United States
                    Environmental Protection
                    Agency
                    Off ice of               OPA 101/9
                    Public Awareness (A-107)     April 1979
                    Washington DC 20460
vvEPA
Environmental
Information
 CAN AMERICA
 HAVE GROWTH
 AND CLEAN
 AIR?
 Questions
 and Answers
 about Growth
 and the Clean
 Air Act
     Will the Federal Clean Air Act stop or restrict
growth in this country?

     That question is being asked more and more frequently.
The concern centers on economic development and stems
from a lack of full understanding of certain sections of
the Act and of the implementation of those sections.  One
concern is the prohibiting of new construction whtch
affects air quality in a State which does not submit an
approvable Clean Air Plan.*  Such Plans, updating how a
State will control pollution to achieve air quality standards,
must be approved by the U.S. Environmental Protection Agency
(EPA).  A second concern is the potential loss of Federal
assistance for new highways, air pollution control, and
wastewater treatment facilities if States fail to submit an
approvable plan.  A third concern is based on the possibility
of difficulties and delays that might occur in getting permits
to build new industrial projects even where approved plans
exist.

     Congress passed major Clean Air Act Amendments in
1970 recognizing that expanding urbanization, industrial
development and growing use of motor vehicles in this
country was increasing air pollution to levels that
endangered public health and public welfare. To protect
the public health, the Act called for a national program
of pollution emission control and air quality management.
To ensure continued success of that program, Congress in
1977, set new and more stringent requirements for pollution
controls that will require creative solutions and coopera-
tive efforts on the part of States, local governments and
all  segments of the American society if air pollution is
to be reduced to acceptable levels.

     Because of the current concern for a healthy economy
and high employment and because of the complexities of the
Clean Air Act, the law is viewed by some as a possible
deterrent to continued growth, particularly urban growth.
                    *A State Implementation Plan

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     EPA, however, believes that with the policies and guidelines that have been developed
and through its continuing efforts to work with the States and local  communities, the Clean
Air Act can achieve the clean air goals set by Congress without stifling essential growth.

     This fact sheet has been prepared to answer some of the most pressing questions about
growth and the Clean Air Act.

Q.  Aren't the Federal law requirements for States to revise thejr Clean Air Plans impossible to meet?

A.  Congress required States to revise their Clean Air Plans for all  areas where the health-
based ambient air quality standards are not being met.  These revisions, call for (1) adoption
of all reasonable control measures on stationary sources and (2) for inspection and maintenance
(I/M) for in-use vehicles, and/or other transportation control measures.  EPA has worked with
the States in interpreting these requirements and believes a workable program to meet the
requirements is possible by any State that makes a good faith effort.

     For stationary sources which contribute to the ozone (smog) problem States must adopt
regulations on a phased schedule after the initial submission, and continue to study and
develop measures to control non-traditional sources of particulate matter such as fugitive dust.

     For  I/M, where it  is necessary, the Plan submitted must contain ohly the necessary legal
authority and a commitment to develop an I/M system.  That system does not have to be operational
until 1981 or 1982, depending on the kind of system selected.  For transportation control measures,
State and local governments must establish a transportation air quality process and commit to
implementation of  reasonable measures.

Q.  Won't it be impossible for  States to demonstrate attainment of the air quality standards
in many of the worst  polluted'areas ?

A.  The most difficult  pollutants to control will be carbon monoxide and ozone.   Congress recognized
this and  provided  additional time—until 1987--for States to meet these standards.  During this
period substantial reductions will be achieved by emission controls on new cars under the Federal
Motor Vehicle Control Program.  Where the State can show  that  it uses all reasonable available
control measures  and  still cannot achieve the standards,  the Act requires only  that the State commit
to such  reasonable measures  and then identify what additional  control measures  could oroduce the
additional required emission reductions.  However, the Act does not require  the State to make a
commitment in 1979 to implement these additional measures.  A  final commitment  does not have to be made
until 1982, giving the  State and local governments'ample  time  for further study and consideration.

Q.   Aren't  the  so-called "no-growth" sanctions  inevitable in  many areas?

A.   No.   The Act  says that  unless  an approved  Clean Air  Plan  is  in place  by  July  1,  1979,  no  permit
applications  for  major  new  construction  can  be  approved.  Also, certain types  of  Federal  assistance
 including grants  for  highways,  air pollution  control  and  wastewater  treatment  facilities  may  be with-
hpld.  Congress1  intention was  to  emphasize  the  serious  need  for State  and  local  governments  to revise
their Plans  as  quickly  as  possible and to  encourage  the  public's involvement as well as  that  of the
 industrial  community  in developing an  adequate  plan  revision.   EPA established criteria  that  are
reasonable  and  that can be  achieved  by a good-faith  effort.
      If  a State Plan  is late or is inadequate  and  sanctions  are  imposed,  all industrial  growth  will  not
stop automatically.   Important  to  remember are:

           *   All  construction  permits  that are  submitted  by  June 30,  1979 will  continue
              to be processed;

           *   The  "no-new permit"  restriction  continues only  until the State  does  submit
              an aoprovable  plan;

           *  The  "no-growth" sanctions for particulate matter of sulfur oxides generally
              will not affect a  broad arpa  because  violations  of these pollutants  tend to
              be more  localized.
           *  Federal  assistance for  highways  and air  pollution control  will  not be  withheld
              where reasonable  efforts  are  being  made  to  submit a plan.

 Q.   Is all  growth prohibited in nonattainment areas?

 A.   No.   EPA addressed the problem of  new  sources  in  nonattainment areas  with  the Emission Offset Ruling
 developed in December 1976.   This  allows new construction in dirty air  areas if there are compensating
 emmission reductions  from existing sources and if  all  reasonable available  control  measures  are used  on
 the  new  source.   During the two years  the  ruling has  been in effect  it  has  worked well.   A few  delays
 have occurred,  but only until  adequate offsets were  found.   New construction has  continued to be

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approved in most areas of the country.   The offset concept is being used by many States to provide
for new source growth in their revised Plans.   In addition to using the offset concept, States may plan
for the future use of their air through providing a quantified margin for emission growth in these plans.
Such a margin is achieved by adopting requirements to reduce emissions below the level  necessary to meet
the standards.

Q.  Is it true that the offset concept discriminates against areas that have done the most to clean up
pollution since additional control  of existing sources is more difficult?

A.  This is true for just a short time until the States complete their revised plans to include all
reasonable available control measures.   Once the Plans are revised, the baseline for determing offset
credit should be relatively uniform nationally.

Q.  Won't EPA's Prevention of Significant Deterioration Program (PSD) adversely affect the country's
energy program and prevent construction of many  new coal-fired power plants?

A.  The Clean Air Act calls for keeping clean  air areas clean and requires EPA to set regulations for
three classes of areas.   The air quality in Class 1  areas which include almost all national  and
international parks and wilderness  areas must  remain virtually free of new industrial pollution and
no new sources are permitted.  A limited number  of plants are allowed in Class II areas and  a somewhat
greater number'of Class III.  In no area, however, will air pollution be allowed to rise above the
health and welfare based standards.

     The PSD requirements call for  a preconstruction review of many major new construction that will
affect air quality.  The review insures that (1) the best control technology is used to control
emissions and (2) that the new source will not exceed certain amounts of air quality deterioration
that are allowable.

     The PSD process focuses on a relatively few major new and modified sources.  Since it began in
mid-1975 some 200 PSD permits have  been approved:  only two have been denied.  Permits have  been issued
for some 60 utility boilers totaling 35,000 megawatts since the start of the program.  The average
processing time was six months.  Eight of the  proposed sites are within a Class I area and one location
for two units totaling over 1,300 megawatts is within 15 miles of a Class I area in Florida.  In
addition, two new refineries totaling 435,000  barrel-per-day capacity plus numerous refinery expansions
have been approved to date under the PSD program.

Q.  'What sense does it make to require PSD permits for sources that want to locate in nonattainment
areas?

A.  A PSD permit is not required if a source is  subject to the Emission Offset requirements  and demonstrates
that it will not affect a clean air area (and  this has been open for public comment).  However, a source
that wants to locate in a nonattainment area should not automatically be exempt from PSD because (1) there
could be a clean air area located within the nonattainment area or (2) pollutants from sources in such
nonattainment areas could affect clean air areas by long-range transport.

Q.  Don't the new source permit requirements under the Clean _Ai'_r_Act create substantial and  costly delays
to new industry?

A.  The experience to date simply does not indicate that there have been coslty delays.  States issue
as many as 40,0000 new construction permits a  year.   Most are for small and medium size sources and the
review is straightforward and rapid with few delays or denials.

     Under the PSD program the average processing time for permits issued as of October 1978 was less
than six months.  Many of industry's concerns about future PSD permit delays center on the requirement
for one year of air quality monitoring and on provisions which allow EPA uo to one year to act on a
permit application.

     In regard to the monitoring requirement,  this is expected to be necessary in only a few situations.
As for the processing time, EPA has and will continue to process most PSD permits in much less than the
one year allowed.  In any case it  is expected that many States will be taking over the PSD program and
the PSD permit can be issued as part of the normal permitting procedures.

     Those who plan new construction projects can accelerate the process by incorporating the permitting
process into the early planning stages of the project and by consulting with the appropriate EPA
Regional Office before submitting a permit application to first determine what requirements  are applic-
able and what information is required.

     States qenerally are implementing the Emission Offset Ruling and experience shows that most new
sources have been approved.  Delays have been minor where offsets 6re from within the facility beinq
expanded or where a company has other plants in the area to provide the offsets.  The most substantial

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        delays have come where external  offsets were needed.  Such delays will be  fewer
        in  the future,  however, as  States  and  industry become more familiar  with this
        somewhat  novel  concept.
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     Agency                     Washington DC 20460 .
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