that approach will be explicit.
Contact: Rosalind Paaswell, Director,
Air Quality Technical Assistance Project, Erie
County Department of Environment and
Planning, Erie County Office Building,
95 Franklin Street, Buffalo, N. Y. 14202.
(716)846-6231.
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17
The Elizabeth Program
The city of Elizabeth, N.J., lies within the
New York-Philadelphia urban corridor. Like
the rest of the State and surrounding area,
Elizabeth does not meet the minimum health
standard for ozone. It also does not meet
the standard for carbon monoxide.
Elizabeth is confronted with many of the
economic problems of an older industrial city
but, through its Industrial Commission and
the Union County development committee,
the city government has done much to ar-
rest its decline. For example, the city has
just initiated development of a 500-acre in-
dustrial park.
Elizabeth has also operated its own air
pollution control program for a decade.
The city already has a basis for the new
demonstration program in its Comprehensive
Land Development Control Ordinance and a
master planning program which provides for
the integration of economic development
and environmental requirements. Also, a
county authority already offers financial
assistance to industries for pollution control
equipment.
The city's objectives for the new program
are two:
• To evaluate stationary and mobile source
control options for potential reductions in
emissions which would allow expansion of
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18
existing industries and attraction of new
facilities; and
• To integrate potential offsets into the
development review process.
Project activities will begin with an inven-
tory of pollution control equipment currently
used by each industrial facility and an inven-
tory of vehicle emissions produced by
employees traveling to and from those
plants. Then, an analysis will be made of im-
provements in stationary source control
equipment, as well as alternative transporta-
tion facilities to reduce transportation-
related emissions.
The analysis and recommendations for fur-
ther pollution controls will be supervised by
task forces of federal, state and local of-
ficials, concerned not only with Elizabeth but
with the whole of Union County.
The city will then establish an "emission
capacity" for land areas based on projec-
tions of possible offsets and identify areas
suitable for future industrial growth. The
Land Development Control Ordinance will be
altered by the city council to specify the
level of control that must be attained by
new or expanded industries in each land-
use zone.
A city air quality coordinator will ensure
that stationary and mobile source emissions
meet requirements, that they do not exceed
the emission limit for the land-use zone and
that sufficient emission offsets are procured
where necessary.
The public and private sectors will be
partners in attaining "clean air for progress."
Current waterfront and industrial park
development indicates the partnership is
working. The city's marketable location and
proximity to air, land and sea transportation
facilities are valuable economic resources.
Compliance with national ambient air stand-
ards and economic growth will be made
possible by the innovative thinking, financial
redevelopment and retooling support provid-
ed by the AQTAD grant.
Elizabeth is weighing the possibility of ob-
taining significant emission reductions
through car and van pooling. Off-site park-
ing areas coupled with mass transit could
reduce single passenger automobile trips.
Elizabeth is relying heavily on industry
cooperation to put these car and van pool
measures into effect. Compliance will be
voluntary and no city funds will be available
to buy vans.
Because experience in other areas has
shown that emission reductions from these
sorts of measures are small and hard to
quantify, Elizabeth is also considering other
area source reductions as offsets, so that its
program will not falter on over-optimistic
projections.
Using mobile emission reductions as well
as stationary source controls to obtain off-
sets is an attempt to expand responsibility
for achieving cleaner air and economic
growth. The city's experience will be a guide
for other areas with substantial transporta-
tion-related pollution.
Contact: John N. Surmay, Director of
Health, Welfare and Housing,
60 West Scott Place, Elizabeth, N. J. 07207,
(201)353-6000, Ext. 200.
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The Philadelphia Program
19
In the past nine years, employment in
Philadelphia has declined by 130,000
jobs—80,000 in manufacturing—a decline
twice that of the city's population loss. At
the same time, pollution has become severe
due to the combination of too many cars
and emissions from older, dirtier industries.
Philadelphia does not meet health standards
for ozone, carbon monoxide, participates, or
sulfur dioxide.
The city's officials recognize that, to
reduce their growing unemployment rate,
they must retain existing plants as well as
attract new ones, even though many of the
older facilities are operating in deteriorating
buildings and face other physical site and
economic problems.
Perhaps because of the difficult economic
problems Philadelphia has had to face, the
city's commitment and ability to foster
economic development is substantial. The
AQTAD grant will be administered by a con-
sortium of city agencies with a
demonstrated record of cooperation and
achievement: the Philadelphia City Planning
Commission, the Philadelphia Industrial
Development Corporation and the city's Air
Management Services.
Initially, the city will be collecting basic in-
formation and establishing mechanisms
necessary for a successful air quality/growth
management program. The project will in-
clude air quality considerations in the city's
development by identifying advanced control
technologies and expanding financial pro-
grams to target industries.
Target industries will be chosen based on
a broad range of criteria, such as thewj poten-
tial for remaining in the city, anticipated
cooperation with the city and their economic
benefit. This effort may forestall some clos-
ings by letting industries know that the city
is preparing to assist them. A secondary ob-
jective is to identify new industries that
might be persuaded to locate in
Philadelphia.
An inventory of advanced and innovative
pollution control techniques for targeted in-
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20
dustries, along with financial assistance, will
help businesses obtain the most advanced
control measures they can afford. To pay for
installation of this equipment, the city will in-
vestigate new financing programs, such as
public-private investment pools, insurance
for private lenders, and innovative loan pro-
grams such as those already established in
New York and California. The needs of small
industrial firms will be given priority; the
local development corporation which
handles Small Business Administration loans
will be expanded.
An offset clearinghouse will be establish-
ed early in the program. The clearinghouse
will publicize availability of offsets, certify
and record them, arrange purchase of offsets
by the city as they are created and transfer
offsets through gift or purchase to industries
that need them. Philadelphia will be retain-
ing close control over the distribution of off-
sets to ensure that they assist targeted in-
dustries.
The city has set aside considerable time
and resources to investigate the possible
legal and institutional hurdles to an offset
program, such as who owns the emissions
reductions when a company goes out of
business.
Philadelphia will also explore region-wide
implementation of the offset clearinghouse
and other growth management measures.
Through Philadelphia's representation on the
Delaware Valley Regional Planning Council,
the air quality grant will be coordinated with
the surrounding counties and municipalities
in both states in the Philadelphia
metropolitan area.
The city's unique contribution to the
AQTAD demonstration program will be its
experiment with emission fees. Emission
fees rely on economic incentives rather than
regulation to reduce air pollution from in-
dustry. Although many economists feel the
approach makes sense, emission fees have
yet to be put into effect by any level of
government in the United States. The city is
very concerned about the possible inequities
of emission fees and will be examining ways
to distribute revenues from the fees to in-
dustries. Philadelphia will be reviewing legal
feasibility and the city/county/state tax struc-
ture, as well as the technical data needed to
set fees and reallocate revenues. Industry
reaction to a "reallocated emission fee" ap-
proach will be assessed.
The city will also explore the use of extra
reductions from transportation sources as
offsets for economic development. However,
because of the city's continuing difficulty in
meeting the ozone standard by 1.987, all its
reductions in transportation emissions may
have to be allocated to that effort, leaving
none for transfer to the industrial sector.
Philadelphia's commitment to the program
extends beyond the two-year federal grant
because the mechanisms established under
the grant will be carefully integrated into
ongoing city departments and agencies. Im-
proving air quality will become a permanent
part of Philadelphia's revitalization efforts.
Contact: Elba C. Pellecchia, Chief, Com-
prehensive Planning, Philadelphia City Plan-
ning Commission, City Hall Annex.— 14th
Floor, S.E. Corner Juniper and Filbert
Streets, Philadelphia, Pa. 19107, (215)
686-4609.
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21
The Chicago Program
In just ten years, Chicago's manufacturing
job base has eroded by one-third, mostly in
high unemployment minority areas. Air pollu-
tion levels during the same period of time
have shown improvement. Due primarily to
conversion of city buildings to natural gas
and to regulations limiting fuel oil sulfur con-
tent, Chicago now meets the minimum
health standard for sulfur dioxide and has
significantly reduced levels of particulates.
But, despite efforts of the city's air pollution
control agency, now in the Department of
Inspectional Services (DIS), large sections of
the city still violate the paniculate standard
and the entire Chicago area has unhealthy
ozone and carbon monoxide levels.
To counter the decline in manufacturing
employment, Chicago has used city and
federal funds to develop a comprehensive
approach, the Chicago Plan, to create new
industrial development. The Chicago
Economic Development Commission (EDO
has been a moving force in the Chicago Plan
which targets for redevelopment industrial
areas located in these high unemployment
neighborhoods. These areas are also those
with the highest pollution in the city.
While both EDC and DIS have been ag-
gressive in their own areas of jurisdiction, air
quality improvement and economic growth
have been treated as independent issues.
The air quality technical assistance grant
was awarded to help create a partnership
between the two city agencies.
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22
The Chicago area transportation control
plan addresses one category of the city's
major air pollution sources — motor vehicles.
Therefore, the city has chosen to focus its
air quality technical assistance grant on sta-
tionary sources of pollution. The project's
goals are to promote the creation of emis-
sion offsets with a city-administered offset
bank, and to use financial assistance to both
create offsets and to help new and expand-
ing firms obtain pollution control equipment.
Two new planning councils will be
formed. The In-City Review Committee,
made up of city department heads, will
develop policies for allocation of emission off-
sets to industries and recommendations for
the use of public funds for any capital im-
provement needs identified by the program.
This group will also review and evaluate the
air quality demonstration program as it pro-
gresses.
An Advisory Council will consist of the
directors and staffs of the city departments
involved, and several representatives from
industry. The Advisory Council will enable
city staff to get industry's reactions to pro-
posed policies before putting them into ef-
fect.
As a first step, the city must learn who is
producing what types and amounts of pollu-
tion, and the cost and degree of control
technology being used at each facility. DIS
will establish a technical base to begin an
offset banking system and identify ways to
create more offsets for the bank. At the
same time, EDC will be interviewing com-
panies that are representative of their in-
dustry. They will be eliciting industry views
on potential offsets needed and available, as
well as gathering data on potential job loss.
tax base contribution, payroll, minority
representation and skill level of employees.
Both agencies will be working to link the
environmental permit system with Chicago's
existing one-stop service at EDC. The
one-stop service provides direct assistance
to industries to alleviate any problems a
company might have either with staying in
Chicago or locating there. It expedites the
processing of all local, federal and state per-
mits and solves problems involving city ser-
vices. It also locates, purchases and
prepares sites for industrial expansion. To
this service will be added the information
available from the offsets bank.
EDC will be assisting existing Industrial
Councils to work with companies that want
to develop emission offsets. With DIS pro-
viding the technical support, EDC will
develop recommendations on the air quality,
technological and financial needs of area
companies, making sure that the unique
needs of smaller companies are accom-
modated.
The Chicago air quality grant should bring
permanent benefits to the city's urban
revitalization effort. The city has pledged to
carry on the program after the federal fund-
ing has expired, although an intensive
evaluation after the initial two years may
serve to refine the process.
Contact: Edward Petkus, Air Quality
Technical Assistance Demonstration Project
Manager, Department of Inspectional Ser-
vices, City Hall-Room 900, 121 N. LaSalle,
Chicago, III. 60602. (312) 744^081.
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23
The Minneapolis and St. Paul Program
Air in the Twin Cities of Minneapolis and St.
Paul has more ozone, carbon monoxide, par-
ticulates and sulfur dioxide than meet health
standards.
During the period 1961-1975, Min-
neapolis's economy as well as its air suf-
fered. Due to plant obsolescence and high
land costs, industrial and commercial
employment declined by 15 percent. St.
Paul's economy in the same period remained
stagnant.
Each city has already taken steps to im-
prove its environmental and economic pros-
pects. The cities, with their areawide agen-
cy, the Metropolitan Council, have formu-
lated a regional plan for attainment of air
quality standards and have separately
developed plans for the revitalization of their
central business districts.
One of the unique aspects of the Twin
Cities area is the system of regional coopera-
tion that has been developed. The seven-
county Metropolitan Council oversees
transportation, housing redevelopment,
public facility investment, and land use, as
well as air quality. The air quality technical
assistance demonstration grant will enable
the Council to add a regional air quality
demonstration program that stresses com-
munity and economic development.
The Council will be exploring an in-
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24
novative zoning strategy using emission den-
sity limits. One form which these limits
might take is a jurisdiction or district emis-
sion quota, obtained by dividing up the
metropolitan area into grids and forecasting
land uses for each. Based on these projec-
tions, planners could estimate future emis-
sions in different areas and establish ceiling
levels of pollution which could not be ex-
ceeded. Floating zone quotas, another option
tor guiding growth, would stipulate that a
new source could not add more than a cer-
tain amount of emissions within a given
radius of its proposed site. Thus, growth in
one area would be dependent on the growth
that occurs adjacent to it.
Once the cost and feasibility of each zon-
ing option is established, the Council will
draft model zoning ordinances and submit
them to the local governments in the region.
Although the Council has no authority to re-
quire cities and counties to enact these
measures, the state Land Use Planning Act
gives the Council approval authority over
local land use plans. The ordinances, when
enacted, would be integrated into the zoning
and land use provisions that are part of the
metropolitan area redevelopment scheme.
The major attraction of this emission den-
sity zoning plan is that it provides a capabili-
ty to integrate air quality assessments with
capital improvement projects in transporta-
tion, waste management and open space.
Although the Council is principally in-
terested in applying these zoning concepts
to the cities of Minneapolis and St. Paul, the
actions will have regional implications. For
example, in order to provide enough of an
incentive for certain industries to locate or
stay in downtown areas, more restrictive air
quality limits may be necessary in outlying
areas. The broad land use objectives in the
Twin Cities area call for economic growth to
occur in the "public service area" where
such services as water and sewer already
exist or are planned by 1990. This area is
much larger than the boundaries of the two
major cities.
The Twin Cities metropolitan area is also
unique in that the property tax revenues
from new development are shared in part by
all jurisdictions under the Fiscal Disparities
Act. This regional revenue sharing could
make it politically less threatening for
jurisdictions to enact strict emissions zoning
ordinances because of the potential for shar-
ing some revenue from growth occurring
elsewhere.
The Council will also consider various
other metropolitan management strategies.
Examples include an offset banking system
to reallocate emissions savings from one
area to another or the use of economic in-
centives such as tax breaks to encourage in-
dustries to install pollution abatement equip-
ment.
The Metropolitan Council has made
specific provisions for continuation of the
project beyond the demonstration program.
One objective of the program is to devise
mechanisms which are not only innovative
but simple enough to be applicable in other
areas.
Cortfacf: Ray Thron, Director, Air Quality
Project, Environmental Planning Division,
Metropolitan Council, 300 Metro Square
Building, Seventh and Robert Streets, St.
Paul, Minn. 55101, (612) 291-6409.
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The Portland Program
25
In Portland, a burgeoning population of
suburban commuters and a topography that
creates frequent incidents of stagnant air
have led to an increase in ambient air pollu-
tion. The Portland area does not meet na-
tional air standards for ozone or carbon
monoxide.
Portland has embarked on a central city
economic revitalization effort. The city was
the first in the country to be designated by
the U.S. Department of Commerce for the
CEDS program.
The completed CEDS plan did take air
quality and transportation considerations into
account. The new air quality technical
assistance demonstration grant will allow the
city to refocus its CEDS development pro-
gram to achieve air quality goals.
Portland has already instituted an exten-
sive number of control measures to reduce
transportation-related pollution, including
emission inspection and maintenance of
vehicles, downtown parking limits, bus and
carpool lanes, park-and-ride programs and a
transit mall. The city's development program
has also tried to minimize pollution from
vehicles of workers commuting to industrial
centers by promoting new construction near
commercial and industrial locations served
by transit.
Measures beyond those considered in the
state air quality implementation plan could
allow industrial expansion that is currently
precluded by high pollution in certain areas.
The demonstration project will focus on
reducing transportation-related pollution in
the Swan Island industrial area. Employment
on the island, which lies in the center of
Portland, could double by 1990 if pollution is
significantly reduced.
The Swan Island Transportation Commit-
tee will coordinate the project. Swan Island
employers sit on the committee with staff
from the Port of Portland (owner of Swan
Island), Tri-Met (the regional transportation
agency) and the city of Portland.
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26
The project involves three components:
• Four new bus lines to the island, based on
surveys showing residential concentrations
of Swan Island employees.
• An intensive marketing program of
brochures, posters, route maps, a carpool
matching service and a personal campaign
in employee neighborhoods.
• Free transit passes to promote bus rider-
ship for up to four months, funded by city,
regional and federal money.
Six firms have been selected for a more
intensive planning effort and will work with
the city in developing unique transportation
schemes to reduce employee auto trips.
The Portland proposal contains an explicit
plan for evaluating the effectiveness of an in-
centive approach to changing commuter
travel behavior. The city, Port of Portland
and the regional transit agency will monitor
auto traffic into Swan Island and increases in
transit ridership to determine the extent of
reductions in auto trips. The reductions can
then be related to a decrease in air pollution
emissions. The participating agencies will
also conduct opinion surveys to determine
which marketing and incentive devices were
most effective in inducing people to switch
to bus or vehicle pools.
If the project is successful on Swan
Island, Tri-Met and the city are committed
to continuing the project as part of their
regular operating budgets. The Swan Island
project would also be the first step in ex-
panded transit service to the five other inner
city industrial areas with similar access prob-
lems for more than 60,000 employees.
The control strategy would become a per-
manent part of Portland's air quality and
economic development planning.
The second part of the Portland program
is the development of a growth manage-
ment strategy for the area. Without it, the
area could soon face a moratorium on new
development.
The management study must first deter-
mine how much room in the airshed is ac-
tually available for growth by identifying the
potential emissions reduction by each facility
and the probable cost of the reduction. The
reductions will be ranked on a cost/benefit
basis.
Then, an analysis will be made of all the
major growth management alternatives, in-
cluding consideration of institutional, finan-
cial and regional factors. The growth margin,
emission offsets and land use/zoning alter-
natives as well as combinations of these and
other strategies will be considered.
A specific recommendation will then be
presented to the Air Quality Management
Committee, which is charged with managing
growth. Ultimately, a strategy for the
Portland area will be proposed as part of the
Oregon SIP.
In this way, local government will have as
much control as possible over decisions
about local development while progress
toward clean air is made.
Contact: Cynthia Kurtz, Office of Planning
and Development, 620 S.W. Fifth Avenue,
Room 610, Portland, Ore. 97204, (503)
248-4293.
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27
Air Quality Technical Assistance Grant Program:
Summary of City Activities
1 Receives Sec. 302 planning money from EPA
2Has developed a Comprehensive Economic Development Strategy (CEDS)
S Study
"Emission density zoning
Activity
1.2 1 1 1 1.2 1.2 1.2
Boston Br/Wat Eliz Buf/Erie C. Phil Chi M/St. P Port
Offset clearing (assemble
& distribute info, on X X X
sources of offsets)
Offset banking X X
Develop strategies to
create city owned off- X XX X
sets
Allocation of offsets
(city develops methodol- X X X X
ogy to distribute offsets)
Legal analysis of offset
issues x x
Rank ordering and
targeting industries for
technical & financial X X
assistance
Technical assis-
tance/target technology
(includes inventory of X X X X
pollution equip, in use,
analysis of potential
reductions)
Transportation improve-
ments intended to XX
create offsets
Financial assistance for
pollution abatement X X
equipment or tax inven-
tories
Small and medium
business emphasis A A A
One stop permits
Siting/Zoning (Air Quali-
ty info combined with X X
indust. siting info)
Case studies/strategies
applied to specific areas X X
of city
Emission fees
X X S S
XX S
X S
X S
X X S
X X
XX S
X X
X X
X
X
X X*
X
X
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28
Glossary
Air quality standard: (see NAAQS)
Ambient air: the surrounding air (see also
emissions)
Areawide sources of pollution: emissions
that do not come from a particular facility.
They can be mobile sources, such as cars,
or stationary sources, such as unpaved
roads.
Attainment area: an area meeting national
ambient air quality standards for a given
pollutant.
Carbon monoxide (CO): an invisible gas
often produced from incomplete combustion
in car engines.
Control technology: the equipment or pro-
cess change used by industries to control
pollutant emissions. The Clean Air Act sets
up a complex system to decide what kind of
technology is required based on availability
and cost.
Emissions: air pollutants discharged into the
ambient air.
Emission standard: a limit set for the
amount of a given pollutant a particular
source may emit into the air.
Hydrocarbons: substances such as gasoline
vapors, paint thinner and alcohol made of
hydrogen and carbon. Hydrocarbons react
with nitrogen oxides in sunlight to form
photochemical oxidants such as ozone.
Mobile sources: cars, buses, trucks,
airplanes.
National Ambient Air Quality Standards
(NAAQS): Federal standards that set max-
imum levels for several pollutants: ozone,
carbon monoxide, sulfur dioxide, total
suspended particulates, hydrocarbons,
nitrogen dioxide and lead. Primary standards
protect human health; secondary standards
protect public welfare (plants, animals,
aesthetics).
Nitrogen oxides: gases which result from
high temperature combustion processes or
from chemical plants.
Nonattainment area: an area dirtier than
NAAQS for a given pollutant.
Offset: a procedure whereby a new or ex-
panding pollution source in a nonattainment
area must arrange for the reduction of pollu-
tion from existing sources by more than the
pollution to be added. States decide how
much more will be necessary to maintain
progress toward meeting air standards.
Ozone (O3): The principal photochemical
oxidant.
Particulates (total suspended par-
ticulates): suspended particles in the air.
Prevention of Significant Deterioration
(PSD): a provision of the Clean Air Act that
protects already clean air by limiting the
amount of additional pollution that can be
emitted by new sources.
AU.S. GOVERNMENT PRINTING OFFICE 1980 O— 323-683/6349
-------
PSD increments: the amount of new pollu-
tion that can be emitted in a clean air area.
Reasonable further progress: areas must
reduce pollution by a given amount per year
until standards are attained by 1982 or 1987.
State Implementation Plan (SIP): a plan
prepared by States (in consultation with
local officials) which must be approved by
EPA, that outlines strategies for achieving
and maintaining the goals of the Clean Air
Act.
Stationary sources: non-moving polluters
such as manufacturing industries and utility
plants.
Sulfur oxides (SOx): gases which result
from burning of sulfur-containing fuels in in-
dustry and power plants.
Transportation Control Plan: part of the
SIP designed to make certain that traffic
emits the least pollution possible. Includes
measures to reduce reliance on private cars.
Transportation-related pollutants: prin-
cipally ozone and carbon monoxide.
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EPA is charged by Congress to protect the Nation's land, air and water systems Under a mandate
of national environmental laws focused on air and water quality, solid waste management and the
control of toxic substances, pesticides, noise and radiation, the Agency strives to formulate and
implement actions which lead to a compatible balance between human activities and the ability of
natural systems to support and nurture life
If you have suggestions, questions
or requests for further information, they
may be directed to your nearest
EPA Regional public information office
EPA Region 1 • JFK
Federal Bldg • Boston
MA 02203. Connec-
ticut, Maine, Massachu-
setts, New Hampshire,
Rhode Island, Vermont •
617-223-7223
EPA Region 2. 26
Federal Plaza • New
York NY 10007 . New
Jersey, New York, Puer-
to Rico, Virgin Islands •
212-264 2515
EPA Region 3* 6th
and Walnut Streets •
Philadelphia PA 19106
• Delaware, Maryland,
Pennsylvania, Virginia,
West Virginia, District of
Columbia • 215-597-4081
EPA Region 4 • 345
Courtland Street NE •
Atlanta GA 30308 •
Alabama, Georgia,
Florida, Mississippi,
North Carolina, South
Carolina, Tennessee,
Kentucky « 404-881 - 3004
EPA Region 5 « 230 S.
Dearborn • Chicago IL
60604* Illinois, Indiana,
Ohio, Michigan, Wiscon-
sin, Minnesota »
312-353-2072
EPA Region 6. 1201
Elm Street • Dallas TX
75270 • Arkansas, Loui-
siana, Oklahoma, Texas,
New Mexico •
214-767-2630
EPA Region 7 . 32".
East 11th Street •
Kansas City MO
64106. Iowa, Kansas,
Missouri, Nebraska «
816 374-6201
EPA Region 8 • 1860
Lincoln Street •
Denver CO 80295 « Col-
orado, Utah, Wyoming,
Montana, North Dakota,
South Dakota •
303-837 3878
EPA Region 9. 215
Fremont Street» San
Francisco CA 94105 •
Arizona, California, Hawaii,
Nevada, Pacific Islands
• 415-556-1840
EPA Region 10. 1200
Sixth Avenue • Seattle
WA98101 .Alaska,
Idaho, Oregon, Washing-
ton • 206-442-1203
S>
o
t>
en
o
m > ~0 m ~n "U
-
------- |