DRAFT
CRITIQUE OF
GUIDELINES FOR PREPARATION OF
A 10-YEAR AIR QUALITY
MAINTENANCE PLAN
MAY, 1974
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Research Triangle Park, North Carolina
alan m. voorhees & associates, inc.* TRANSPORTATION & URBAN PLANNING
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CRITIQUE OF THE
GUIDELINES FOR PREPARATION OF A
10-YEAR AIR QUALITY MAINTENANCE PLAN
DRAFT REPORT
May 31, 1974
Prepared by
ALAN M. VOORHEES & ASSOCIATES, INC.
Westgate Research Park
McLean, Virginia 22101
Contract N. 68-02-1388
EPA Project Officer: Thomas Donalson
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Water Programs
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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INTRODUCTION
A. Based on Problems in Attempting to Follow in
Actual Prototype Plan Development
B. 10-Week Period
II. REVIEW AND ANALYSIS OF DRAFT EPA GUIDELINES DOCUMENTS
A. Documents Reviewed (Annotated Bibliography)
B. Analysis of Each Guidelines Document
C. Suggested Additions
D. Suggestions for a Similar Document in 5 Years
III. CRITIQUE OF EPA APPROACH TO AIR QUALITY MAINTENANCE
A. Overview
B. Unresolved Issues
C. Recommendations for Resolution of These Issues
and Alternative Approaches
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CHAPTER I
INTRODUCTION
A. GENERAL
The purpose of this report is to present a critique of the U.S. Environ-
mental Protection Agency's (EPA) guideline documents available for use
in the development of ten-year Air Quality Maintenance Plans (AQMP).
This critique is part of a larger Task Order which requires the preparation
of a sample AQMP for the St. Louis, Missouri-Illinois Air Quality Mainte-
nance Area (AQMA). The critique requires an analysis of the scope,
content, potential applicability, and usefulness of the available
guideline documents. As such, the critique will be based primarily on
problems that have been encountered in attempting to use the guidelines
in the development of the sample AQMP for St. Louis. This approach was
taken because it was felt that the critique of the guidelines should be
based on attempting to actually use them rather than on a theoretical
basis. The results from such an approach would produce much more
meaningful results in terms of the applicability and usefulness of the
guidelines.
The overall project is scheduled for 10 weeks. Because of the limited
time duration, many of the procedures suggested in the guidelines to be
accomplished in a sequential order had to be completed along a parallel
time frame. This situation has caused assumptions to be made that would
not occur during the development of the actual plan. These assumptions
will be noted in the critique.
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B. ST. LOUIS AREA BACKGROUND
In order to more fully understand the comments contained in this
critique, it would be helpful to point out some background information
about the St. Louis area. St. Louis was chosen as a sample city for
AQMP development principally because it is an interstate region. In
addition, the jurisdiction of the various federal agencies emanate from
two regional centers: Chicago for the Illinois portion, and Kansas City
for the Missouri portion. This means that all planning review must be
done by two federal regions, depending upon which is involved.
The St. Louis area is composed of seven counties and one independent
city. More than 400 taxing agencies exist in the metropolitan area. A
total of over 300 municipalities exist, each with their own zoning power
(Illinois also has a law which allows for zoning by municipality of the
land up to 1.5 miles outside its boundaries). In addition to the munici-
palities, over 100 other taxing bodies exist. These consist of counties,
special districts, school districts, etc.
Planning for the area is done by a variety of agencies. The A-95 and 3C
agency is the East-West Gateway Coordinating Council. It is a voluntary
planning agency which has no power of implementation. Any of the member
governments can withdraw from the Council at anytime. The three Illinois
counties have formed the Southwest Illinois Metropolitan Area Planning
Commission which does the planning for the three counties. The
City of St. Louis, St. Louis County and St. Charles Counties in Missouri
have active planning agencies with professional staff who do the planning
for these governmental agencies. Franklin County has a part-time planner
who also works in the county engineer's office. Jefferson County has no
planning and, in 1971, eliminated its zoning ordinance. In addition to
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these county agencies, each community has a planning board which may or
may not have professional staff. The larger communities do, the smaller
areas don't. The smaller communities usually contract with private
consultants or, in St. Louis County, with the county planning department
for their planning needs.
Politically, the area is also quite diverse. Illinois has a Democratic
administration; Missouri a Republican. The City of St. Louis is Democratic;
St. Louis County is Republican. Since the 1920s, several attempts have
been made to form an areawide type of government between the City of St.
Louis and St. Louis County. All attempts have failed by wide margins at
the polls.
With this local information in mind, greater insight may be obtained from
the comments in the critique.
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CHAPTER II
REVIEW AND ANALYSIS OF DRAFT EPA GUIDELINE DOCUMENTS
A. DOCUMENTS REVIEWED
Annotated Bibliography of EPA Guideline Documents
Mechanics of 10-Year Plan Preparation and Implementation. Final Report
Task 1. Guidelines for Preparation of 10-Year Air Quality Maintenance Plan,
March 8, 1974, prepared for U.S. Environmental Protection Agency,
Research Triangle Institute.
This document is primarily introductory, presenting an overview of the
requirements placed upon the individual states for the development of an
Air Quality Maintenance Plan (AQMP). It deals with those areas within
each state which currently or in all likelihood will exceed the National
Ambient Air Quality Standards (NAAQS) within the 1975 through 1985
period. These areas will be identified by the states as Air Quality
Maintenance Areas (AQMA). Included is a general summary of the purpose
of the AQMP and a schedule for the plan development.
Although the AQMP is primarily the state's responsibility, coordination
efforts between state and local governments are stressed as vital to the
development and implementation of the AQMP. Five alternative modes for
the division of this responsibility are presented along with general
conditions warranting their use. These are:
o The State agency conducts all air quality maintenance planning
and implementation activities within the State.
e The State agency participates with local agencies in preparing
and implementing the AQMP.
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e The State agency conducts planning operations, but delegates
implementation activities to local agencies.
Planning is done jointly by State and local agencies; implemen-
tation is done by local agencies.
o Planning is done jointly by State and local agencies, but all
implementation is done by State.
Since each AQMA is unique, it will require a tailored approach.
When interstate management situations arise, the approach is formation
of a task force on interstate cooperation to define the coordination
problem, determine the appropriate course of action, and establish the
arrangements needed. Two methods of coordination are noncomoactual and
compactual. In addition to the interstate coordination, methods of
cooperative working relationships between the states are suggested.
These include data sharing, utilization of joint personnel and equip-
ment, centralized legal research, etc.
The report includes a step-by-step procedure for preparing a 10-year
AQMP. The outline suggests a plan preparation sequence, generally
explaining each task in the action sequence, a time schedule for the
plan, an applicable bibliography of EPA guidelines that should be used,
and a general plan format indicating the items to be included. A short
discussion is included on procedure and context of the state and local
plan review.
The document was developed to assist states with:
Plan Development
Intra- and Intergovernmental Coordination
o Plan Review
Institutionalization of the Air Quality Maintenance Process, Draft
Report, Task 2, Guidelines for Preparation of 10-Year Air Quality Mainte-
nance Plans. April, 1974, prepared for U.S. Environmental Protection Agency,
Research Triangle Institute
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This document is intended to assist State and local governments in the
identification of the relationship between the AQMP and other community
goals, plans, and activities. It is also intended to suggest ways in
which the AQMP and its development and implementation can be integrated
into overall community activities. This takes the form of functional
programs with which the AQMP must be coordinated, the existing framework
available for this coordination, and the suggested process for the
implementation of the air quality maintenance for an AQMA.
The functional programs requiring coordination can be separated into
three basic areas: environmental, transportation, and land use. The
programs identified are:
ENVIRONMENTAL
Air Pollution Control
e State Implementation Plans (SIP)
e Stationary Source Review
o New Source Performance Standards
e The Federal Motor Vehicle Control Program (FMVCP)
e Transportation Control Measures
e Indirect Source Review
Water Planning and Control
Federal Water Pollution Control Act 1972 as amended
Section 303
Section 208
Section 201
Section 402
Solid Waste
Federal Solid Waste Disposal Act, 1970 as amended
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Other Programs
Noise Abatement
TRANSPORTATION
Federal-aid Highway Act of 1970
This act must be interfaced with air quality maintenance activities
because of its effect on the growth and development patterns of
urban areas due to its making funds available for the construction
of transportation facilities.
LAND USE PROGRAMS
Coastal Zone Management Act of 1972
National Land Use Policy
Legislation on national land use is currently in Congress and no
final action has been taken. Should the legislation come about in
the near future, it will have an impact on the AQMPs required by 1975.
The coordination of these various programs should be at the regional
level. Two coordination mechanisms are discussed: the A-95 and the
Environmental Impact Statements (EIS). Two coordinating agencies are
also discussed: the Regional Planning Commission (RPC) and the Council of
Governments (COG). Limitations of these two agency types are presented.
The implementation mechanism is briefly discussed, but reference is made
to the Task 1 report for a more detailed discussion. Included, as a
supplement, is a discussion of legal constraints and general
considerations.
There are two legal constraints:
e The institutional structure which must provide legally enforce-
able procedures for ensuring the attainment and maintenance
of NAAQS.
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9 The structure and arrangements for plan development and implemen-
tation which must be such that ultimate responsibility rests
with the State.
The document was developed to provide an impetus to State and local
decision-makers faced with air quality maintenance requirements. In
this manner, they could determine specific institutional arrangements
and roles tailored to their own jurisdictional needs.
Maintenance Strategies, Draft Report, Task 3. Guidelines for Preparation
of 10-Year Air Quality Maintenance Plan, May 1974, prepared for U.S.
Environmental Protection Agency, Research Triangle,Institute and PEDCO
Environmental, Inc.
This document is intended to describe several alternative administrative
and technical approaches for the maintenance of air quality standards in
designated AQMAs. It suggests a general procedure for selecting approaches
which are best suited for a particular AQMA. These procedures assume,
however, that certain detailed projections are available from an analysis
of the AQMA. The method for conducting this analysis is presented in
another guideline document. The evaluation procedure for selecting a
maintenance strategy uses the results of the analysis and other infor-
mation to screen potential measures for:
Administration feasibility
Contributing source control effectiveness
o Compatibility with other control measures
The measures are then grouped as to their capability of maintaining air
quality standards and are selected using cost and social acceptability
as primary considerations.
The report indicates that two basic types of maintenance measures are
available: administrative and emission control.
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Initial Screening
e Project Emissions and Ai. Quality
Estimate Emissions to be Prevented
0 Estimate Further Reduction from Existing Sources
o Determine Potential Source Category Condi dates
o Determine Maintenance Measure Applicability
o Determine Contribution to Emission Reduction and/or
Air Quality Impact
o Determine Compatibility of Measures
o Develop Alternative Maintenance Measures
Alternative Maintenance Strategies Evaluation
o Social Effects
o Economic Effects
o Select Preferred Maintenance Strategy
The report then explains in greater detail the measures that could be
used for the maintenance strategies.
Administrative Measures
Emission Allocation Procedures
e Regional Development Planning
Emission Density Zoning
a Zoning Approvals and Other Indirect Regulatory Controls
e Transportation Controls
Emission Charges
o Transfer of Emission Source Location
e Indirect Source Review
e Environmental Impact Statements (EIS)
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Emission Control Measures
New Source Performance f'andards
Revision of Existing SIP Control Measures
Phaseout or Prohibition of Emission Sources
Fuel Conversion
Energy Conservation and Utilization
o Combination of Emission Sources
e Special Operating Conditions
o Stack Height Regulations
o Control of Fugitive Dust Sources
The report then presents a technical procedure for assessing the interaction
between the various control measures. Legal authority requirements are
also presented. This authority eminates from the states police power
and comes from four legislative areas: zoning, direct regulation,
licensing, and taxation.
Relation of Land Use and Transportation Plans to Air Quality, Draft
Report, Guidelines for Preparation of a 10-Year Air Quality Maintenance
Plan, April 26, 1974, Alan M. Voorhees and Associates, Inc. prepared
for U.S. Environmental Protection Agency.
The purpose of this document is to indicate the relationship between
land use and transportation planning and air quality. The document accom-
plishes this end by first explaining what the land use plan is and how it fits
into the overall comprehensive planning program for an AQMA. The land
use plan is then shown to be a map for potential patterns of air pollution.
The sources of this pollution can be put into three categories: Point,
Source, Line Source, and Area Source. Data needs are then presented
which will be used for more detailed analysis of these various sources
and their relationship to land use. A discussion is then presented on
the power that land use planning has in terms of implementability of the
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plan. Two mechanisms are mentioned as needed to implement the plan:
mechanics of enforcement and the integrative aspects of the plan as it
relates to other components of the comprehensive plan.
In line with the integrative aspect of the plan, the "3-C Process" is out-
lined. This process comes from the wording of the Federal-aid Highway Act of
1962 for projects approved after July 1, 1965 in urban areas of more than
50,000 population. It required that a Continuing, Comprehensive transporta-
tion planning process must be carried on Cooperatively in the state and
local communities. By its very nature this process requires integration
of all planning activities.
A generalized methodology is presented for the consideration of air
quality within the overall planning process. This process should include:
o Land Use Planning
e Transportation Planning
e Social Planning
e Environmental Planning
Other Planning Aspects
Tools and information requirements are presented that are needed to
relate land use to air quality. Some of these requirements are illus-
trated in a review of related studies that have been completed in various
sections of the country. A series of conclusions are drawn with regard
to the state-of-the-art of relating land use to air quality for AQMAs.
The last section of the document presents a procedure for utilizing
existing land use and transportation plans to project and allocate
emissions. This procedure is based on a set of assumptions and criteria
outlined in the document. A general approach is given for pollutant and
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source problem definition and for problem area and time period analysis.
A methodology is then presented for projecting and allocating emissions
and/or air quality in AQMA's. This methodology is for four source
categories:
e Area Source Emissions
Power Plant Emissions
0 Point Source Emissions
o Mobile Source Emissions
The document concludes with a summary. It states that the methodologies
described in the document represent an approach which is considered to
be applicable in most urban areas within the period for the plan analysis
and development. It may be expected that each area will make modifica-
tions to the method described, based on local conditions. It may also
be anticipated that refinements will be made, both to the plan and to
the guidelines over time.
Manual of Instruction for Projecting County Emissions. Preliminary Draft.
May 15, 1974, Booz-Allen Hamilton.
This document was not received in time to be placed in the annotated
bibliography. However, its contents were reviewed for use in the course
of performing this Task Order.
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B. ANALYSIS OF EACH GUIDELINE DOCUMENT
Task 1 -- Mechanics of 10-Year Plan Preparation and Implementation
As noted in the annotated bibliography, this document was to provide the
states and local agencies with alternative methods of developing the
coordination needed for plan preparation and to provide a sequence of tasks
required for the plan preparation. Five modes were indicated as possible
methods of coordination between state and local governments with regard to
plan preparation and plan implementation. In addition, situations were
presented for when these modes would be applicable. The five modes are
as follows:
e The state agency conducts all air quality maintenance planning
and implementation activities within the state.
e The state agency participates with local agencies in preparing
and implementing the AQMP per a mutual agreement.
o The state agency conducts planning operations but delegates
implementation activities to local agencies.
o Planning is done jointly by state and local agencies; imple-
mentation is done by local agencies.
e Planning is done jointly by state and local agencies, but all
implementation is done by state.
These five modes were applied to the situation in St. Louis and all were
found not to fit the local situation. The principle reason was the inter-
state nature of the area and the lack of implementing power given to the
regional agency, East-West Gateway Coordinating Council. The Council is
the logical agency to do the planning and implementing for St. Louis;
however, because of its voluntary nature, implementation of the AQMP
would be impossible. Discussions with East-West Gateway staff indicated
that they are willing to undertake such work, but require Federal directions,
instructions, and most importantly, additional funds. These would be
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needed for the incorporation of the AQMP into the overall comprehensive
planning program. Based on a similar effort in Baltimore, funding for
such an undertaking could be up to 50<£ per person depending upon indus-
trial and municipality complexities.
The report then indicated approaches that could be used for coordination
within an interstate AQMA, such as St. Louis. Two approaches were
presented: noncompactual mechanisms and interstate compacts. In addition,
it was suggested that an interagency task force on interstate coordination
be formed. Given the multiplicity of agencies within the St. Louis AQMA,
this task would be very time consuming and the task force would be extremely
large and unmanageable. An interstate compact would probably not work in
St. Louis, because it would be a regional type of government. This, in
the past has been unacceptable at the polls especially given the failure
rate which is not palpable in today's climate. It appears that for
St. Louis, a noncompact type of solution would be required. Both states
could mutually agree on both the problem areas and the implementation
methods.
One possibility that has not been discussed in this document is the
formation of special districts within each state and then the coordi-
nation of the two districts for the purpose of implementing the AQMP.
Both sides of the river have special districts presently which traverse
city and county boundaries. In Missouri there is the Metropolitan
Sewer District, and the Zoo-Museum District. In Illinois, there is
the East Side Levee and Sanitation District. This indicates that
districts could be formed and then given the power to implement the
AQMP and to coordinate this implementation between themselves. This
implementing power could be through zoning or taxation. Planning
would remain the function of the East-West Gateway Council.
The remainder of the discussion on coordination seems relevant and
could be carried out within the St. Louis AQMA.
*L
1"
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The second section deals with the actual sequence of tasks required to
prepare an AQMP.
One of the required components of the AQMP, as shown on page 24 of the
Task 1 Report, is a description of resources available to the state
and local agencies over the 10-year period. Such a commitment of
resources by any agency exceeds normal funding and administrative
planning horizons and would probably be no more than conjecture if it
were submitted.
Several of the agencies that might participate in implementation of
parts of the SIP in St. Louis would do so in a manner for which it
would be difficult to estimate manpower allocations. Also, the air
pollution control agencies will have many ongoing programs that are
included in the SIP but are not described in the AQMP. Thus, the
values submitted would be subject to many different interpretations
and could not be used to evaluate the adequacy of the resource commitments,
For most maintenance measures, submittal of compliance timetables for
emission source categories would not be applicable (page 24). This
requirement should be enlarged to include timetables for initiation of
new regulatory measures, such as an emission density zoning regulation
or designation of critical environmental areas.
Also on page 24, the draft guidelines state that if the timetable for
attaining NAAQS is different than shown in the SIP, the difference
must be explained in the AQMP. Unless an extension is officially
requested from and granted by the Administrator, the states cannot
change the attainment dates prescribed in the Clean Air Act. Nor do
they have authority to establish new attainment dates if they miss the
required ones. Presumably, attainment must be achieved as soon there-
after as possible.
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IFf
The time schedule shown in Figure III-l does not seem to provide
enough ime to prepare the required plan. Therefore, the responsible
agencies are left with options such as:
e refuse to prepare the plan under the indicated schedule
e assemble material necessary for submittal and neglect inter-
agency coordination and careful selection of optimum mainte-
nance strategy
select a strategy without the quantitative analysis described
and attempt to justify it with data assembled subsequently
Even with considerable contractual assistance and a major commitment
of agency effort, the proposed schedule does not appear sufficient to
permit the necessary interactions and checking of indirect effects
that the guidelines advise.
Given the choice between 1) developing the AQMP in an incomplete
manner in order to meet a court-ordered deadline or 2) developing more
meaningful AQMPs in a more realistic schedule one would obviously
choose the second option. Therefore, the June 18, 1975 submittal data
could be relaxed. However, if a decision is to be made by EPA to
relax the schedule, it would be more effective if if were done as part
of the guidelines rather than submitting the AQMPs next April or May
after the agencies have already opted for one of the three alternatives
described above.
Task 2 -- Institutionalization of the Air Quality Maintenance Process
As mentioned in the bibliography, this document is intended to assist
State and local governments in the identification of the relationship
between the AQMP and other community goals, plans, and activities. It
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is also intended to suggest ways that the AQMP and its development and
implementation can be integrated i^to and coordinated with overall
community plans, goals, activities, and institutional arrangements.
The document is intended to provide an impetus to State and local
decision-makers faced with air quality maintenance requirements to
determine for themselves the specific institutional arrangements and
roles suitable to their own jurisdiction.
Given the above two intentions, the document does not present these
intentions to the reader. The document appears to be more of introduc-
tory material to the guideline document on land use and transportation
relationships to air quality. No information is presented to aid the
state and local decision-makers to make a decision as to which institu-
tion, federal program, and review process would be the most useful in
various situations. The institution, federal program and review
processes are presented and explained, but their situations application
is omitted.
The document could have been more meaningful if some hypothetical
situations had been set up and the functional programs and coordina-
tion framework had been applied to the situations. This application
would have been of much value to the state and local decision-makers.
They could have seen how these programs and frameworks would apply in
a hypothetical situation and then would have been able to modify this
application to meet their own AQMAs specific needs. An area like St.
Louis with a multiplicity of agencies and two states would have dif-
ferent needs than an intrastate AQMA such as Denver or San Diego.
Reviewing the final chapter on the implementation of the air quality
maintenance procedures the same lack of any application to hypothetical
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situation is noted. This chapter could have been the very heart of
the guideline document. However, few if any situations are set up
that the State and local agencies could use as a basis for selecting
the aspects of the various institutional arrangements which would be
appropriate for their particular AQMA.
Task 3 Maintenance Strategies
This document is intended to describe various alternative administrative
and technical approaches for maintaining air quality standards in a
designated AQMA. A procedure for selecting the approaches best suited
for the particular AQMA is also included.
Two stages for selection are presented; an initial screening for
feasibility and an evaluation of the feasible alternatives on a cost-
effectiveness and social acceptability basis. The first step of the
initial screening requires projection of emissions and air quality to
the years 1980 and 1985. When this step was applied to the St. Louis
AQMA it was discovered that no agreement existed between the data that
the EPA had in NEDS and the data that the state and local agencies
said should be in NEDS. This was for the existing emissions inventory.
A base line set of data must be agreed to before projections to 1980
and 1985 can be made. At present there is no data base generally accepted
by local agencies in St. Louis. Once this data base is agreed upon,
however, the projection could be made.
The second step is to estimate emissions which are to be prevented.
This estimation is accomplished by comparing the projection emissions
to the NAAQS. The problem areas are then noted. Applying this step
to the St. Louis situation resulted in discovering that many of the
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existing pollutant sources have been granted variances by the local
and state air pollution agencies. This situation will make compliance
of NAAQS more difficult for these future sources will be required to
have more stringent controls so that the air quality levels will be
maintained. These controls and variances could be contested as being
discriminatory in the courts.
The remaining steps should pose no great problem provided the data
base and the projections are sound and are agreed upon by the state
and local agencies.
The second stage of the selection indicates that an evaluation must be
made of the alternative maintenance strategies which passed the screening
process in stage one. This evaluation is done on two levels: the
social effects and the economic effects. While it is quite difficult
to ascertain the effects of air quality control measures on the social
and economic fiber of an AQMA, an attempt will be made to indicate
some of the impact that would probably be felt in St. Louis.
The first area to be discussed is the social effects. Perhaps the key
to the effect of the maintenance program is contained in the two
following sentences quoted from page 1-12 of the document:
Politicians stake their political lives on what they perceive to
be what the public desires. They, therefore, are in a position
to assess the social acceptability of proposed maintenance measures.
These two sentences basically sum up the situation in the St. Louis
AQMA not only for the social effects but also for the economic effects.
It may be assumed that political leaders will not accept a plan that
will be a detriment to his political life. Should a maintenance plan
be produced that would require massive changes in the socioeconomic
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fiber of the AQMA, no politician would back it unless the plan had the
overwhelming support of the majority of his constituents. Should a
large industrial plant wish to locate in the AQMA, most politicians
would welcome it with open arms because of the economic impact it
would have on the community. Variance from the NAAQS might very well
be granted if meeting the standards would disuade the plant from locating
in the AQMA. A local example might further serve to illustrate the
point.
St. Louis has a large automobile assembly industry. In fact, it is
second only to Detroit as an automobile assembly center. The Volkswagen
Company has been looking at possible sites for the location of a new
assembly plant within the U.S. St Louis was one of the six areas that
was reviewed as a possible location for the multimillion dollar facility.
Should St. Louis be chosen as the plant site, every possible effort would
be made by the local leaders to ensure that the plant be built. This
effort could include a relaxation of the NAAQS for the AQMA and a
bending of the control measures in the AQMP. The economic impact of
5,000 to 10,000 jobs could be overwhelming. Possible health hazzards
could be the only reason for imposing strict control. It could be
unpolitical for any politician to be against such an economic boost
to the area, barring any health hazzard problems.
This illustration indicates that when all the dust settles, the AQMP
may, in fact, become a political item. This is because the plan will
have a major impact on a portion of the community's life that is
extremely sensitive to political pressure: jobs and taxes.
Chapter II of the document deals with nine possible administrative
measures for controlling emissions. A short discussion follows on
each.
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Emission Allocation Procedure This procedure has possible appli-
cation in the St. Louis AQMA because of the numerous governmental
bodies in the area and because this measure is somewhat general. As
noted in the chapter, however, the main problem with this measure is
that it assumes that the assimilative capacity of the ambient air in
the region is known. As of yet, operational techniques for determ-
ining this capacity do not yet exist.
Another problem with this procedure as applied to the St. Louis AQMA
is that a major local data collection and planning effort would be
required on a subcounty or submunicipality basis. Most of the existing
detailed planning effort in St. Louis is being completed on a county
or municipality basis.
A third problem would be determining which agency in St. Louis should
be charged with implementing the plan and whether or not this agency
would have police power cross state boundaries.
Regional Development Planning This measure implies that the AQMP be
made part of the overall comprehensive planning process of an AQMA.
This was discussed with the East-West Gateway Council staff in St.
Louis. They agree completely with the concept since they are the only
regional planning agency for St. Louis. Their main concern was that
they had received no directives from the federal agencies that the
AQMP should be included, nor had they received any guideance as to
what was to be included in the plan or how to develop the plan. Most
importantly, they were concerned about funding for the additional
effort required to develop the AQMP. Once these items of concern are
addressed the Council will be more than ready to include air quality
planning in the overall comphrensive planning program for St. Louis.
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Emission Density Zoning -- This type of zoning implies that emissions
of a pollutant be limited to prescribed levels within a defined spatial
area. This zoning would be administered by an air pollution control
agency in conjunction with planners and zoning administrators.
In applying this measure to the St. Louis AQMA, the major problem is
the multiplicity of local communities that exist within each county.
St. Louis County has 93 municipalities each with its own zoning ordinance.
The County does not have the power to override local zoning. In addition
the bi-state nature of the AQMA and the fact that many of the major
pollutant sources are located along thestate boundary. This type of
measure could only be applied at a municipal level in St. Louis and
could not be applied on a regional scale.
Zoning Appraisals and Other Indirect Regulatory Controls -- All of the
measures indicated in this set of controls would again be implementable
in St. Louis only on the local level. Regional implementation would
be virtually impossible. Any regional controls would give the local
citizens the feeling that a "super government" was taking over and
they would be losing control of their own "destiny". As b-3rkground
for this statement, the City of St.' Louis and St. Louis County were
politically seperateJ in 1876. Since -;he 1920's five attempts at some
type of consolidation have been made and all have failed at the polls
by wide margins.
Transportation Controls -- A transportation control plan is being
developed for St. Louis at the present time.. It should be input to
any AQMP developed for the area. However, it will not be workable
until Fedruary, 1975.
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Emission Charges -- This measure proposed placing a charge on the pol-
luter as part of his cost of doina business or of consuming goods.
It is also suggested that the rate charged could be on a graduated
scale with the highest charge being in those areas with the worst
pollution problem.
Application of this concept to St. Louis or to any other AQMA could
cause an adverse economic effect on the central city. The polluters
could decide to relocate within the AQMA or could move out of the
area with the highest pollutant levels and, abandon the central city.
In St. Louis this is an especially acute problem because of the fixed
boundaries of the central city and its inability to annex suburban
areas to which these new industries may go.
The charge could also provide an opportunity for an "island" of no or
minimal charge to come into existence. This "island" could be within
an AQMA or it could be an entire metropolitan area. The "island"
would be able to siphon many large industries from other areas which
have these charges. A national policy would be required to prevent
this type of abuse of this measure.
Transfers of Emission Source Location -- This measure requires the
optimium use of terrain, meteorology, and geography of an AQMA from an
air pollution viewpoint. It is especially applicable to power plants.
This measure is essentially being used at the present time in St.
Louis due to the concern of the local citizenry about the location of
the power plants and the requirement of the state air pollution agency
for an EIS on power plant locations.
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Indirect Source Review and Environmental Impact Statements -- These
measures are relevant upon regulations stated in 40 CFR and on Section
102 (2) (C) of NEDDA of 1969. The principal question concerning these
measures is not the measures themselves, but the realism of the standards.
Whether the standards are realistic or not will not be determined
until the absorption rates of the ambient air are determined.
Chapter III of the document deals with explaining nine emission control
measures. These are:
e New Source Performance Standards
e Revision of Existing SIP Control Measures
e Phaseout or Prohibition of Emission Sources
o Fuel Conservation
o Energy Conservation and Utilization
o Combination of Emission Sources
e Special Operating Conditions
e Stack Height Regulations
e Control of Fugitive Dust Sources
All of these measures appear to be applicable to the St. Louis AQMA
and are only restricted by the state-of-the-art of the technology
required for their implementation.
Chapter IV merely presents a matrix of how the varying control measures
assist each other, overlap each other, or act independently. The
matrix gives some useful information to the state and local agencies
as to the applicability of each measure and will help in making the
decisions required for developing specific control measures for the
AQMP.
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On a "broad-brush" review it appears that Chapter V is adequate.
However, the general nature of the discussion may be imcomplete with
respect to some of the legal problems involved in implementing these
meausres. The state-local relationships in terms of legal authority
and air pollution control responsibilities should be emphasized. A
more concise legal analysis, which brings in definitions of criteria of
acceptability for implementation of each measure would enhance the
usefulness of this chapter.
Relation of Land Use and Transportation Plans to Air Quality
This document is intended to provide a methodology for relating land
use and air quality. The document presents a general review of land
use planning and the 3-C Process and defines a general methodology for
considering air quality in the overall planning process. Procedures
are also suggested for utilizing existing land use and transportation
plans to project and allocate emissions and air quality in AQMAs.
Following are the comments on the document.
1. Although work on the St. Louis plan has not progressed to the
diffusion modeling stage as yet, it is already apparent from
discussion with the Source-Receptor Analysis Branch that the
spatially distributed projected emissions data for 1975, 1980,
and 1985 cannot be modeled with any of the simple models listed
in the Task 1 to indicate the extent of the AQMA expected to
exceed air quality standards. Available models which do provide
the necessary spatial resolution, such as AQDM, require considerable
effort in validation and calibration steps and generally need
stack parameter and other data that cannot be obtained for projected
new sources (and many existing sources in St. Louis).
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2. The expected integration of guidelines on modeling to be prepared
by EPA with the guidelines relating land use and transportation
plans to air quality is lacking. If input data are not presently
available for the preferred models, especially under the proposed
schedule, some backup methodology such as emission density calculations
should be explained in the guidelines, so that the responsible
agencies can make some estimates of the area where maintenance
action are needed.
3. The "preferred" or available analysis approach described in the
document assumes a detailed county projection methodology will be
available as well as an EPA guideline on air quality models.
There are then three documents which must be integrated to provide
the complete analysis guideline. To date, these three documents
have not been properly coordinated in their preparation and it
appears that they may be inconsistent. It is recommended that
EPA coordinate these efforts so that a detailed methodology can
be prepared.
4. The "preferred" analysis approach described in the document is a
sequential approach resulting in a description of air quality.
The emissions projection methodology implies that consideration
will be given to emission controls and control plans already in
existence as well as the source of growth rate in the determination
of projected emissions. However, the impact of SIP's and Transportation
Control Plans (TCP's) on land use and transportation has not been
adequately defined to date. Indeed, the majority of proposed TCP
measures have not been implemented and are not defined in sufficient
detail to perform an air quality impact analysis. Therefore, the
growth rates used in the projections may be in considerable error.
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Many regional transportation plans are under study or revision at
this time. For example, in St. Louis the existing transportation
plan calls for rapid rail transit. However, a new study is
about to begin to determine the feasibility of alternative approaches,
This study will not be completed until mid or late 1975. Therefore,
1980 or 1985 transportation network cannot be evaluated at this
time.
It seems apparent that a one time sequential analysis will not be
sufficient to support an air quality maintenance strategy. It is
therefore recommended that the air quality analysis be a continuing
and interative process responsive to the changes in policy which
affect both the sources and their control. This would require a
large scale effort to quantify the effect of policy changes, etc.,
on both sources and resultant air quality. The states should be
given some guidance in establishing a mechanism to incorporate
these changes as they occur.
5. The analysis approach begins with a controlled 1975 emissions
inventory (which was a required step in the techniques for
designating the AQMA) assuming that an accurate, complete, and
"controlled" emissions inventory can be compiled for 1975. In
attempting to compile such an inventory for St. Louis, the
following problems were noted and specific examples are given.
However, these problems are probably not unique to St. Louis. It
is, therefore, recommended that a major upgrading of the emissions
inventory be performed as an integral part of the maintenance
plan implementation. This upgrading will require significant
resurveying as opposed to reformating of data and should consider
a means of continuous update when significant fuel use or other
energy related or control related changes occur.
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(a) Projection techniques are based on multiplying existing
emissions by a growth factor. This assumes that the data
base is reasonably accurate. Since the industrial growth
rates are small (less than 3 percent per year), the major
source of error in projected total emissions will be the
baseline. For example, in St. Louis, one point source was
listed as emitting 100,000 TONS/year of S02 . The State of
Missouri has determined that in actuality this source emits
more than 400,000 TONS/year. If fuels are varied during the
next few years, the annual emission rate for this source may
vary significantly. It appears that S02 is still a significant
point source control problem and that maintenance measures
directed at any other sources (i.e., area source fuel combustion)
may not be justified due to the significant error in the
data base of major sources.
(b) Specific formulation of growth and control factors on a subcounty
basis is time consuming and costly. If backup growth factors
and control factors such as those used in the guidelines for
designation document are employed, the error in the projected
emissions can be greater than the control potential of pro-
posed AQMA control measures.
(c) In the counties outside of the urbanized portion of the
SMSA, fugitive dust may be a significant impact on TSP
ambient monitor readings. Projections of TSP emissions will
contain no growth factor for these sources although the
ambient monitors will continue to record values exceeding
the standards. This implies that a sensitivity analysis
should be performed to determine the significant sources
influencing each monitor before the monitor data base is
used as a criterion for AQMP development.
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(d) Power plants are frequently the most significant sources of
S(L and TSP. The range of error in control or fuel use
assumptions for a power plant may be greater than the total
emissions from all other sources. Annual average or annual
total emissions are not sufficient to show the fluctuations
in emissions from these sources which may be influencing an
ambient monitor. This data must be updated continuously and
should include results of source testing. This level of
detail is beyond the simplified sequential approach for AQMA
analysis and AQMP development.
(e) CO is now and will become more so in the future a "hot-spot"
problem. Existing inventory data for mobile sources is
totally inadequate to project "hot-spots". Backup methodologies
for projecting VMT all have one thing in commonthey aggregate
the VMT data spatially and temporally in order to avoid
error. Backup, or short cut approaches to mobile source
emissions projection is not appropriate for AQMP development.
Some guidance should be prepared on how to estimate the
location of probable "hot-spots".
(f) Photochemical oxidants are inadequately treated in any
available analysis approach. Current efforts to model these
pollutants will not be available within the proposed time
frame. Some guidance should be given to the states on how
to proceed.
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C. SUGGESTED ADDITIONS TO GUIDELINES DOCUMENTS
It is recommended that the following additions and deletions of material
from draft reports be made in the final guidelines document distributed
to the States.
1. As part of the requirements for contents of the maintenance
plans, some preferred or suggested formats for data presenta-
tions should be added. This would assist the agencies and
also make EPA evaluation of the plans easier.
2. At several points throughout the draft guidelines, the im-
portance of indirect source review, NSPS, new source perfor-
mance standards, permit systems for new sources, and environ-
mental impact statements as elements of the maintenance plan
are mentioned. Also, analyses of the air quality impacts of
the first three of these programs are required in the AQMP.
Yet, the administrative coordination between the separate
agencies responsible for these different elements is not
discussed in the Task 2 report and no indication is given that
the agency and personnel responsible for implementing the AQMP
must be continually apprised of all actions taken under these
four programs in order for any maintenance strategy to function
properly.
Possibly, the establishment of some notification procedure
should be required in each plan within the section entitled
Intergovernmental Cooperation.
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3. The sequence of activities for air quality maintenance planning
shows a step (number 7) entitled "Refine AQMA Boundaries."
This particular step does not seem appropriate, and it is
recommended that it be deleted. The States have supposedly
considered factors other than growth potential, e.g., boundaries
of regional planning areas, in their original recommendations
and the Administrator has officially designated these specific
areas as AQMA's.
There are no obvious advantages in refining the boundaries
within six months of their designation, since the maintenance
plan does not necessarily have to specify controls for the
entire AQMA. Low-growth counties (or other subareas) simply
would not have any maintenance effort during the initial 10-
year planning period. Including fringe counties in the AQMA
permits greater latitude in developing a regional plan that
can accommodate growth and maintain air quality standards.
Although the guidelines for designation of AQMA's are not
specific on this point, revising the boundaries would probably
require public hearing and approval of the Administrator.
4. The situation of a regional planning agency with no enforcement
powers, preparing the AQMP and local air pollution control
agencies, with enforcement powers, being responsible for
implementation in their own jurisdictions may be a common
division of responsibilities. At present, this is the most
probable alternative in the St. Louis AQMA. Since there are
some inherent problems with this arrangement, it should be
discussed in detail in the guidelines. The statement that the
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any plan. If it is not accepted there, then the federal or
state government will be forced to use the "carrot and stick"
approach to ensure implementation and compliance of the plan.
7. In conjunction with number 6 above, it is assumed that the
guidelines discussion will include the results, based on the
experience of the contractors developing plans in the four
sample cities. These results would be very helpful to the
agencies in other AQMAs in the development of their AQMP.
8. Analysis guidelines are uncoordinated and inadequately detailed.
It is recommended that after the sample plan projects are
complete and after EPA has determined final policy on possible
alternative approaches to AQMP development and submittal, a
concise, coordinated analysis document, as prepared with some
guidance on expected availability of required or recommended
techniques. This document should be updated periodically as
new techniques become available. EPA should evaluate and
critique the new techniques for specific applicability to AQMA
analysis and plan development or revision, and circulate a
brief description of the technique and the critique of its
applicability to those responsible for AQMA implementation.
The level of effort and expected cost to utilize the techniques
should be included.
D. SUGGESTIONS FOR SIMILAR DOCUMENTS IN FIVE YEARS
Within the next five year period, the AQMPs that are presently required
will be produced. Possibly the most useful document that could be
produced would be one that would summarize all the general and specific
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problems that the states and local agencies encountered in their develop-
ment and implementation of the AQMP. This document would also summarize
the methods that these agencies used to solve the problems that arose.
These results could be a seperate document or they could be used to
update the present guideline documents. The latter could be extremely
time consuming and may not be an effective as the summation document.
In addition, EPA could develop over the five-year period, an information
and data clearinghouse for the states and local agencies. Presently,
these agencies do not have the staff to accomplish this, yet the need is
definitely present as shown by the data problems being experienced in
St. Louis. This clearinghouse would not only include emission data .
base, but also would include information on new control technology and
analysis techniques and applicability of this technology based on its
use in the field. This type of information would be extremely valuable
to the implementing agency in suggesting proven methods of control.
This information in the clearinghouse should be automated for easy
retrieval by the states and local agencies.
Using this updated and more detailed data base and methodologies, the
AQMP process should be included in the overall comprehensive planning
process for the AQMA. By so doing, a much more thorough AQMP can be
developed. This plan will become part of the overall comprehensive plan
for the AQMA.
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IF IF
CHAPTER III
CRITIQUE OF EPA APPROACH TO AIR QUALITY MAINTENANCE
A. OVERVIEW
The framework for evaluation of the guidelines is necesssarily limited
by the short time in which they could be applied in the field, compli-
cated by the fact that the plan development process was proceeding
simultaneously. Also, it has not been possible to fully evaluate some
of the guidelines in the practice of plan development; for example, no
effort has been directed toward strategy development (Task 3). Neverthe-
less, the guidelines have been reviewed with an understanding of essential
application and the findings are summarized below.
In general, it may be concluded that although there is a need to develop
maintenance plans for air quality, there is a lag in the state-of-the-
art which has a potential to be costly and may not prove to be effective.
Theoretically, the procedures described by the guidelines should be
applicable in most AQMAs; however, as has been demonstrated in St.
Louis, the emissions and air quality data bases and land use plan develop-
ment have not progressed to a point where they are compatible or are in
a format that can be used in the development of the AQMP. In other
areas, especially where the land use plan has been quantified, it may be
more practicable to apply the techniques specified in the guidelines.
Similar problems are apparent in the jurisdictional and institutional
constraints present in St. Louis which will hinder plan development and
implementation. Again, it is not unlikely that similar problems will be
encountered elsewhere, especially within AQMAs.
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Another concern is the fact that the air quality implementation plans
are to be developed, based on tenuous data, within less than a year,
while the land use and transportation planning processes, in which the
AQMP is so intimately involved, have been in practice for at least a
decade. Admittedly, these latter processes have generally excluded the
air and water quality aspects of the urban activity, but many areas are
proceeding to incorporate these elements into the process. It will be
useful to observe the results of this in Fairfax County, Virginia, and
the Northeastern Illinois Planning Commission where air quality and
land use will be quantified on a subarea basis and incorporated into the
overall process. Thus, one recommendation is that the air quality
maintenance plan development be delayed at least 12-18 months until
a comprehensive approach can be implemented in the AQMA. This should
result in a cost-effective approach and would ensure a more valid basis
on which to evaluate maintenance strategies. There is also the question.
of whether most areas will actually attain air quality standards by
1975, and if not what the impact of maintenance strategies will be.
Furthermore, it must be recognized that planning agencies will not have
the funds to actively participate in AQMP development in the next 12
months and it would be inappropriate for air pollution control agencies
to prepare such plans without this participation.
B. UNRESOLVED ISSUES
General Issues
Perhaps the greatest barrier to the level of intergovernmental cooperation
envisioned in the draft guidelines documents is agency funding. Air
pollution control agencies have traditionally been receptive to under-
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taking new projects requested by EPA because a part of their funding
comes from EPA. The impact of eliminating agency grants has yet to be
determined.
Planning and other local agencies, on the other hand, do not receive
funding from EPA and have program commitments related to their sources
of funding. Two different levels of involvement by these agencies can be
anticipated. First, the agencies might be asked to send representatives
to meetings and voice their agencies' viewpoints on the acceptability of
plan development procedures and proposed maintenance measures. In
general, this amount of assistance and cooperation may be expected. The
other level of involvement would be to request the agency to generate
data, such as regional VMT by highway link for the two projection years,
or to simulate and evaluate the effects of a proposed maintenance measure.
In most cases, this type of participation will not be forthcoming unless
the agency receives some additional funding. The draft guidelines do
not discuss the possibility that an important local agency may not
accept the responsibility of participating in plan development.
Demographic, economic, and transportation projection data necessary for
plan development are generally not available for both of the projection
years (1980 and 1985). Linear interpolation between available projection
years may not be accurate. A regional planning agency may be able to
generate the required data, but it will require the use of sophisticated
activity models that may be beyond the resource availability of the
planning agency or may take more time than is allotted to definition of
the growth problem.
Ideally, planning for air quality maintenance could best be accommodated
by integration into other ongoing planning efforts. For example, an
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18-month study of alternative rapid transit and mass transit systems for
the St. Louis area, sponsored by the East-West Gateway Coordinating
Council, is scheduled to begin in June or July. Although improved mass
transit has strong potential as a maintenance measure in St. Louis, the
results and recommendations of this comprehensive study will not be
available in time to be input into the plan. The immense air quality and
emissions data base that would be provided by RAPS in St. Louis likewise
will not be available for use in preparing the maintenance plan. The
impending RAPS projects also make the local agencies understandably
reluctant to update or upgrade their existing emissions data to the
extent necessary to provide an adequate basis for plan preparation.
In general, large-scale regional planning studies that may provide input
to AQMP development cannot be rescheduled to meet the AQMP deadline.
Therefore, to assure the best possible maintenance plans, the schedules
for submittal should be more flexible.
As noted in the proposed California plan prepared by Livingston and
Blayney, an analysis that can determine whether air quality standards
will be maintained throughout every part of an urban area requires a
more detailed emissions inventory (especially spatial resolution of area
sources) than the NEDS format or the 40 CFR Appendix D format used in
the SIPs. In most cases, the additional data needed would necessitate
an extensive field survey rather than just compilation or updating of
information from permit forms and compliance schedules. This information
is to be obtained for the St. Louis area during the next year as part of
the RAPS program. However, it will not be available by September or
October 1974, the completion date shown in the draft guidelines. For
other AQMAs, the need for such an inventory should be emphasized.
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During 1974, there have been significant shifts from historical trends
in usage of all major fuel types, and therefore changes in emissions
from fuel combustion operations. If the emissions projection procedure
utilizes a data base of 1972 or 1973 rather than current data for 1974
or estimates for 1975, it will probably ignore these changes. For
example, higher gasoline prices have reduced urban travel by 3-15 percent
compared with year earlier values, while the normal occurrence is a 2-10
percent annual increase in VMT. Thus, VMT projections from 1973 data
might overestimate any future values by an average of 15 percent.
Industrial and domestic energy conservation programs instituted in 1974
might cause similar overpredictions, but switches to lower grade fuels
due to non-availability and price increases would result in some signi-
ficant underestimates of emissions rates per unit of fuel consumed. If a
current data base cannot be developed, some method of correcting for the
recent changes should be established and/or required because their
impacts may be as great or greater than many of the maintenance measures.
Demonstration that short-term air quality standards will be maintained
requires that some analysis be made of maximum short-term emissions
rates. Emissions are normally calculated on an annual basis. Therefore,
some standardized methodology should be provided for converting annual
emissions rates into equivalent maximum short-term rates. Unless such a
standard method is prescribed, divergent assumptions made in conversions
for different AQMAs may create problems of consistency in evaluating the
plans.
The St. Louis AQMA has one scheduling problem which is atypical--the
initial transportation control plan will not be submitted until Febru-
ary 1975. Until the contents of that plan are known, it is impossible
to determine what additional measures, if any, will be needed to maintain
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standards for carbon monoxide and oxidants through 1985. In fact,
control measures that would be considered for inclusion in the two plans
would probably be identical. Due to this peculiar overlapping in plan
preparations, it is recommended (for the St. Louis AQMA only) that
maintenance provisions of a regulatory nature be included in the trans-
portation control plan, and that the maintenance plan for these two
pollutants contain only the required demonstration of adequacy.
Data Projection Issues
This section present some of the more specific problems that have been
encountered in attempting to develop baseline data and to project this
data to 1975, 1980, and 1985. The emissions were divided into four
categories: point sources exlusive of power plants, power plants,
stationary area sources, and mobile sources.
POINT SOURCE EMISSIONS
Estimation for 1975, 1980, and 1985 The main data sources used were
the 1972 NEDS emissions inventory for individual point sources for all
counties involved as shown in Appendix B of Attainment of National Air
Quality Standards for Carbon Monoxide and Oxidants in the St. Louis AQCR
by PEDCo-Environmental Specialists, Inc., and individual information on
major point source emissions for 1972 and 1975 for the Illinois Counties
in the AQMA provided by the Illinois Environmental Protection Agency
(IEPA). (Emissions and compliance status information for major point
sources in Missouri is forthcoming from the Missouri Air Conservation
Commission (MACC), but was not available for usage in developing these
preliminary emission estimates.)
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The primary problem is the necessity of using NEDS data which is not
considered total accurate. Incorrect site locations and plant closings
were corrected where known. The lack of compliance projections necessitated
using the average reduction factors given in the EPA guidelines for
designating AQMA's. These average factors probably introduced a consid-
erable amount of error into the 1975 and consequently '80 and '85 esti-
mates because (1) they are national average figures which may not apply
to the St. Louis area, (2) they are based on allowable emissions and not
actual compliance, and (3) they probably are weighted more heavily
towards large point sources than small point sources, thus giving a
greater reduction than is likely for small point sources. This problem
will be partially remedied by utilizing the forthcoming Missouri Air
Conservation Commission's emissions and compliance information.
Another problem was the lack of consistent countywide growth projections.
This necessitated the use of SMSA level growth projections. Thus, the
1980 and 1985 emissions projections probably overpredict growth in
emissions for slower growing, but heavily industrialized central city
areas and underpredict growth in emissions for faster growing, but less
industrialized suburban areas.
POWER PLANT EMISSIONS
Estimation for 1975, 1980, and 1985 Power plant emissions were provided
for both 1972 and 1975 by the Illinois Environmental Protection Agency.
However, these figures were not disaggregated according to consumption
of fuel by fuel type.
Missouri power plant emissions are not available as yet, but will be
provided by the Missouri Air Conservation Commission. The information
provided in the State Implementation Plan and in NEDS was not considered
reliable.
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Forecasts of 1980 and 1985 emissions from power plants by county will be
based upon data already gathered on expected operation of existing power
plants and new plants to be opened in the future.
The area source emmisions were divided into three basic categories for
forecasting purposes. These are: residential, industrial, and commer-
cial/institutional. Each of these categories was further subdivided by
fuel type to bituminous coal, anthracite coal, distillate oil, and
natural gas. To project these values, the BEA statistics for the St.
Louis SMSA were determined to be the only obtainable data source which
covered the years of interest. The growth in residential area sources
was forecast using the BEA estimates of population growth, industrial
source pollutants were forecast using the estimated increase in total
manufacturing earnings, and commercial/institutional was projected using
wholesale and retail trade earning estimates.
The projection of residential source emissions using base year totals
was deemed unrealistic since coal usage is on the decline in the St.
Louis area. To compensate for this, a fuel balance based on expected
BTU requirements was performed. The assumption made was that by 1980,
the percent of total BTU's required contributed by coal would decrease
by 50 percent, and by 80 percent in 1985. Thus if in a given area 10
percent of the required BTU's were derived from coal in 1972, only 5
percent would be derived from coal in 1980, and only 2 percent in 1985.
It was assumed that distillate oil and natural gas would contribute the
necessary extra BTU's in proportion to their 1972 use. The fuel require-
ments thus determined were converted to the respective pollutants using
the appropriate emission factors.
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These procedures resulted in county totals by type of pollutant and
source for each of the forecast periods. These totals were then modified
by the appropriate reduction factors required to comply with the 1975
emission standards.
The results obtained by this technique should not be considered accurate.
The BEA growth rates reflect areawide growth for the entire SMSA of St.
Louis. Thus areas with high growth potential are significantly under-
estimated, while current high density areas are overestimated.
The basic problem encountered in the area source projections was the
varying levels of refinement of the input data. The original or base
pollutants were at the county level while the forecasting variables were
based on regional growth. Ultimately the result is to be disaggregated
to a one kilometer square grid system. To justify any result from such
a procedure and substantiate the accuracy is extremely difficult.
MOBILE SOURCE EMISSIONS
Estimates for 1975, 1980, and 1985 -- Mobile source emission estimation
for light and heavy duty vehicles for 1975 and 1980 will be based primarily
on Appendix A of Pedco's Attainment of National Air Quality Standards
for Carbon Monoxide and Oxidants in the St. Louis AQCR. This appendix
gives VMT projections for 1975 and 1980 by county by class of road,
average speeds by class of road, and weighted emission factors for 1975
and 1980 based on the expected vehicle model year distributions in those
years.
In order to estimate emissions for 1985, it will be necessary to project
1985 VMT by county by class of road. This will be done by extrapolation
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of 1980 PEDCo figures in accordance with 1995 projection totals estimated
by the East-West Gateway Coordinating Council. It will also be necessary
to calculate weighted emission factors for 1985 based on the expected
vehicle model year distribution in that year and revised average speed
estimates by class of road.
These techniques are again primarily directed toward obtaining a data
base to test the procedures for Maintenance Strategy Development. This
level of aggregation of data and interpolation of networks is considered
inadequate to define the carbon monoxide maintenance problem.
D) 3ft
f
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C. RECOMMENDATIONS FOR RESOLUTIONS AND ALTERNATIVE APPROACHES
Following is a list of recommendations for resolution of some of the
noted problems and some possible alternative approaches.
1. A comprehensive effort is needed to upgrade, update, and expand the
emissions inventory for AQMAs. This task should begin after all
alternative approaches to AQMP development are defined so that the
data base can be compiled in a form suitable for analysis.
2. Efforts should be expended to determine the interactive effects of
all existing environmental programs before any new program is
initiated. For example, the 208 water programs are to be integrated
with AQMA programs. However, under the proposed time constraints,
little effort can be expended to coordinate these programs.
3. A means of providing incentive and direction for coordination of
all Federally funded local activities is required. For example,
DOT could provide direction and assistance to the 3-C planning
agency to allow them to take part in the AQMP development.
4. Energy planning in urban areas must be coordinated with environmental
programs.
5. Alternative approaches. The June 1975 submittal should consist of:
(a) A detailed description and schedule of the states selected
approach to AQMP development, implementation, and enforcement.
(b) A detailed description of the agency or agencies responsible
for each element of the proposed approach to AQMP development.
(c) A detailed description of the coordination procedures to be
employed during plan development to ensure that all available
resources are applied and adequate review by all concerned
organizations is provided.
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(d) A description of a public awareness program to be initiated to
which will an avenue for public participation and review.
(e) A detailed description of available resources for plan develo-
pment including staff and budget requirements and a listing
of areas where resources are inadequate and funding or technical
support is required.
(f) A description of the coordination of AQMP development and
implementation with other environmental programs; i.e., 208
water planning, indirect source procedures, transportation
control plan implementation, etc.
(g) A description of the means of coordinating AQMP development
with other community planning programs, i.e., comprehensive
planning, 3-C transportation planning, energy planning, etc.
(h) An interim plan including:
o a review of the progress of existing SIP and TCPs
o proposed changes to SIPs or TCPs including new regulations
o interim measures
(i) A description of activities initiated to:
o upgrade the emissions inventors
o resolve legal issues
o Obtain the staff and funds required
(j) A legal authority analysis including:
o a detailed description of existing state and local authority
relevant to possible maintenance measures and approaches.
o a description of deficiencies in existing authority
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CHAPTER IV
SUMMARY
The comments contained in this critique are based on the first six weeks
and attempt to apply the guideline documents to the situation in the St.
Louis AQMA. Because of the many problems noted with the emissions and
planning data base and because of the multitude of political juris-
dictions, the application of the guidelines was necessarily limited.
Though limited, the critique comments present some of the problems
that have developed as the guidelines were applied to the St. Louis
AQMA. The results are valuable in that they point out major stumbling
blocks that presently exist and that will have a very real effect on the
development of the AQMP for St. Louis. It is also likely that some if
not all of these problems will surface in other AQMAs especially those
that are interstate in nature.
As the remaining portion of the Task Order and the sample plan development
progresses, additional problems may occur that will alter or supplement
the opinions already made in this critique. Because of this, it is
anticipated that the final version of this critique, due on June 21,
1974, will not only incorporate the comments from EPA, but will also
incorporate additional critique comments resulting from the development
of the AQMP.
This critique points to the need for submission of our AQMP work
program that ties into the local area and is integrated with the
local planning process. The work program should be submitted annually
and be the basis for multiagency funds in the next year. The annual
work program should be accompanied by a larger (5-year) program.
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