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Acknowledgement
We would like to thank all the members of the Air Quality Management Work Group for their
contribution to this effort, including participation in numerous calls and meetings, as well as
countless hours spent reviewing the recommendations included in the final report. A special
thank you to Daniel Greenbaum and Michael Bradley, representing the Committee on Air Quality
Management in the United States, for their guidance throughout this process.
Janet McCabe, Co-Chair
Gregory Green, Co-Chair
u
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December 10, 2004
MEMORANDUM
SUBJECT: Air Quality Management Work Group Report
FROM: Janet McCabe and Gregory Green, Co-Chairs, Air Quality Management
Work Group
TO: Clean Air Act Advisory Committee
On behalf of the Air Quality Management Work Group, we are pleased to present to you
for your deliberation, a report with recommendations to improve the current air quality
management system For the past six months the Work Group has evaluated ways to improve air
quality management in the United States and is today making its recommendations available to
this Committee. In its evaluation, the Work Group considered the recommendations made by the
National Research Council (NRC) in its report entitled Air Quality Management in the United
States. In this report, the NRC outlined the many substantial achievements of the United States
air quality management system over the past 30 years. The NRC also identified areas where
additional changes to that system would provide further benefits to human health and the
environment. The recommendations of the NRC helped guide this Work Group.
The attached report outlines thirty-seven recommendations for near-term improvements
in air quality management. It focuses on translating the NRC recommendations into more
specific steps that can be taken quickly by EPA and others to realize improvements in air quality
planning. We also outline in the report areas on which we were unable to reach consensus and
have made recommendations involving the establishment of a new subcommittee to the CAAAC
that will allow us to continue discussion on these and other issues in the future. Finally we have
included four possible options this subcommittee may use as a starting point in the discussions
on managing air quality in the future.
We would like to thank the many CAAAC members who have participated on the Work
Group. We would also like to thank Michael Bradley and Daniel Greenbaum for their support
and guidance throughout this process. In addition to the CAAAC members, we also appreciate
the work of many representatives from state and local organizations, tribes, regional
organizations, environmental and public health organizations, industry and EPA. They have
played a critical role in developing these recommendations.
-------
On behalf of the Work Group, we thank you for the opportunity to participate in
CAAAC's activities and hope you find our work useful in providing advice to EPA for
developing future air quality management strategies.
Attachment
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Air Quality Management Work Group
Final Report to the Clean Air Act Advisory Committee
Table of Contents
Executive Summary vi
Introduction 1
The Air Quality Management Work Group 3
Next Steps 6
Air Quality Management Work Group Recommendations 8
NRC Recommendation 1: Strengthen Scientific and Technical Capacity 8
1.1 Emissions Measurements and Reporting
1.2 Emissions Factors and Estimation Methods
1.3 Uncertainty in Emissions Inventories and Modeling
1.4 Multipollutant Monitoring
1.5 Framework for Accountability
NRC Recommendation 2: Expand National and Multistate Control Strategies 13
Further Study and Possible National and Regional Regulations 15
2.1 Industrial, Commercial, and Institutional Boilers
2.2 Industrial Surface Coatings
2.3 Non-Industrial Solvents
2.4 Architectural Surface Coatings
2.5 Heavy-Duty Diesel Engines
2.6 Emissions from Ships, Locomotives, and Aircraft, and
Mobile Source Air Toxics
Evaluation of Additional Emissions Reduction Potential 17
and Cost-Effectiveness
2.7 Cement Manufacturing, Petroleum Refining, and Pulp and Paper
2.8 Residential Fossil Fuel Combustion
National Guidance for Local Controls 18
2.9 Guidance for Local Control Measures in Key Sectors
2.10 Residential Wood Smoke
2.11 Open Burning
2.12 High-Emitting Gasoline Vehicles
2.13 Conformity
111
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NRC Recommendation 3: Transform the SIP Process 21
Streamlining the SIP Process 22
3.1 Align SIP Submittal Dates
3.2 Protocol for SIP Development
3.3 Clearinghouse of Approved SIPs
3.4 Streamline Minor SIP Revisions
3.5 Timely EPA Guidance
3.6 Avoid Unnecessary Public Hearings
3.7 Facilitate Redesignation Process for Certain Areas
Measures to Improve Communication to the Public 25
3.8 Effective Communications with Constituencies
3.9 Co-Benefits of Innovative Measures
Steps to Increase Adoption of Innovative Measures 25
3.10 Innovative and Voluntary Measures
3.11 SIP Credits for Bundled Innovative Measures
Increasing Collaboration in SIP Planning and 26
Control-Strategy Development
3.12 Regional Approaches to SIP Planning
3.13 Federal and State Partnerships
Steps to Improve Tracking and Evaluation of Results 28
3.14 Weight-of-Evidence Demonstrations
3.15 Periodic Assessments to Track Progress
3.16 Averaging, Banking, and Trading in Gasoline Sulfur Program
NRC Recommendation 4: Develop Integrated Program for Criteria and 29
Hazardous Air Pollutants
4.1 SIPs to Address Multipollutant Impacts
4.2 Multipollutant Benefits and Disbenefits in Standards Setting
NRC Recommendation 5: Enhance Protection of Ecosystems and 31
Public Welfare
5.1 Program Review to Improve Ecosystem Protection
Unresolved Issues for Further Discussions 32
Looking Forward: Long-Term Realignment of the AOM System 34
Long-Term Vision: Core Principles
Long-Term Framework Options
Moving Forward: Continuing the Evaluation Process
Conclusions 38
IV
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Appendices
A - Air Quality Management Work Group
B - Recommendations Matrix and associated background papers
B-l Matrix
B-2 Background Papers
C - Summary of Deferred Issues
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Air Quality Management Work Group
Report to the Clean Air Act Advisory Committee
Executive Summary
In June 2004, the Clean Air Act Advisory Committee (CAAAC) formed the Air Quality
Management Work Group. The Work Group's task was to assess the recommendations made by
the National Research Council (NRC) of the National Academies in its 2004 report, Air Quality
Management in the United States,1 and to advise the CAAAC on ways to improve the U.S. air
quality management system, with an emphasis on activities that could be accomplished in the
next one to five years. The NRC report described the dramatic improvements in air quality
achieved in the U.S. since 1970, and the resulting improvements in human health and the
environment. Despite these improvements, however, the NRC noted a number of areas in which
the air quality management system could be enhanced to allow progress to continue in a more
effective and efficient manner. Recognizing this, the CAAAC charged the Work Group with
outlining concrete steps that could promote change in the directions recommended by the NRC.
The Work Group formed two subgroups, the Science and Technology Subgroup and the Policy
and Planning Subgroup, to focus on the critical issues outlined in the NRC report. From June
through December 2004, the Work Group considered many options for change. The Work
Group included representatives from State and Local organizations, Tribal interests, regional
organizations, environmental and public health organizations, industry, and the United States
Environmental Protection Agency (EPA).
In this report, the Work Group advances 37 detailed recommendations. These recommendations
address the five main areas of concern of the NRC:
1) Strengthening scientific and technical capacity
2) Expanding national and multistate control strategies
3) Transforming the SIP process
4) Developing an integrated program for criteria and hazardous air pollutants
5) Enhancing protection of ecosystems and public welfare
The recommendations presented in this report are designed to be implemented in the near term.
Some of them require short-term process changes or alterations to existing policies that can be
accomplished relatively quickly and will result in substantial improvements in efficiency and
effectiveness of current programs. These recommendations will streamline processes, improve
resource allocation, and enhance scientific and technical capacity. Other recommendations
suggest initial steps that should be taken to form the basis for longer-term initiatives to be carried
forward into the future. These recommendations focus on larger-scale efforts that would
transform the air quality management system in more fundamental ways and further strengthen
its scientific and technical underpinnings. These latter efforts would, of course, require more
1 http:/Avww.nap.edu/books/0309089328/html/
VI
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resources and time to implement fully. However, the Work Group regards them as critical steps
that must be taken soon so that long-term gains can be realized.
Over the past six months, the Work Group also considered a variety of other issues on which it is
not prepared to make recommendations at this time. Some topics were so complex, resource
intensive, or controversial that the Work Group was unable to reach consensus and, therefore,
has decided not to carry them forward. Additional discussion on these topics is expected in the
future. The Work Group has also begun considering options for the air quality management
system in the future. It evaluated the long-term challenges facing air quality management in the
U.S. from a number of perspectives and identified several criteria that may help guide
discussions on alternatives for reforming the current system in future years. To help begin this
process, the Work Group outlines four approaches reflecting different views that could serve as
the basis for a more complete transformation of the air quality management system. In addition,
the Work Group recommends that discussion of future options and unresolved issues be
continued over the next several months.
The Work Group advises that the recommendations contained in this report be implemented by
EPA, States, Locals, Tribes, and other stakeholders in the immediate future. Several of the
recommendations are critical because of impending SIPs for ozone, PM2s and regional haze.
The Work Group, however, is sensitive to the level of resources needed to implement these
recommendations and understands that EPA should establish priorities that reflect practical
constraints. All of these recommendations can be implemented under the current authority of the
Clean Air Act (CAA). Specifically, the Work Group recommends:
• A new CAAAC subcommittee should be established to continue the assessment and
development of recommendations for long-term changes to the air quality management
system and to address the issues on which the Work Group could not reach consensus.
Until the subcommittee is formed, the current AQM Work Group should continue
working to further define and resolve additional issues and long-term framework options.
• The Work Group recommends that EPA carefully consider the recommendations and
issue a response to CAAAC outlining a plan for implementation, and that EPA report
back to the CAAAC subcommittee periodically on its implementation efforts.
• The new subcommittee, in conjunction with existing CAAAC subcommittees, should be
assigned the responsibility for overseeing the implementation of, and any modifications
to, the recommendations contained in this report.
• Following its establishment, the new subcommittee should develop a timeline for
delivery of new recommendations and provide periodic progress reports to CAAAC.
Discussion by the subcommittee on remaining issues and options should be directed
towards further strengthening the U.S. air quality management framework over the next
decade.
vu
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Air Quality Management
Work Group
Report to the
Clean Air Act Advisory Committee
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Air Quality Management Work Group
Report to the Clean Air Act Advisory Committee
Introduction
In 2004, the National Research Council (NRC) of the National Academies released a report
entitled Air Quality Management in the United States. In this report, the NRC outlined the many
substantial achievements of the United States air quality management (AQM) system over the
past 30 years. Controls on air pollution enacted under the Clean Air Act have led to dramatic
declines in emissions and air quality concentrations of a number of pollutants (Figure 1). The
NRC concluded that these controls have been highly cost effective and have promoted the
advancement of new technologies for pollution control.
A) National Average Air Quality Concentrations, 1980-2003
B) National Emissions Estimates, 1970-2003
— Suftjf Oo«)0«Annu»lAw»f»9f (t85«tt*J* 1000
— OzDniAflKMlWiMwB-tKMrAvwvpeCTBeMn)! 1
td u«x Mov Anno* (>
250
- 200
1970 1975 1980 1985 1990 1995 2000 2001 2002 2003
f-Lead
«•*-* PW2.S
.-.-VOC ~«*«»SO2 "»*«°«-P M10
NOx «»ta»CO (Y2)
Figure 1. National Air Quality and Emission Trends for selected 'Criteria' Pollutants.2 a) Long term
air quality trends (1980 thru 2003) and, b) national emission trends for the years 1970 thru 2003 illustrate
the continuing improvement achieved by air quality management under the Clean Air Act.
Overall, the nation has achieved a 51 percent decrease in aggregate emissions of the six principal
air pollutants and their precursors since 1970, despite significant increases in population, energy
consumption, gross domestic product, and vehicle miles traveled (Figure 2). These successes
demonstrate that implementation of the Clean Air Act has resulted in significant progress toward
improving the nation's air quality and protecting the health of its citizens.
2 U.S. EPA Air Quality System (http:/Avww.epa.gov/ttn/airs/airsaqs)
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Comparison of Growth Areas and Emissions,
70 SO S8 "*S 96 »? «» #5 «> 01 <»
Figure 2. Comparison of Growth Areas and Emissions.3 Between 1970 and 2003, gross domestic product
increased 176 percent, vehicle miles traveled increased 155 percent, energy consumption increased 45
percent, and U.S. population grew by 39 percent. During the same time period, total emissions of the six
principal air pollutants dropped by 51 percent
Looking to how such successes can be sustained or expanded in the future, the NRC identified
areas where modifications to the AQM system could more effectively provide further benefits to
human health and the environment in the most effective and efficient manner (see Figure 3).
Some of the NRC's recommendations involve near-term changes with immediate impact. Other
NRC recommendations focus on more sweeping changes to the nation's approach to air quality
management over the mid- to long-term. Taken together, these recommendations provide the
NRC's vision of how AQM in the United States could be reshaped and improved to achieve
greater benefits more rapidly and at lower cost.
' http://www.epa.gov/air/airtrends/aqtrnd03/images/growth-and-emissions.gif
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The Challenges Ahead
• Meeting National Ambient Air
Quality Standards for ozone
and paniculate matter at 2 5
um in diameter and reducing
regional haze
• Designing and implementing
controls for hazardous air
pollutants
• Protecting human health and
welfare in the absence of a
threshold exposure
• Ensuring environmental justice
• Assessing and protecting
ecosystem health
• Mitigating intercontinental and
cross-border transport
• Maintaining AQM system
efficiency in the face of
changing climate
The Long-Term Objectives for
AQM to Meet Future Challenges
AQM Should Strive To
• Identify and assess most
significant exposures, risks, and
uncertainties
• Take an integrated mulUpolhitant
approach to mitigating most
significant risks
• Take an airshed-based approach to
controlling emissions
• Emphasize results over process,
create accountability, and
dynamically adjust
To begin the evolution of AQM
toward these objectives m the United
States, five interrelated
Recommendations and related
Actions are proposed
RECOMMENDATION 1: Strengthen Scientific and
Technical Capacity
ACTIONS Improve emis
i tracking, enhance air pollution
monitoring, improve modeling, enhance exposure assessment,
improve health and welfare assessment, track implementation
costs, and invest in research and human and technical resources
RECOMMENDATION Z: Expand National and
Multlstate Control Strategics
ACTIONS Expand federal emission controls, emphasize
technology-neutral standards, use market-based approaches,
reduce exisUng-sources emissions, and address multistate
regional transport
RECOMMENDATIONS: Transform the SD? Process
ACTIONS. Replace state implementation plan whh integrated
mulapolhitant air quality management plan and reform process
to focus on tracking results using periodic reviews,
encouraging innovative strategies, and retaining conformity
and federal oversight
RECOMMENDATION 4: Develop Integrated Program
for Criteria and Hazardous Air PoOutants
ACTIONS Set priorities for pollutants, institute dynamic
review of pollutant classification, list potentially dangerous but
unregulated pollutants, *Mr~** mulupolhttants m standard-
setting process, and enhance residual assessment
RECOMMENDATIONS: Enhance Protection of
Ecosystems and Public Welfare
ACTIONS Conduct review of standards to protect public
welfare, develop ecosystem monitoring networks, establish
acceptable ecosystem exposure levels, promulgate secondary
standards, and track progress
Figure 3. NRC Vision for an Enhanced AQM System.4 To meet the major challenges that will face air
quality management in the future, the NRC identified a set of overarching long-term objectives.
The Air Quality Management Work Group
Following the recommendation of the NRC to establish a stakeholder group to oversee
implementation of its recommendations,5 the Clean Air Act Advisory Committee (CAAAC), a
body chartered under the Federal Advisory Committee Act, formed an Air Quality Management
Work Group (hereafter "Work Group"). This group was charged with evaluating the NRC's
recommendations and advising the CAAAC on ways to improve the AQM system in the near-
term. The Work Group included representatives from State and local organizations, Tribal
interests, regional organizations, environmental and public health organizations, industry, and the
Environmental Protection Agency (EPA). For a list of the Work Group members, see Appendix
A of this report.
4 NRC Report, p. 10
5 NRC Report, p. 314
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From June through December 2004, the Work Group considered many options to improve the
U.S. air quality management system consistent with the NRC report. To organize its discussion,
the Work Group formed two subgroups: one to address scientific and technological issues, and
the other to address policy and planning issues. The Science and Technology Subgroup worked
in a cross-disciplinary mode on most issues, but formed separate subgroups that focused on
health, ecosystem, and source apportionment issues. The Policy and Planning Subgroup also
subdivided into teams that focused on: 1) improving the State Implementation Plan (SIP)
process; 2) expanding the use of regional and national strategies; and 3) encouraging innovation
and developing multipollutant approaches. A fourth team began to discuss longer-term visions
of air quality management. Members from both the Science and Technology Subgroup and the
Policy and Planning Subgroup, as well as outside academics, focused on developing more robust
approaches for health and ecosystem issues.
All of these subgroups and teams met, separately and together, on numerous occasions to
develop a set of detailed recommendations responding to the NRC report. The teams took as
their starting point the four long-term objectives set forth in the NRC report (see Figure 3), and
the five overarching recommendations the NRC suggested as steps toward achieving those
objectives. Some of the recommendations outlined by the NRC that would require statutory
change are not feasible in the near-term and are not addressed in this report. The NRC clearly
recognized that the more significant changes embedded in its broad vision will take time to
develop, and that some more immediate actions are warranted to assist States as they develop
new ozone (8-hour), fine particle (PM2.s), and regional haze SIPs in the next few years. As the
NRC wrote after outlining its four long-term objectives,
"Immediate attainment of these objectives is unrealistic. It would require a level of
scientific understanding that has yet to be developed, a commitment of resources that
would be difficult to obtain in the short term, and a rapid transformation of the AQM
system that is undesirable in light of the system's past successes. The committee
proposes, therefore, that the AQM system be enhanced so that it steadily evolves toward
meeting these objectives."6
In the pages that follow, the Work Group provides a series of recommendations intended to
begin this steady evolution. If implemented, these recommendations would build upon and
strengthen the current system, starting with important modifications in the methods and
technologies used to collect scientific data, as well as the ways those data are translated into
control decisions. Though some of the recommendations will require further development to
become wholly effective, they provide a necessary foundation for improving air quality
programs. The Work Group agrees with the NRC findings that both short- and long-term
changes are needed. The Work Group is, however, acutely aware of what is achievable within
the next five years, and has, therefore, focused on short-term, pressing concerns such as
providing support for the development of the upcoming SIPs. These actions include enhancing
emissions inventories, redefining the role of air quality modeling, assisting in the development of
multipollutant planning and control strategies, achieving reductions from mobile sources, and
supporting innovative approaches to air quality improvement.
6 NRC Report, p. 16
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As the Work Group developed recommendations, the need for three categories of
recommendations quickly became evident: 1) recommendations upon which there was
substantial consensus among Work Group members; 2) recommendations upon which there was
not consensus, but on which consensus might be reached with additional discussion by the Work
Group or a follow-on group; and 3) recommendations that relate to an overarching long-term
vision. This report presents the Work Group's recommendations in each of these categories.
As a way of illustrating graphically how the system currently operates to manage and improve
air quality and the performance of control programs, Figure 4 depicts the connections among the
major components of the air quality management system. In this report, the Work Group first
lays out a series of detailed recommendations that will improve how different components in the
system are managed and enhance the feedback loops between the components. In these 37
recommendations, the Work Group offers concrete suggestions on how to improve the scientific
and technical foundation of the AQM process, and how to enhance the policy and planning
activities built on the scientific and technical foundation.
Establish
Goals
NAAQS
Acid Rain Caps ~
Visibility •
s^
'rack and Evaluate
Results
^*~~~
Emissions ^^^
Rule Effectiveness —
Monitoring (air quality)
Modeling
Record Keeping
Reporting
Determine
Emissions
Reductions ..
Monitoring
Emissions
Inventories
Modeling
Implement
Reduction
Strategies/
Enforcement
Sources Comply
Permits
Develop Reduction
Programs
National Rules
Mobile Sources
Fuels
NSPS Stationary
MACT / Residual Risks
Acid Rain Program
Regional Programs
State/Local/Tribal
Plans
Figure 4. Conceptual Diagram of the Air Quality Management Process. Air quality management
should be an iterative process of continuous improvement driven by national goals established, by
Congress or EPA (top left). Scientific and technical information are key to determining what pollutants
need to be reduced, by how much, and over what scale and time (top center). Strategies are then
developed to achieve needed pollution reductions (right). Over time, the CAA Amendments have added
emphasis on national controls for mobile sources and some stationary sources. The states (SIP process)
are responsible for developing additional reduction programs as needed. SIPs are then adopted and
enforced as sources implement reduction measures (bottom). Finally, air quality and emissions are
tracked to determine how well the measures worked to improve air quality (left). Depending on the
outcome, the process may require further iterations.
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The Work Group recognizes that among the many suggestions for change outlined, virtually all
require an expenditure of resources by EPA, States/Locals/Tribes (S/L/T), or other organizations,
and, in some cases, may require large resource commitments over many years. Thus, either new
resources need to be identified for implementation of the recommendations in this report, or a
discussion needs to occur about reallocation of existing resources at the State and Federal level.
The Work Group is very sensitive to these resource considerations and understands that priorities
must be established which reflect the practical constraints. The Work Group lacked the time and
information to complete prioritization during the first phase of its discussion, but would like to
work with the CAAAC and EPA to assist them in setting priorities over the next few months.
Key considerations should include, but are not limited to: whether the change is needed to assist
the development of ozone, PM2.5 and regional haze SIPs; whether the action is one not currently
underway, but could greatly improve the current process if implemented by a certain time; and
whether the recommendation relates to critically needed improvements that will take multiple
years to accomplish and, therefore, needs to be initiated soon.
After presenting the recommendations on which the Work Group was able to reach substantial
consensus, the report highlights a number of other crucial issues that the Work Group has
discussed. Though the Work Group has not yet been able to reach consensus on these issues, it
has engaged in considerable debate and is now prepared to summarize that debate and outline a
suggested process for further discussion in the future.
For areas requiring longer-term or more fundamental changes, the Work Group has focused on
outlining possibilities and initial steps which could steer the AQM system in the desired
direction. The final section of this report lays out important criteria to consider when designing
new air quality management programs in the future, and outlines briefly four options for a
revised AQM framework that the Work Group considered, but has not reached final conclusions.
The Work Group recognizes, however, that even these four options do not address the universe
of potential changes, either minor or substantial, that could be considered in a comprehensive
look at the current AQM system.
Next Steps
The Work Group recommends that decisions on implementation of the recommendations in this
report, as well as discussion of future options and unresolved issues, be continued over the next
several months. These continuing discussions would also allow review and/or adjustment of the
near-term recommendations if warranted. Specifically, the Work Group recommends:
• A new subcommittee of CAAAC should be established to continue the assessment and
development of recommendations for long-term changes to the air quality management
system and the issues on which the Work Group could not reach consensus. Until this
subcommittee is formed, the current Work Group should continue working to resolve
additional issues and continue discussion of long-term framework options. Following its
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establishment under the CAAAC, the subcommittee should develop a timeline for
preparing additional recommendations and provide periodic progress reports to CAAAC.
Discussion of all remaining issues and options should be directed towards further
strengthening the U.S. air quality management framework over the next decade. The
Work Group recommends that the new subcommittee, in conjunction with existing
subcommittees, also be given the responsibility for overseeing the implementation of, and
any modifications to, the recommendations contained in this report.
EPA should carefully consider the recommendations presented in this report, and should
issue a response to the CAAAC as soon as practical outlining a plan for implementing
those recommendations to the extent possible. The CAAAC should support EPA's
development of this plan. EPA should report back to the newly formed CAAAC
Subcommittee periodically on its implementation efforts.
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Air Quality Management Work Group Recommendations
In the next five sections of the report, the Work Group lays out 37 recommendations on which it
achieved substantial consensus (see matrix Table B-l). These detailed recommendations are
organized according to the five overarching recommendations of the NRC (see Figure 3, above).
At the top of each section, a header identifies the relevant NRC recommendation. The
recommendations outlined in these five sections are also detailed in Appendix A, with more
complete information about background, supporting evidence, feasibility considerations, and
preliminary resource estimates. For many of the recommendations, the Work Group has defined
an appropriate time frame for implementation, with most starting as soon as possible. This set of
recommendations, if implemented, will strengthen the current AQM system by streamlining
processes, improving the quality of data, and enhancing the efficiency and effectiveness of
current control efforts.
NRC Recommendation 1: Strengthen Scientific and Technical Capacity
The NRC noted that a key to improving air quality management in the United States is
improving our knowledge concerning the sources and emissions of air pollutants and their
precursors, the mechanisms for their fate and transport, and their impacts on human health and
the environment. Achieving these goals will require significant efforts on many fronts. First, the
Work Group recommends significant improvements to the collection, management, and analysis
of emissions and ambient air quality data. This step is critical for moving the nation's AQM
system toward a more performance-oriented approach, and for supporting a framework to track
significant health- and ecosystem-based outcomes. On the scientific and technical front, the
Work Group makes the five recommendations below.
The first two recommendations focus on improving the information we currently have about
emissions of air pollutants. Recent studies have noted many deficiencies with current emissions
inventories (e.g., NARSTO 2004), such as poorly defined emissions factors and inefficient
emissions reporting. Improved emissions inventories are needed to provide for more effective
planning for control strategies and to meet future air quality challenges. Therefore, the Work
Group recommends:
1.1 Emissions Measurements and Reporting - EPA, in conjunction with
States/Local/Tribes (S/L/T) and affected stakeholders, should pursue improved emissions
measurements and reporting to enhance emissions databases for more accurate air quality
assessments and tracking of progress. A strong national effort is needed to require emissions
measurements and reporting for as many major source categories as possible. The primary
objective of this recommendation is to produce accurate emissions data for supporting
control strategy planning and tracking progress (and establishing accountability mechanisms
because they reduce uncertainty in emissions inventories), enhancing opportunities to
establish viable emissions trading programs, supporting air quality modeling, and increasing
certainty for compliance purposes. In 2005 and 2006, EPA, in conjunction with S/L/T and
affected stakeholders, should:
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Conduct a study to identify relevant existing emissions measurement methodologies,
categories to which these methodologies are necessary and appropriate, and protocols for
conducting these measurements.
Identify efforts needed to develop new emissions measurement methodologies and
technologies for other source categories (e.g., continuous emissions monitors (CEMs),7
"random" stack testing for minor sources and remote sensing).
Evaluate the need for and appropriateness of regulations to require emissions
measurements. As necessary and appropriate, EPA should undertake rulemaking to
establish these requirements as soon as possible.
Evaluate the need for and appropriateness of regulations to require reporting of emissions
measurements to a user-friendly central data base, similar to EPA's Acid Rain data base
for Electric Generating Units (EGUs). As necessary and appropriate, EPA should
establish these requirements through rulemaking as soon as possible.
Figure 5. Continuous Emissions Monitor.* These instruments provide high quality information on air emissions
and exhaust gas characteristics. See recommendation 1.1.
1.2 Emissions Factors and Estimation Methods - Where emissions measurement-based
information is impractical to obtain for air quality assessments, or where improved
projections are needed, EPA, in conjunction with S/L/T and affected stakeholders, should
improve emissions factors and emission estimation methods. A strong national effort is
needed to improve emission estimation methods for major source categories, especially for
sources that are poorly characterized or whose emissions estimates are uncertain. The
primary objective of this recommendation is to produce better emissions inventories for
supporting air quality modeling and tracking progress. In 2005 and 2006, EPA, in
conjunction with S/L/T and affected stakeholders, should:
7 CEMs are already required by Title IV of the Clean Air Act for certain Electric Generating Units, by the Ozone
Transport Commission's (OTC) NOx Trading Program for several source categories, including industrial boilers,
turbines, and cement kilns, or by numerous NESHAPS or NSPS.
8 Inquest Environmental, Inc.
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• Review existing emissions factors to identify the most significant needs, recommend and
prioritize data collection and steps necessary for improving emissions factors, and
develop and implement procedures for quickly disseminating new emissions factors.
• Review existing source profiles used in source-based (and receptor-based) modeling to
identify the most significant source profile needs, and recommend and prioritize data
collection and steps necessary for improving or developing source profiles for poorly
characterized sources.
• Conduct a study to reconcile current emissions inventories with ambient measurements.
Based on the study, EPA should work with the S/L/T and affected stakeholders to
improve emission estimates.
Recommendation 1.3 seeks to improve the usefulness and acceptance of technical information
for air quality planning and decisionmaking. The Work Group recommends:
1.3 Uncertainty in Emissions and Modeling - EPA, in conjunction with S/L/T and affected
stakeholders, should quantify and take actions to reduce uncertainty in emissions inventories
and air quality modeling applications, provide guidance for incorporating uncertainty
assessments into SIP planning, and improve communication of uncertainty to decision-
makers. Technical analyses performed to support policy development address complex and
sometimes poorly understood problems. While serious attempts are made to rely on the best
science available at the time, there are limitations to these analyses. In 2005 and 2006, EPA,
in conjunction with S/L/T and affected stakeholders, should conduct the following actions to
better characterize, quantify, and reduce uncertainty in existing emissions inventories and
modeling analyses:
• Conduct a study to evaluate sources of uncertainty in emissions inventories and modeling
analyses for all sources; identify needed data collection activities (and associated costs) to
reduce the most significant emissions uncertainties; and identify appropriate methods for
incorporating uncertainty in preparing emissions inventories and conducting modeling
analyses. Uncertainty also is present in monitoring data, but it can be better
characterized.
• Provide guidance to S/L/T for incorporating uncertainty assessments in SIP and Tribal
Implementation Plan (TIP) planning.
Recommendation 1.4 seeks to provide more scientifically relevant and responsive data for air
quality planning and tracking progress, and to provide a more robust and spatially complete basis
for current and future air quality planning. Specifically, the AQM workgroup recommends:
1.4 Multipollutant Monitoring - EPA, in conjunction with S/L/T and affected stakeholders,
should promote and improve integrated, multipollutant monitoring. Over the past 30 years,
the air pollution situation has changed significantly as control programs have reduced
emissions of many pollutants and as science has identified emerging issues of concern.
Accordingly, it is important that air monitoring efforts be more dynamic and responsive to
meet the current and future public, regulatory, and scientific needs. To promote and improve
10
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monitoring over the next 3-4 years, EPA, in conjunction with S/L/T and affected
stakeholders, should:
• Finalize its proposed national ambient monitoring strategy, and S/L/T should, as
appropriate, work together on a regional scale to consider the need for, and, if appropriate
develop, regional monitoring strategies.
• Establish a minimum of six Level I (research-grade) NCore sites with reasonable
geographic coverage (e.g., one each in the Northeast, Southeast, Midwest, and South, and
two in the West), and in conjunction with S/L/Ts, establish the Level II (multipollutant)
NCore sites (see Figure 6).
• Support research and development to improve monitoring methods for several pollutants,
including PM2.s, PM-coarse, and air toxics.
• Promote policies to avoid disincentives for monitoring.
• Promote co-location of atmospheric dry and wet deposition monitoring with long-term
monitoring of ecological conditions whenever possible.
Figure 6. Enhanced Multipollutant Monitoring Site. Ambient monitoring site operated by the
Wisconsin Department of Natural Resources in Mayville, Wisconsin, which includes the
multipollutant measurements associated with Level II NCore sites.
At the core of the NRC recommendations for transforming the Air Quality Management system
in the U.S., was their call "to create accountability for the results, and dynamically adjust and
correct the system" in response to data from programs that track progress. The Work Group
recognizes that substantial information and tools already exist for expanding the role of tracking
in the SIP process and has made some recommendations for beginning to expand the role of
tracking and evaluation in the process (see recommendations 3.14 and 3.15). Nevertheless, the
kind of comprehensive approach envisioned by the NRC will take a concerted effort that
includes assessing the available scientific information (e.g., identifying and expanding new
research and assessments programs). To promote understanding and characterization of the
impacts of air quality changes on health and ecosystem outcomes, and to improve the scientific
basis for more informed policy decisions, including the need for and nature of air quality
standards, the Work Group recommends:
11
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1.5 Framework for Accountability - EPA, in conjunction with health and ecosystem
experts, S/L/T, and affected stakeholders, should undertake a systematic effort to track air
quality achievements and evaluate air program results. This effort should begin by focusing
on the progression and associations of air emissions as they interact and ultimately affect
human health and the environment. In order to move beyond the current approach of relying
predominantly on air quality measurements, we need to further develop and apply the
capacity to monitor, assess, and report on haw changes in emissions impact air quality,
atmospheric deposition, exposure, and effects on human health and ecosystems. Emphasis
should be placed on developing and enhancing appropriate health and ecosystem indicators,
benchmarks, and subsequent analyses within this overarching accountability framework. To
establish greater accountability for protecting human health and the environment, EPA
should better track, assess, and communicate significant results of emissions control
programs, including changes in sources and emissions, air quality and atmospheric
deposition, exposures, and effects. Emphasis should be placed on systematically measuring
progress and assessing benefits of air quality management through enhancing and expanding
the suite of benchmarks and indicators of health and ecological outcomes. The Work Group
recommends a 3-part approach involving health effects, ecosystem effects, and SIP planning
for systematically ensuring that air policies and programs are achieving intended results.
Over the next two years, the Work Group recommends:
• EPA should work with health effects experts (e.g., federal agencies under the Committee
on the Environment and Natural Resources (CENR) Air Quality Research Subcommittee;
the Clean Air Scientific Advisory Committee, the State/EPA/Center for Disease
Control/EPA environmental public health tracking partners, and the Health Effects
Institute) to develop measures to define and assess human health impacts of air pollution
and ways to track and evaluate progress in reducing those impacts. Specific actions
include:
o Facilitating communications among health research and program accountability
efforts;
o Expanding on-going efforts into public health and air quality accountability; and
o Undertaking specific accountability efforts.
• EPA should work with others to develop benchmarks and measures to assess ecological
impacts of air pollution and improve ways to track and evaluate progress in reducing
those impacts. Specific actions include:
o Improving tracking and assessing the effects of multiple air pollutants on
ecosystems;
o Conducting and facilitating integrated assessments and research to develop and
implement an appropriate suite of measurements for detecting ecosystem
response;
o Facilitating and pursuing collaboration on integrated assessments; and
o Examining the possibility of using critical loads and thresholds.
• EPA should work with S/L/T to determine appropriate metrics which should be used to
more effectively track progress.
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NRC Recommendation 2: Expand National and Multistate Control Strategies
As the NRC has indicated, national and multistate approaches to pollution control have been
particularly effective in reducing emissions and should be implemented more widely. In
addition, national or regional approaches incorporating cap-and-trade provisions can be efficient
mechanisms for reducing regional air emissions. While recent initiatives such as the NOX SIP
Call, the proposed Clean Air Interstate Rule (CAIR), the Heavy-Duty Diesel Rule and the Non-
Road Rule are expected to expand the use of regional and national strategies, the Work Group
has identified a number of significant stationary and mobile source categories with substantial
emissions which should be evaluated for potential controls.
States face an ambitious schedule for attaining the PM2.s and 8-hour ozone standards (in 2010 for
PM2.5 and beginning 2007 for ozone), and for meeting regional haze requirements. The NRC
report clearly states that regional and national controls are an integral part of any national
strategy for cost-effective attainment of these standards.
The NRC also recognized, however, that continued nonattainment for ozone and PM2.s as
projected for 2010 (assuming implementation of currently planned emissions control measures),
will require a multipronged approach that includes innovative, federally supported local
measures as well as regional or national controls. The Work Group agrees that an approach
combining a variety of different measures will be most effective in reducing air pollution
nationwide and solving the worst problems in nonattainment areas. Furthermore, a combination
of local, regional, and national approaches targeting particular sectors is likely to be the most
effective in addressing pollutants in a comprehensive and integrated fashion (see NRC
Recommendation 4 on multiple pollutants). Therefore, strong and timely regional and national
approaches are needed to complement State and local controls to help the nation achieve rapid
improvements in air quality.
To help direct choices of control strategies in the next few years, the Work Group considered
future year (2010) regional and local (nonattainment area) emissions inventories, select source
apportionment studies, and modeling analyses. The future year regional emissions inventories
were used initially to screen a list of more than 40 categories of mobile, stationary, and area
sources, and to identify those with the more significant criteria pollutant emissions (see Table 1).
The other information (i.e., nonattainment area emission inventories, source apportionment
studies, and modeling analyses) was then used to help determine whether these source categories
are better addressed at the national/regional level or the local level.
As a result of its deliberations over the past six months, the Work Group advances several
specific recommendations about particular sectors or strategies. Some of these recommendations
suggest regulations at the regional and/or national level as appropriate, while others concern
national guidance for potential application at the local level. Some of the recommendations
apply to mobile sources, while others focus on stationary or area sources.
Air emissions from the recommended categories are projected to continue to be substantial (see
Figure 7). However, a variety of factors must be considered in determining whether and how a
sector can be effectively regulated, including pollutant type, geographic location, dispersion
13
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patterns, multipollutant interactions, control strategy availability, emissions reduction potential,
and cost-effectiveness. Some Work Group participants believe that adequate information exists
to begin the regulatory process now for certain source categories, while others believe that
additional'data and data analyses are necessary. After extensive deliberations, the Work Group
recommends that each of the sectors listed below be addressed in some fashion by EPA. This
action may include, but should not be limited to, development of national and/or regional rules,
control technique guidelines, other guidance, and/or further study.
I
I
UJ
PM2.5 DS02 HNOX OVOC SCO
y >
^N Ao*
v> ^v
V
Figure 7. Projected 2010 National Emissions for Key Source Categories. In developing
recommendations relating to the source categories shown here, Workgroup analysts examined
projected emissions of five key criteria pollutants to 2010 for a list of 40 stationary and mobile
categories. Excluding EGU and natural emission sources, the categories shown comprise over 70
percent of the national SOx and NOx emissions and about 30% of the direct PM2s and VOC
emissions. These projections include recognized uncertainties in the current inventory and the
forecast. Due to data limitations, the assessment did not include estimates of air toxics emissions
or ammonia.
In each case, EPA should review the contributions from these categories, assess the technical and
economic feasibility of further controls, and conclude this review process as soon as possible,
given the urgency of achieving effective air quality improvements. EPA should initiate
appropriate actions regarding the category consistent with the results of its analysis as soon as
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possible. Because cost-effectiveness and technical feasibility are important considerations, EPA
should also consider whether market mechanisms or program design elements, such as cap-and-
trade provisions, can be employed to improve environmental results while maximizing flexibility
and efficiency.
Sectors for Further Study and Possible National and Regional Regulations
The Work Group recommends that EPA consider developing national and/or regional rules for
sectors identified as key contributors to nonattainment from a national or multistate perspective.
The Work Group acknowledges the importance of working more directly with these industry
sectors to further evaluate the emissions contributions from the respective categories.
Stationary and Area Source Categories
2.1 Industrial, Commercial, and Institutional Boilers - EPA should complete as soon as
possible a review of the contributions from this category and the technical and economic
feasibility of further controls, given the high priority assigned to this sector. EPA should then
initiate development of a regional or national emissions control regulation for the category, or
take alternative action consistent with the results of its analysis.
2.2 Industrial Surface Coatings - EPA should complete as soon as possible a review of the
contributions from this category and the technical and economic feasibility of further controls.
EPA should then initiate development of a regional or national emissions control regulation
for the category, or take alternative action consistent with the results of its analysis.
23 Non-Industrial Solvents - EPA should initiate rulemaking efforts to establish minimum
performance standards (i.e., national rules) for this category using the volatile organic
compound (VOC) content limitations contained in, and regulating the products covered by,
the model rule developed by the Ozone Transport Commission.
2.4 Architectural Coatings - EPA should initiate rulemaking efforts to establish minimum
performance standards (i.e., national rules) for this category using the VOC content
limitations contained in, and regulating the products covered by, the model rule developed by
the Ozone Transport Commission.
Mobile Source Categories
In the mobile source category, the Work Group endorses the following recommendations made
by the Mobile Source Technical Review Subcommittee of the CAAAC:
2.5 Heavy-Duty Diesel Engines - EPA should reduce emissions from the existing fleet of
heavy-duty diesel engines by employing a multi-pronged approach. Over the last decade,
EPA has moved aggressively to strengthen federal emissions standards for a wide range of
diesel engines. While these standards will serve to dramatically lower emissions when fully
implemented, the full human health benefits will not be realized for 20 years or more. The
delay in achieving emissions reductions is attributable to two factors: the fact that emissions
15
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standards do not take effect for new engines until 2004-2007, and the long lifespan of the
existing fleet of diesel engines. The Work Group recommends that EPA employ a variety of
strategies to monitor and reduce emissions from the in-use fleet. This is a high priority for
action within the next 3-4 years. Recommended actions include:
• Continue working with manufacturers to ensure heavy-duty compliance and supporting
initiatives such as heavy-duty inspection and maintenance programs, harmonized
nationwide on-board diagnostics requirements for heavy-duty vehicles, and development
of portable emissions measurement capabilities for diesel PM.
• Encourage voluntary programs for diesel retrofits, idling reductions, and other emissions
control strategies, concentrating on the construction, port, freight, and school bus sectors.
Some members of the Mobile Source Technical Review Subcommittee believe EPA should
consider expanding current federal programs through a mandatory program of accelerated
retirements, retrofits, repowering, replacement and anti-idling measures. These stakeholders
believe EPA should encourage retrofits for all heavy-duty diesel engines by 2012 by: (a)
establishing mandatory measures to cut pollution from existing diesel engines; and (b)
seeking Congressional appropriations to expand funding for programs aimed at reducing
emissions from heavy-duty engines.
2.6 Emissions from Ships, Locomotives, and Aircraft, and Mobile Source Air Toxics -
EPA should address emissions from ships, locomotives, and aircraft, and mobile source air
toxics through national emissions standards. While emissions from most categories of
mobile sources have stabilized or decreased over the past two decades, emissions from ships,
aircraft, and locomotives have increased and are forecast to continue to increase (Figure 8).
Nationally, these sectors produce substantial emissions of both criteria pollutants and air
toxics, and they represent major sources of pollution at the local level. EPA should control
criteria and toxic pollutant emissions from ships, aircraft and locomotives, and other mobile
source air toxics by:
• Promulgating technology-forcing emission standards for all new marine diesel engines,
all new and rebuilt locomotive engines, and all aircraft engines.
• Developing national rules to control mobile source air toxics and criteria pollutants
through fuel reformulation (e.g., national benzene cap, lower sulfur fuels).
• Developing strategies for reducing emissions at airports, seaports and rail yards that can
be employed at the S/L/T level, such as reducing engine idling and taxiing, imposing
differential landing fees, using gate-powered electricity, or reducing emissions from
ground service equipment.
EPA has already begun action for some of the source categories outlined above. Current plans
call for a Notice of Proposed Rulemaking (NPRM) on gasoline outboard, stemdrive, inboard and
personal watercraft engines in the Spring of 2005; an NPRM on locomotive and marine diesel
standards in mid-2005; an NPRM on air toxics in mid-2005; a final rule adopting the existing
International Civil Aviation Organization NOx standards for aircraft engines in 2005; and a final
rule on ocean-going marine diesel engines by mid-2007. EPA should give high priority to
16
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continuing the development of these standards and adopting additional control strategies, as
necessary.
14,000,000
12,000,000
10,000,000
8,000,000
6,000,000
4,000,000
2,000,000
0
1996
2030
m on-high way
D nonroad-diesel
m other nonroad
m aircraft
8 locomotives
• marine
Planes
Trains
Ships
Figure 8. Mobile Source Nox Emissions Projections. Over the next 30 years, highway emissions
are projected to decrease greatly, with the result that categories with limited controls - ships,
locomotives, and aircraft - will become of increasing relative importance for air pollution control
strategies. See Recommendation 2.6
Evaluation of Additional Emissions Reduction Potential and Cost-Effectiveness
For some sectors, the Work Group did not reach consensus on whether there are sufficient data
to recommend that EPA consider national and/or regional strategies at this time. The Work
Group determined that additional research and consultation was necessary to clarify the timing
and levels of national or regional pollution-reduction measures that would be appropriate for the
following potentially important sectors:
2.7 Cement Manufacturing, Petroleum Refining, and Pulp and Paper - The cement
manufacturing, petroleum refining, and pulp and paper industrial source categories are already
under substantial regulation, but continue to be significant sources of pollutants and warrant
further consideration by EPA. EPA should evaluate potential national or regional emissions
reduction strategies for criteria pollutants and air toxics in these categories. This should
include improving emissions inventories if necessary and assessing their impacts on
nonattainment areas or other sensitive areas. EPA should carefully consider the cost-
effectiveness of imposing additional controls as it determines whether additional emissions
reductions are justified and should take action consistent with the results of this analysis.
2.8 Residential Fossil Fuel Combustion - EPA should evaluate the potential for expanding
the Energy Star voluntary program to gain additional criteria pollutant emissions reductions
(as well as improve energy efficiency) from the residential fossil fuel sector. As part of this
effort, EPA should continue to gather information on the characteristics of residential fossil
fuel emissions and their contributions to nonattainment, and the magnitude and cost of
17
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potential emissions reductions under a voluntary program and/or expanded use of low-sulfur
fuel. EPA should also coordinate with Regional Planning Organizations (RPOs) and
companies that produce lower-emitting appliances to assess the potential for programs that
promote the installation of such technologies.
National Guidance for Local Controls
National rules are complex and take several years, at minimum, to develop for any industrial
sector. Recognizing that many of the most severe air quality problems in the nation demand
more immediate action to assist S/L/T in developing their Implementation Plans for ozone,
PM2.s, and regional haze, the Work Group recommends that, in addition to developing national
and/or regional rules for the sectors discussed above, the EPA should issue guidance as soon as
possible for use at the local level or offer additional federal support for existing local-level
programs. Specifically:
2.9 Guidance for Local Control Measures in Key Sectors - EPA, in conjunction with S/L/T
and affected stakeholders, should prepare federal guidance for local (urban-scale) control
measures to support the upcoming round ofozone and PM^sSIPs, and, if possible, optimize
multipollutant control benefits and opportunities for criteria and hazardous air pollutants.
Federal guidance is needed by October 2005 to assist States in preparing SIPs to address
ozone and Plvks nonattainment and regional haze milestones. Based on a preliminary review
of available ambient monitoring data, source apportionment studies (see Figure 9), modeling
analyses, and emissions inventories, the Work Group recommends that EPA, in conjunction
with S/L/T and affected stakeholders, should issue guidance as soon as possible for the
following source sectors:
• Residential wood stoves and fireplaces
• Open burning
• Mobile sources (high-emitting vehicles and diesel retrofit programs)
• Industrial operations (e.g. cement manufacturing, petroleum refineries, pulp and paper,
metals, and surface coating)
In prioritizing development of the guidance, EPA should consider factors such as emissions
reduction potential, timeliness, cost effectiveness, completeness of existing guidance, and
reactivity. Additionally, EPA, in conjunction with S/L/T and affected stakeholders, should
continue to assess other source categories that would benefit from local (urban-scale)
strategies. The identification of these categories should be based on the same factors cited
above (e.g. evaluation of ambient monitoring data, source apportionment studies, modeling
analyses, and future year emissions inventories). As appropriate, EPA should issue technical
guidance for other source categories.
At this time, the Work Group is advancing more detailed recommendations for three of the listed
sectors. In keeping with the NRC's recommendation to focus on areas with the highest risk, the
Work Group recommends the highest priority be placed on implementing local controls for these
sectors in areas that do not attain the ozone or PM2.s standards, or that have air quality close to
the standards:
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3% 3%
18%
36%
D Secondary sulfate
• Secondary nitrate
D mobile
• diesel
• industrial
• woodsmoke
E3 soil
22%
13%
Figure 9. Fine Particle Source Apportionment.' Estimated source contributions (%) to annual
average PM2.5 concentrations in St. Louis, Missouri (2000-2003). Secondary ammonium sulfates and
nitrates are formed from reactions of SO2, NOx, and NH3 emissions from a variety of sources over
large scales. The relative fraction of source contributions can vary significantly among different urban
areas. The apportionment results also may vary with analysis methodology uncertainties and
monitoring.
2.10 Residential Wood Smoke - EPA should farther develop the Residential Wood Smoke
Reduction Initiative that includes working with S/L/T, industry, non-governmental
organizations and others to support and facilitate the changeout of dirty, inefficient,
"conventional" (pre-New Source Performance Standard or NSPS) woodstoves with new,
cleaner, and more efficient heating appliances (e.g., EPA certified wood stoves). Concurrent
with the development and implementation of changeout programs, EPA should commence
efforts to revise the NSPS. Residential wood smoke contains various types of toxic air
pollutants (e.g., polycyclic organic matter) and contributes 420,000 tons of direct PM2.5
emissions annually. Almost 80 percent of these emissions come from about 10 million wood
stoves currently in use, 80-90 percent of which are pre-NSPS stoves. Many Tribes are
affected by wood smoke from dirty stoves causing serious health problems in Indian
communities. The voluntary residential wood smoke reduction initiative EPA began in 2004
should be expanded, with substantial increases in grants to States and Tribes to retrofit or
replace existing woodstoves. In parallel, on the national level, EPA should update the NSPS
to ensure that all wood stoves reflect the kind of clean technology available today (see Figure
10). In addition, EPA should consider emission control opportunities for fireplaces and
"Analysis of Midwest PM-Related Measurements" (draft), Philip K. Hopke, Jong Hoon Lee, Center for Air
Resources Engineering and Science, Clarkson University)
19
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outdoor wood boilers. While many of the aspects associated with this entire effort are local in
nature, some are national in scope and require a national effort.
Figure 10. Woodstoves.10 The change out of a) dirty, inefficient "conventional woodstoves with b) new
cleaner and more efficient appliances could potentially increase overall efficiency by 20 - 30 percent.
2.11 Open Burning - EPA should -work with S/L/T to encourage more vigorous control of
open burning, especially in, and adjacent to, counties with Class I areas and counties
classified as nonattainment for fine particles or ozone. Open burning releases substantial
emissions of PM2.5, VOCs, carbon monoxide, and other pollutants of concern. Emissions
from open burning, released near the ground and most often in relative proximity to inhabited
areas, contribute to urban smog, regional haze, ozone, and elevated PM2.5 readings, and cause
periodic localized exposures in excess of acceptable risks. To encourage controls on open
burning, EPA and S/L/T should work cooperatively to develop guidance, model rules, and
communication strategies for deployment at the local level. In addition, EPA should develop
methods for crediting open burning control strategies in SIPs/TIPs. Open burning is of
critical interest to Tribes near or in urban areas, as well as rural areas. Agricultural concerns
also need to be considered.
2.12 High-Emitting Gasoline Vehicles - EPA and S/L/T should reduce emissions from high-
emitting gasoline vehicles that are believed to contribute a high fraction of mobile source
emissions. Increasingly stringent regulation of new vehicle emissions has had a large
positive effect on overall fleet emissions reductions. As a result, an increasing portion of
uncontrolled mobile source emissions are produced by a relatively small fraction of high-
emitting vehicles (such as poorly maintained vehicles or older vehicles). Future emissions
10 Photo Credit: Wood Heat Organization, Inc.
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reductions in this sector depend on identifying and controlling such vehicles. In the next 3-4
years, EPA should:
• Determine the impact of high-emitters on today's mobile source inventory, using new
data sources and improved analytical techniques.
• Encourage the continued development of on-road vehicle remote sensing or other
technologies to enhance high-emitter identification programs for pre-1996 vehicles.
• Continue to evaluate the effectiveness of on-board diagnostic systems, tailpipe emissions
testing, and new technologies to identify post-1996 high-emitting vehicles.
• Make use of new technology as it becomes available to improve detection of high-
emitters.
• Continue to support State and local inspection and maintenance programs and initiatives
designed to repair high-emitting vehicles or remove them from the road.
Implementing these recommendations will have significant, but variable, impacts on air
quality throughout the nation, depending on the proportion of high-emitters in local
inventories.
2.13 Conformity - Conformity should be retained as part of the nation's AQM system. The
Work Group and the Mobile Source Technical Review Subcommittee wish to emphasize that,
in addition to other mobile source initiatives in local nonattainment areas, the overall
transportation planning approach embedded in the conformity program should continue to
receive substantial federal support. The NRC found that the transportation conformity
program has significantly reduced pollution levels in cities around the country, with die
greatest impact in nonattainment areas experiencing rapid growth. Furthermore, the program
has "fostered greater interaction" between transportation planning and air quality regulatory
authorities, resulting in knowledge transfer and mutual respect. Therefore, conformity's
current key requirements and schedules must be retained and effectively enforced.
Additionally, nature administrative action should consider (1) protecting sensitive populations
from localized, elevated particle pollution levels; and (2) expanding emissions budgets under
the general conformity program to limit emissions from other significant transportation
sectors (e.g., marine ports, rails, airports and freight).
Even with the application of these complementary strategies at the national, regional and local
levels, the Work Group recognizes the possibility that certain nonattainment and emissions-
transport problems may not be resolved. Further analysis of nonattainment problems projected
to persist after implementation of these recommendations may suggest additional controls on
certain sectors, and/or alternative or supplementary approaches to improving air quality.
NRC Recommendation 3: Transform the SIP Process
Among the most immediate and critical areas in which the NRC and the Work Group advocate
change involves the ways SIPs are developed, processed and evaluated. Recognizing that the
SIP/TIP process can be cumbersome and time-consuming for S/L/T, the Work Group proposes a
number of steps that would improve the SIP process and facilitate more integrated,
21
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comprehensive air quality management. These recommendations fall into two categories: 1)
immediate changes that will provide incremental improvements by streamlining the SIP process,
and 2) additional steps that begin the longer-term task of transforming the SIP process in more
substantial ways. Taken together, these recommendations will improve accountability, promote
innovative approaches to air pollution problems, and help integrate key programs and
approaches.
Streamlining the SIP Process
The Work Group recognizes that the SIP process itself (See Figure 11)—the procedures by
which the SIP is managed by S/L/T; the timing of key steps; and the way stakeholders are
included in the process—could be improved significantly in the near term. Part of creating
accountability mechanisms is ensuring that necessary procedural steps are carried out with
maximum efficiency and transparency. Here, the Work Group offers several recommendations
for immediate actions that could help expedite the SIP process, encourage innovation, and
improve communication with stakeholders.
Near-Term Procedural Changes to Expedite SIP Development and Processing
3.1 Align SIP Submittal Dates - Because ozone, PM2.i, and regional haze SIPs have
similar elements and are likely to contain similar control strategies, EPA, S/L/T and other
stakeholders should strive to align the submittal dates of the three SIPs. This
recommendation is not intended to suggest changes to any deadlines for attainment or
implementation of control strategies, or to imply that a single SIP should be required for
ozone, PMzs, and regional haze. It is further recommended that, in the future, EPA should
align designation dates as appropriate to promote multipollutant SIP development. For many
States, there is likely to be overlap between the efforts necessary to address 8-hour ozone,
PM2.5 and regional haze problems. The resources saved from a holistic analysis and the
development of a single strategy as opposed to several incremental adjustments within a few
months' time may be significant. It is difficult for States to accelerate adoption of the PM2.s
and regional haze SIPs (due in 2008) to coincide with the schedule for 8-hour ozone SIPs (due
in 2007). Therefore, EPA should identify incentives (e.g. modeling assistance) it could
provide to States to accelerate the preparation of regional haze and PM2.s SIPs. It is critical
that EPA take rapid action—within the next 6 months—to provide guidance to States in time
to impact the current round of SIPs.
3.2 Protocol for SIP Development - Each State should work with the appropriate EPA
Regional Office to develop and implement a protocol for SIP development and processing that
would lay out responsibilities, expectations, and timelines for all parties. While a model
protocol should be developed, the EPA Regional Office and each State should have the
flexibility to design a protocol tailored to their specific needs. The lack of effective and
consistent communication between States and EPA historically has been an impediment to
development and processing of SIPs. To avoid delays in the SIP approval process and to limit
the insertion of new demands by EPA late in the process (after public hearings and legislative
action are well underway at the State level), EPA and the States should jointly foster the
22
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development of a model protocol within the next six to nine months outlining the SIP process.
While the protocol can be tailored to fit each particular situation, it should generally:
• Be flexible enough to address all types of SIP submittals;
• Incorporate regular mechanisms for communication, expected turnaround for EPA review
of State materials, and more streamlined processes for simpler SIPs; and
• Include accountability mechanisms.
CAA or court case mandates plan subrnirfil ,. 1
j
«y State/Local decides to revise its own SIP
.
*- -gtate prepares draft SIP and rule's
I Public hearing on SIP and rules. |
, - .............. ^ ......... f .............................. - ,
[State roakefr appropriate revisions ami .adopts SIP]
U^.. ^-~~ u , ~~~
? State submits-BIP to EPA Regional office j
.... ._ _,
********
I EPA reviews 8|P; for completeness^ J
..... "it ....... ..... '
... EPA prep
I'""
rat/disapproval in CFR ]
EPA considers publi* comnwnts'on SIP ... i
.A.M.hAnA.b..hA^..^MbJ»»i.«n.«n.fc.wwbA^«A« .^QLi.^n.'nwk..."..Jk. •
Figure 11. Major Steps in SIP Processing. The Work Group recommends a number of steps to
streamline aspects of SIP processing to expedite procedures and save significant resources without
sacrificing the benefits of public participation and comment.
3 J Clearinghouse of Approved SIPs - EPA should develop a website, similar to the Best
Available Control Technology (BACTJ/Lowest Achievable Emission Rate (LAER)
clearinghouse, containing interpretations of rules and other SIP/TIP approval-related issues.
This website could contain both policy and/or technical information depending on how it is
developed. Each EPA Regional Office should develop a website, to be updated every 12
months on or about October 1, that identifies and provides links to all statutory and
regulatory requirements in the federally approved SIP, including associated State and federal
legal citations and effective dates. Because there is no central repository for information
about SIP/TIP approvability, the process for finding answers can be very time and resource
consuming. EPA should give medium priority to developing a clearinghouse that is
accessible to States and the public. Additionally, EPA regional offices should standardize the
content and quality of websites containing statutory and regulatory requirements for
applicable SIPs. This includes providing: (a) a citation of and link to every State statute and
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regulation; (b) the State effective date; (c) the federal publication date; (d) the federal
effective date; and (e) the applicable federal register citation.
3.4 Streamline Minor SIP Revisions - For the SIP approval/disapproval phase of the air
quality management process, EPA should establish a de minimis level for SIP revisions and
streamline the processing of these revisions by the use of "letter approvals " or similar
expedited procedures signed by the Regional Administrator. EPA should, in consultation with
S/L/T and other stakeholders, develop a listing of the types of SIP actions that are eligible for
streamlined processing. Many SIP revisions submitted by States are minimal in their scope
or impact, yet such submittals must still undergo the full administrative process that is
required of all Federal rulemaking actions. To streamline the revisions approval process and
save significant resources, EPA is advised to take action within the next 12-18 months to:
• Develop guidance defining what would be considered de minimis, in terms of subject
matter, emissions limits, and the process by which such actions would be approved.
• Group in one rulemaking action a series of SIP submittals which meet the de minimis
criteria
3.5 Timely EPA Guidance - EPA guidance should be issued in sufficient time for States to
meet their SIP development deadlines. EPA should involve S/L/T and other appropriate
parties in its guidance development process. In cases where guidance is delayed, EPA should
take into consideration States' efforts to meet deadlines without the benefit of the appropriate
policy guidance. Frequently, States must prepare SIPs under a specific deadline, but are
dependent on EPA to develop guidance for the SIP. Delay by EPA in preparing guidance can
cause States to be rushed or late in meeting their deadlines, or to develop SIPs which have to
be revised later. This can lead to strained relationships between EPA and the States, public
criticism of the States, and possibly sanctions against the States. Furthermore, greater
communication between EPA and other stakeholders in the development of guidance can help
reduce implementation problems, resource expenditures, and litigation. Therefore, within the
next six months, EPA should institute a new, collaborative process for developing guidance in
a more timely fashion. In any Federal Register notice for a final rulemaking, EPA should
clarify if and when any additional guidance will be forthcoming. The Work Group would
hope that this notice should serve as a deadline to prompt EPA action.
3.6 Avoid Unnecessary Public Hearings - EPA should work with the States and Tribes to
develop a model regulation that would require a public hearing for SIP revisions only if one
is requested after public notice. This recommendation is not intended to restrict public
comment in any way; it is meant only to eliminate those hearings that no one attends. The
CAA has long been interpreted to require that a public hearing be held by States for all SIPs
and SIP revisions prior to their submittal to EPA. Holding public hearings is resource-
intensive, and while the use of State resources is completely justifiable when interested parties
testify at the hearing, in many instances no comments or testimony are offered. A work group
comprised of members of EPA's Office of General Counsel, EPA Regional Counsels, States'
Attorneys General, and Tribal attorneys should undertake a review to determine whether
holding a public hearing only upon request could satisfy CAA requirements for SIP revisions.
If so, the work group should also develop a model regulation for States to adopt for SIP
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approval that provides the circumstances and procedures for holding SIP revision hearings
only upon request.
3.7 Facilitate Redesignation Process for Certain Areas - For those areas that have not
pursued and been granted redesignation when initially eligible, and have continued to
demonstrate violation-free ambient air quality data for several years, EPA should expedite
the redesignation process. EPA should ensure that all Regions and States are aware of the
simplified procedures. This recommendation is not intended to change the requirements for
redesignation under the CAA. All EPA Regional Offices should disseminate and provide any
needed assistance on the implementation of both the May 10,1995 Clean Data Policy (CDP)
and the "Limited Maintenance Plan Option for Moderate PMio Nonattainment Areas,"
commonly referred to as the Limited Maintenance Plan Policy (LMPP). The CDP allows the
Part D SIP requirements of an approved attainment demonstration, rate of progress plan and
their associated contingency measures to be waived in areas with three or more years of
violation free data. Similarly, the LMPP can exempt an area from modeled maintenance
demonstration. These policies change and simplify the technical requirements for
redesignation, not the legal requirements.
Measures to Improve Communication to the Public
3.8 Effective Communication with Constituencies - EPA, along with S/L/T, should develop
a menu of options for effective communication to build support with a wide variety of
constituencies for clean air plans at the S/L/T level. The SIP/TIP planning process is
cumbersome, lengthy and difficult for the public to comprehend, which hinders plan
development and air quality improvements. Successfully engaging the public early in the
SIP/TIP development process builds general understanding and support. Some States and
Tribes have done this successfully, but other States could improve their outreach efforts,
particularly by fostering collaboration at the local level. EPA should also develop outreach
materials for diverse audiences explaining the SIP/TIP process and the health effects of air
pollution.
3.9 Co-Benefits of Innovative Measures - EPA and S/L/T should work collectively to
communicate the co-benefits associated with innovative measures. In keeping with the
previous recommendation, it is important for S/L/T to tailor their communication strategies to
the concerns of their audience(s). The public is concerned with basic goals, such as
improving public health and increasing economic and environmental benefits, when
considering pollution control alternatives. Overemphasis on receiving SIP credit for new and
innovative types of pollution control initiatives limits public understanding and support for
such initiatives. Therefore, EPA and S/L/T should communicate how proposed strategies and
innovations would improve quality of life more generally.
Steps to Increase Adoption of Innovative Measures
3.10 Innovative and Voluntary Measures - EPA should encourage States' efforts to
implement innovative measures by providing enhanced flexibility, SIP credit guidance,
technical support, and funding for innovative and voluntary programs. Some areas have
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implemented most of the readily available traditional emissions control strategies, but still
have not met air quality goals. As areas consider new strategies to attain the NAAQS, EPA
should continue to develop policy and technical guidance to provide States with the flexibility
to utilize innovative emission reduction strategies in their SIPs. The Work Group
recommends that within 6 to 9 months EPA should: 1) clarify and expand the channels
through which States may gain SIP/TIP credit for innovative measures by issuing additional
enabling guidance and by balancing the level of effort required for approval (recordkeeping,
reporting, etc.) with the level of environmental benefits; 2) create a clearinghouse for
information on new technologies, innovative approaches, mentoring resources, and "off-the-
shelf measures, pilot projects, and quantification techniques; 3) develop sector-based
guidance that would synthesize and clarify innovative technological approaches to reducing
pollution in key sectors; and 4) continue to offer targeted funding to promote innovation.
3.11 SIP Credits for Bundled Innovative Measures - EPA should incentivize innovative
pollution control strategies by offering SIP/TIP credit for "bundled and discounted"
measures. States are often discouraged from adopting innovative measures because those
measures are typically too small scale to result in significant SIP/TIP credit. In addition,
results of those measures may be hard to quantify or verify individually. In the aggregate,
however, such measures can provide significant air quality benefits. EPA has recently
increased the amount of presumptive SIP credit States can earn for stationary-source
innovative measures to 6 percent through its guidance on Incorporating Emerging and
Voluntary Measures in a SIP (September 2004). The Work Group recommends that EPA
build upon this initiative by granting States and Tribes SIP/TIP credit upfront for a "bundle"
of small, innovative measures, with an appropriate discount to deal with the uncertainty
embedded in these untested measures. The impact of the bundled measures on air quality
should be evaluated in the aggregate. Each approval of "bundled" measures in a SIP will
need to be conducted through full notice-and-comment rulemaking in the context of a
particular State SIP revision.
Steps toward Transformation: Improving SIP Development and Evaluation
In addition to the near-term steps for streamlining SIPs outlined above, the Work Group
recommends a number of other changes regarding the development of SIPs that should be
initiated now and pursued over the course of the next several years. These more fundamental
changes can only be accomplished over a longer time period. These recommendations focus on
the nature of the federal/State/Tribal partnership, and on increasing the role of tracking progress
and mid-course corrections. Specifically, the Work Group recommends that the current SIP
process can be transformed in the following ways:
Increasing Collaboration in SIP Planning and Control-Strategy Development
3.12 Regional Approaches to SIP Planning - For many areas, planning for new SIPs or
major revisions to existing SIPs for two or more separate nonattainment areas that are both
part of the same regional-scale air quality problem should be coordinated. If requested by a
State, EPA should work with the different nonattainment areas, Tribes and combinations of
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multistate organizations and other stakeholders, as appropriate, to assist in the development
of regional approaches to planning. This could include technical assistance such as
modeling, national or regional control strategies, model SIPs, and model rules as templates
for S/L/T adoption. State-by-State planning without proper coordination can result in a
patchwork of regulations and numerous stakeholder conflicts. As discussed in the previous
section of this report, the nature of many areas' 8-hour ozone and PM2.s problems increasingly
calls for the development and implementation of regional control strategies. In several areas,
Regional Planning Organizations (RPOs) and Multi-Jurisdictional Organizations (MJOs) are
being used successfully to develop model SIPs for regional haze (e.g. the Western Regional
Air Partnership) or ozone (e.g. the Ozone Transport Commission). The Work Group
recommends expanding such efforts within the next year to aid States in developing their
ozone and PMzs SIPs. Specifically, RPOs and MJOs can assist with developing model rules
and SIPs, and developing standardized technical support documents. EPA should encourage
flexibility in the use of grant funds allocated to RPOs and MJOs so they address multiple
ambient air pollution problems under the "one atmosphere" approach, ensuring that the most
scientifically valid and cost-effective approaches are evaluated and implemented.
3.13 Federal and State Partnership - EPA should participate with S/L/T in the SIP/TIP
development process to identify and pursue emissions reductions from important source
categories, especially those that only the federal government has the ability to address, such
as federal and international sources. The level of control sought from these sources should
be commensurate with their impact on the nonattainment area. As warranted by the nature of
the source, control strategy development should be carried out by S/L/T working either
directly with EPA or with EPA and other federal agencies. For attainment demonstration
purposes, States should be able to take appropriate credit for anticipated reductions from
these sources (whether the reductions are from regulatory or incentive programs) so long as
the control strategy and its anticipated impact are found to be consistent with EPA regulation
and guidance. States and Tribes often struggle to control existing sources, such as mobile
sources, federal sources, or international sources, over which they have limited regulatory
authority. The Work Group suggests that EPA and S/L/T could collaborate more successfully
to control such sources so mat the 8-hour ozone and PM2.s standards can be met. Specifically,
within each nonattainment area, EPA should work with S/L/T to:
• Identify and reduce emissions from national and international sources, in part by
cooperating with international standards-setting bodies and participating in international
agreements with neighboring countries;
• Reduce relevant emissions from federal sources, cooperating with other federal agencies
as necessary;
• Expedite the approval of new technologies that can be applied to existing local mobile
source fleets; and
• Develop new strategies, including multijurisdictional strategies, targeting sources that are
difficult to control at the State or Tribal level in order to help local areas achieve
attainment.
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Steps to Improve Tracking and Evaluation of Results
As the NRC report stressed, it is important to push the current AQM system towards a more
performance-oriented approach, one that measures both outputs and outcomes and ties them
together in meaningful ways. While the comprehensive vision outlined by the NRC will require
the kinds of assessment and research outlined in Recommendation 1.5, the Work Group believes
that there are important steps that can be taken to improve methods and metrics for tracking
pollution outputs, translating them into impacts, and creating feedback loops to adjust policies
and programs to make them more effective in improving public health and welfare. Specifically,
the Work Group recommends:
3.14 Weight-of-Evidence Demonstrations - In order to move beyond the current approach
of relying on air quality modeling, EPA, in conjunction with S/L/Tand affected stakeholders,
should modify its guidance to promote \veight-of-evidence (WOE) demonstrations for both
planning and implementation efforts. In particular, these demonstrations should reduce
reliance on modeling data as the centerpiece for SIP/TIP planning, and should increase use
of monitoring data and analyses of monitoring data, especially for tracking progress. The
current system is top-heavy on modeling for planning purposes, especially during the
preparation of an attainment demonstration, and light on tracking progress. Enhanced
tracking and ambient monitoring data is a better use of available resources than intensive
local modeling. As such, EPA, in conjunction with S/L/T, should:
• Incorporate a WOE approach in planning efforts to provide the most technically
defensible basis for a control plan and to satisfy any statutory requirement for a
demonstration of attainment. The WOE approach should include three elements:
o A prospective modeling analysis to identify the appropriate control path;
o Analyses of air quality data; and
o Summaries of current actual and expected future year emissions.
• Consider WOE elements such as retrospective modeling analysis (as necessary), analyses
of air quality data, and summaries of actual emissions in implementation efforts (i.e.,
periodic progress assessments, as discussed in Recommendation 3.15).
• Issue WOE guidance, which clarifies the proper role of modeling for SIP planning,
establishes standard WOE procedures, and identifies appropriate data analysis methods
(e.g., estimating statistically significant trends).
3.15 Periodic Assessments to Track Progress - S/L/T and EPA should conduct periodic
assessments to ensure that areas are on track to meet NAAQS, HAP, and visibility goals, and
make mid-course adjustments, as necessary. To lay the foundation for a performance-
oriented approach, and to help build a stronger framework for accountability, over the next
two years:
• States, Tribes, and EPA should work together on tracking progress, including a review of
changes in actual emissions and air quality concentrations, as described in
Recommendation 3.14.
• If actual progress differs "substantially" from the expected trend for a given metric, then
S/L/T should reexamine effectiveness of that attainment measure. If attainment will be
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later than the statutory attainment date, then the S/L/T authorities should determine
whether it is necessary to modify the SIP.
• EPA should report annually on health and ecosystem impacts (i.e., indicators and
benchmarks established pursuant to Recommendation 1.5).
• EPA should report annually on major control programs that it is coordinating (e.g., Title
IV and NOX SIP Call).
• EPA should prepare guidance on determining "background" air quality concentrations.
In accordance with this recommendation to improve program evaluation, the Mobile Source
Technical Review Subcommittee recommended the Work Group highlight one particular
program for detailed evaluation:
3.16 Averaging, Banking, and Trading in Gasoline Sulfur Program - EPA should
evaluate the averaging, banking, and trading (ABT) provisions included in the Tier II
gasoline sulfur regulation to see if they are effective. Averaging, banking, and trading (ABT)
provisions have been widely used by EPA to provide flexibility to industry while
aggressively addressing environmental problems. EPA should evaluate the effectiveness of
these provisions in the gasoline sulfur program as that program develops over the next few
years. The evaluation should consider the distribution of credits; the volume and nature of
trading; the impact of trading on firm-level performance; and the overall administrative
performance of the program. The evaluation should include annual analysis of available
information and a complete report when the program has been fully implemented and
patterns of credit usage are well established. EPA should consider conducting a similar
analysis for ABT when it implements the diesel sulfur program.
In addition to the specific example of program evaluation noted above, the detailed text of
Recommendation 1.5 in Appendix A notes several other programs that EPA should consider for
evaluation, such as the NOX SIP call and the CAIR.
All of the above recommendations on SIP processing, SIP development, planning,
communications, innovations, and tracking will help improve the current SIP process by making
it more efficient and more effective. These changes should all be implemented in the near term,
some because they are designed to help S/L/T with the upcoming round of SIPs for ozone, PM2.5
and regional haze, and others because they represent initial steps that will form the basis for
longer-term initiatives necessary to transform the SIP process as the NRC recommended.
NRC Recommendation 4: Develop Integrated Program for Criteria and Hazardous Air
Pollutants
The Work Group believes it is also possible to take immediate steps toward controlling criteria
and toxic air pollutants (also known as hazardous air pollutants or HAPs) in a more integrated
fashion. The Work Group agrees with the NRC that this is a critical task in the air quality
management arena, and one that has often been neglected in the past. While fully integrated
pollution control is a difficult task that will take many years and substantial reorganization of the
entire air quality management framework to accomplish fully, the earlier recommendations for
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sector-based approaches and multipollutant control strategies (2.1 - 2.13) represent some of
these steps. The following additional steps will also promote greater integration of programs
designed to control criteria and toxic air pollutants:
4.1 SIPs to Address Multipollutant Impacts - For the SIPs States are required to submit
over the next several years, EPA and S/L/Tshould promote the consideration of
multipollutant impacts, including the impacts of air toxics, and where there is discretion,
select regulatory approaches that maximize benefits from controlling key air toxics, as well as
ozone, PM2.5, and regional haze. The SIP process provides an opportunity for many urban
areas to include key toxic air pollutants in a comprehensive, multipollutant air quality plan.
While in no way reducing federal responsibilities for air toxics, this recommendation
envisions SIPs/TIPs as providing an opportunity to see how S/L/T efforts are also reducing
key air toxics, to identify what actions could be taken at the S/L/T level to supplement current
federal efforts, and to help identify priorities for federal action. EPA should focus on
developing a "short list" of critical toxic air pollutants and other widespread pollutants that
pose the highest risk to human health in urban areas. In developing this list, EPA should
consider including benzene, acrolein and diesel PM, and other widespread pollutants. EPA
should encourage S/L/T in developing their SIPs/TIPs for PM2.s, regional haze and ozone, to
evaluate opportunities for achieving co-benefits through simultaneous reduction of these key
"urban risk driver" air toxics and any other air toxics which are of high risk in their area
Because of the urgency of this task, EPA should work with stakeholders to develop and test a
model integrated SIP as a pilot project by the end of 2005.
4.2 Multipollutant Benefits and Disbenefits in Standards Setting - EPA should explicitly
outline and quantify multipollutant benefits and disbenefits when setting emissions standards.
As part of its attempts to encourage integrated air quality planning, EPA should utilize the
ongoing air toxics standards-setting process (e.g., remaining Maximum Achievable Control
Technology (MACT), residual risk, and area source standards) to explicitly consider
multipollutant effects of proposed control strategies in selecting options. Specifically, when
conducting engineering reviews to support emissions standards efforts, EPA should assess
how options identified for controlling air toxics reduce and/or increase direct PM2.s emissions,
and emissions of PM and ozone precursors such as VOC, NOX and SOj. Furthermore,
engineering reviews for air toxic standards should catalog available control options that would
reduce direct PM, SO2, VOC and NOX emissions even if those options would not reduce air
toxics.
These multipollutant measures are very important to advancing the core goals outlined at the
beginning of this report. Obviously, these recommendations promote integration of air quality
programs and approaches, thus addressing one of the main points of the NRC report. These
recommendations also enhance accountability by providing more meaningful data about
emissions and their likely impact on health and the environment. Combined with some of the
measures discussed earlier about improving tracking, monitoring, and health/ecosystem
indicators, these recommendations will help us measure progress toward desirable outcomes and
design more effective and efficient pollution control strategies.
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NRC Recommendation 5: Enhance Protection of Ecosystems and Public Welfare
Finally, the Work Group agrees with the NRC that a great deal of work remains to be done in the
areas of ecosystem protection and public welfare improvements. These are, in essence, among
the most fundamental goals of the air quality management system, and while substantial progress
has been made on both fronts in the past thirty years, there are important gaps which require new
approaches and new resources to address. The Work Group has focused on identifying a list of
critical needs that could serve as the foundation for long-term progress in the protection of
ecosystems and public welfare.
5.1 Program Review to Improve Ecosystem Protection - EPA should, in parallel with
recommended scientific and technical work, begin now to examine current and alternative
clean air related policy and programs to develop approaches that would advance the
protection of ecosystems from the adverse effects of air pollution. Alternatives that should be
evaluated include a regional cap-and-trade program, protection of ecosystems based on
critical loads, and a State-wide planning program for protecting and enhancing air quality in
areas that attain the NAAQS (including National Parks and Wilderness Areas). The NRC
stated that the system of air quality management in the United States does not go far enough
in protecting ecosystems and other aspects of public welfare from the impacts of air
pollution. The NRC noted specific policy-related deficiencies in secondary NAAQS,
tracking of ecosystem outcomes from air quality changes, and accounting for ecosystem
effects in cost-benefit analyses. The Work Group agrees with this assessment, and
recommends that, in addition to developing innovative benchmarks and measures to assess
the ecological impacts of air pollution and improving ways to track and evaluate progress
(see Recommendation 1.5), EPA should also assess the current and potential effectiveness of
major clean air programs in providing ecosystem protection. In its assessment, EPA should
consider a number of features of each program:
a) policy mandates, objectives, goals, definitions of ecosystem protection, and
historic/legal interpretation;
b) characteristics of the air pollutant(s) regulated, and potential magnitudes of impact;
c) existing measures for reporting program progress and ecosystem impacts;
d) desirable modifications to existing tracking efforts to support their application to
different regulatory programs;
e) current and future opportunities or impediments to expanding the use of ecological
science in the policy context; and
f) policy innovations or revisions that would help translate ecosystem science into
effective ecosystem protection policies.
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Figure 12. Wetland Ecosystem in NY.11 Regional air deposition is a significant source of pollution to
aquatic and terrestrial ecosystems in some areas of the US.
EPA should also assess the impact of non-regulatory programs, such as the Sustainable
Environment for Quality of Life (SEQL) project in Charlotte, NC, on the protection of
ecosystems. These projects involve innovative efforts to integrate air pollution effects
with other ecological concerns, and may serve as a model for future regulatory
approaches.
Unresolved Issues for Further Discussions
Given sufficient resources, most of the recommendations outlined in this report so far could be
implemented within the next 1-5 years under the current statutory framework. Such short-term
changes are desirable, even critical, for helping S/L/T meet the air quality challenges they
currently face. In addition to these recommendations, the Work Group also discussed a number
of other changes to the AQM system that might be beneficial. While many of these issues
provoked controversy within the Work Group, and no consensus was reached on how to handle
them, they represent opportunities for further improvements in the near- or long-term and
deserve mention here. The Work Group expects discussion of these issues to continue, and
hopes to make additional recommendations over the next several months.
Included in this group of topics for future discussion were scientific and technical issues such as:
increasing the number and distribution of air quality monitors; implementing more short-term
monitoring programs; improving the process through which emissions inventories are developed;
and promoting the use of multipollutant and multimedia technical tools.
11 Photo Credit K. Mirza/S.Olson
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In the policy and planning arena, the Work Group also had a number of unresolved issues.
Among them were: improving the transparency and consistency of the SIP process; the possible
role of geographically dispersed emissions reductions and whether they should be counted in
SIPs for nonattainment areas; improving the communication of technical information to
policymakers; integrating programs for criteria pollutants and toxic air pollutants more fully; and
accounting for pollutant tradeoffs from different emissions control technologies during
permitting at individual facilities. Many of these issues were considered medium or low priority
compared to the recommendations listed in this report, or were so complex that the Work Group
believed that it was premature to attempt to make recommendations at this time. Pending further
discussion, additional recommendations may be forthcoming in these areas at a future date.
The Work Group gave detailed attention to two other issues raised during the course of its
discussions, but was unable to reach consensus on these issues. Some participants in the Work
Group believe that an information-based multipollutant approach could be used to address
greenhouse gases as well as air toxics. The following draft recommendation was offered:
EPA should assist States to quantify the potential greenhouse gas emissions increases and
decreases for reduction measures primarily designed to address ozone, PM2.5, regional
haze, and air toxics.
The Work Group, however, could not achieve full consensus on this matter. Some members
believe that accurate analysis of greenhouse gas emissions co-benefits and disbenefits during the
development of criteria pollutant SIPs could assist States in making control measure decisions
that might provide economic multipollutant benefits. Others felt that the issue of greenhouse
gases was not central to the core focus of the air quality management system or the NRC report
(addressing criteria pollutants, air toxics and regional haze), and were not comfortable with
allocating resources to address them. Since agreement was not reached on this issue, the Work
Group recommends that discussions continue by the new CAAAC subcommittee.
A second potential recommendation discussed at length by the Work Group was the electricity
generating unit (ECU) sector because of the large contribution that this sector makes to multiple
air quality problems. Many on the Work Group believed that the active rulemaking underway on
the Clear Air Interstate Rule (CAIR) provided the proper forum for considering what this sector
ought to do for the next IS years or more; others did not. Since no agreement could be reached
on a recommendation regarding this sector, the Work Group recommends that discussions
continue by the new CAAAC subcommittee. Regardless of the outcome of any future
discussions, many of the stakeholders involved saw value in S/L/T and utilities consulting with
each other after final promulgation of the CAIR (or new legislation) to share compliance plans,
evaluate likely emissions reductions and their geographic distribution, and apply that information
to further planning activities.
All of these issues deserve further consideration and remain on the Work Group's agenda for the
future. While some of them may involve irreconcilable conflicts among stakeholders, it is the
Work Group's hope that gathering additional evidence and continuing deliberations may produce
a number of follow-up recommendations that would accompany those outlined in this report.
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Looking Forward; Long-Term Realignment of the AOM System
Among its many tasks, the Work Group also considered more sweeping changes to the AQM
framework in the United States. Such a broad-scale endeavor is necessarily a long-term project,
requiring a great deal of discussion and negotiation among stakeholders. Still, the Work Group
believes it is possible to outline some aspects of a new long-term vision. These aspects must be
taken up in greater detail in the upcoming months as the reevaluation of AQM in the United
States moves forward.
In its discussions about long-term issues, the Work Group focused on identifying core principles
around which future air quality programs should be organized. These core principles offer the
opportunity to build highly effective programs to address emerging and future air quality
problems by capturing past successes and incorporating new approaches. On top of these core
principles, the Work Group drafted a series of Framework Options: approaches to air quality
management that implement the core principles in different ways. Below, the core principles are
described, followed by a brief description of four possible Framework Options. These options
need further evaluation and discussion before any recommendations can be made by the Work
Group to the C AAAC.
Long-Term AOM Vision: Core Principles
Members of the Work Group identified ten major principles that should be further considered in
future deliberations of the long-term vision.
1. Expand application of and develop national and/or regional measures for all source
sectors (stationary, area, and mobile) to address air pollution in a nationally and/or
regionally consistent manner.
2. Integrate multipollutant considerations when addressing emissions reduction
requirements and developing control programs.
3. Include emissions reductions approaches from "non-traditional" sources and "non-
traditional" (i.e., innovative) approaches (as well as from traditional sources and
approaches) when developing plans and programs to achieve clean air goals.
4. Make the SIP process simpler, more effective and more efficient.
5. Ensure periodic review of progress to determine whether public health and environmental
protection goals are being achieved.
6. Ensure that innovative and market-based programs yield the desired levels of public
health and environmental protection, as well as being economically efficient.
7. Incorporate land use and transportation planning in clean air planning efforts.
8. To the extent feasible, integrate health risk during control strategy program design.
9. Maintain and protect States' and Tribes' authority to reduce emissions in order to protect
public health and the environment, and meet and maintain air quality standards.
10. Integrate air quality management with national energy policy to ensure coordination and
mutual support between energy policy and air quality policy.
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The Work Group did not presume that the CAA would necessarily need to be changed in order to
move in the direction of these principles, although some approaches would likely not be
achievable without statutory change. The NRC report recognized that the current AQM system
has been and continues to be effective in many aspects. The current system provides a firm
foundation to address present challenges and flexibility to adapt to developments in science and
changes in policy. Consideration of changes to the current system warrant serious and
thoughtful discussion in light of the goals to be achieved and the ultimate goal of continued
progress towards clean air.12
The Work Group envisions that future AQM efforts will involve a heightened role for the federal
government to issue national or regional programs covering multiple source sectors. These
programs and this approach will be necessary to support State, local and Tribal governments as
they address their nonattainment problems by assisting them in addressing multipollutant
interactions and pollution transport. Under die CAA, the federal government has largely an
oversight role. State, local, and Tribal governments are responsible for nearly all air quality
implementation tasks. Furthermore, the current system does not currently implement
mechanisms and processes adequate to address the significant impact of sources outside
nonattainment boundaries. The mechanisms provided by the CAA to address pollution transport
to date (SIP calls and petitions) can result in individual progress. Federal technology-based
controls targeting various industrial sectors could achieve more integrated planning and address
multipollutant interactions.
Even with a greater federal presence, S/L/T will still have considerable work ahead in order to
meet their air quality challenges and responsibilities—they hold ultimate authority and
responsibility for attaining and maintaining the NAAQS and protecting public health. By
streamlining the currently burdensome SIP process, incorporating innovative and multipollutant
solutions, developing better ways to track progress, enhancing States' and Tribes' ability to
address transported pollution, and crafting new controls on sources that only the federal
government can regulate, the AQM system can promote cleaner air across the nation.
Long-Term Framework Options
The Work Group has developed four options for anew long-term AQM framework. These
options share some of the core principles discussed above; in this sense, there is some overlap in
the approaches described. However, in other respects the options are quite distinctive, both from
the current AQM approach and from one another. These options are all in their infancy: while
they have been subject to much discussion within the Work Group, that discussion served to
highlight the complexity of the decision the nation faces in altering the current AQM system in
any significant way. Therefore, rather than attempting to flesh out any "favored" option and
recommend its adoption, the Work Group chose only to outline the four options. By presenting
the options in this manner, the Work Group hopes to carry forward its internal discussions into
the wider public sphere where these and other options will be given more considered attention.
12 NRC Report, p. 22
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Option 1
Under this option, all stationary sources nationwide that emit above a specified threshold of a
criteria pollutant or HAP would be required to reduce emissions of the full set of pollutants.
New sources would be required to install state-of-the-art controls equivalent to LAER, while
emissions from existing sources would be capped at a specified minimum level of control.
Individual States would not need to go through the standard-setting process, but would retain
their authority to adopt more stringent standards as necessary. To enhance flexibility, the option
would incorporate emissions trading for some pollutants and would offer the possibility of
reduced NSR obligations. A similar, national performance standard approach would be used for
area sources. For mobile sources, EPA would expand its existing mobile source programs by
regulating all HAPs from mobile sources and their fuels, and establish new national standards for
remaining source categories, such as locomotives, marine engines and aircraft. Further
reductions could come from a national mandatory diesel retrofit program and other restrictions
on mobile sources and fuels.
States and localities would be responsible for conducting ambient monitoring of criteria
pollutants and HAPs to identify where unacceptable pollution levels persist after the application
of national performance standards, and for ultimate attainment and maintenance of the air quality
standards. In fulfilling these responsibilities, they would be subject to a "SIP lite" requirement,
whereby they would develop local plans to address remaining air pollution problems.
Option 2
Modeled after the successful CAA Title IV acid rain trading program, a second option would be
to set caps for emissions from certain source categories and allow trading. As in Option 1, the
federal government would take the lead in controlling sources, with States responsible for
addressing hotspots, residual risk, and transportation and land use planning measures. This
approach is probably most amenable to large and medium stationary sources, but could also be
applicable to some smaller stationary and area sources, if minimum criteria for participation in a
trading program could be met.
This approach's coverage would be national and involve all major air pollutants, but could be
regional for a given pollutant if certain demonstrations were made. In general, control programs
should cover most sources within a source category, controlling 90 percent of emissions of each
major pollutant from the category. Most sources would have an emissions control obligation, but
would not necessarily need to make reductions on-site. Individual emitting sources would not be
able to opt out of regulation altogether, but could receive compliance flexibility in a sector that is
not regulated with emissions trading.
Trading would be allowed across participating stationary and area sources for criteria pollutants.
Trading might be restricted for air toxics to prevent hotspots, and trading between mobile and
stationary sources would not be permitted. Initial caps/reduction targets would be set quickly
(within five years) based on cost-effective control levels and adjusted periodically (every eight to
ten years) considering emissions reductions needed to meet environmental goals. This would
provide long lead times for technology advancement and a high degree of certainty to industry
while providing a mechanism for continuous improvement towards environmental goals.
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Allowance allocations would also be used to encourage technology advancement. All new
sources would be required to meet state-of-the-art controls.
Option 3
A third option would establish innovative technology-promoting programs and national or
regional multipollutant performance standards. The program would be national or regional,
depending upon the sector and the air quality objective, and would cover criteria pollutants and
toxic air contaminants. The multipollutant performance standards would be designed to achieve
attainment and other appropriate air quality objectives (e.g., visibility, risk reduction) in most
parts of the country. The States would be responsible for addressing residual nonattainment.
The program would apply to most sectors, including stationary, mobile and area sources. New
sources would be required to install "best integrated control technology," which EPA would
establish on a sector-by-sector and multipollutant basis after consideration of several factors,
including the technology's impact on criteria pollutant and toxic air pollutant emissions, and any
adverse macroeconomic impacts. Most existing sources would be required to comply with a
multipollutant emission reduction obligation set by EPA based on various sector-specific
considerations, including public health, ecosystem, energy, technical, economic, and market
considerations.
The program would also include demand-side and incentive-based strategies to encourage the
development and use of clean technologies. These strategies include a pre-certified credit
program; a clean air investment fund; and retail choice, transportation mode choice and energy
choice programs. This option also includes measures to ensure that trading does not interfere
with risk-reduction or public health benefits.
Option 4 - Continuous Improvement Program
A fourth option, based on the Toxics Release Inventory, would set reporting standards for all
major stationary sources and require an annual report of all relevant air emissions (HAPs,
criteria pollutants, and criteria precursors). The reporting could be done by source category or
on a national basis. The program would provide a metric to determine the relative pollution
efficiency of the facility (pollution per unit of production).
A threshold would be set above which facilities would be required to control emissions within a
three- to five-year period. Emissions trading would be permitted and sources that went beyond
compliance could bank the credits in accordance with national rules. The program would be
adjusted on a cycle set forth in the rule (three to five years). Annual reports would serve as a
benchmark to let everyone know how a facility ranks, thus creating a reduction incentive. New
major sources would be required to install state-of-the-art control equipment. Because of the
continuous improvement features of the program, NSR requirements could be lessened or
removed. Program safeguards for attainment demonstrations and increased risk to the public
from HAPs would have to be established.
Certain area sources (e.g., consumer products and solvents) could be controlled by this approach,
while others would be controlled using traditional CAA programs. Innovative programs could be
implemented at the national and local levels to effectively address these sources. Area sources
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that represented a large portion of the national inventory may require rule making at a regional or
national level.
Moving Forward: Continuing the Evaluation Process
These options represent four models out of many that could be developed as alternative futures
for air quality management efforts in the United States. Though each option has some strong
features, in each case many questions about a new AQM framework remain unanswered,
including:
1. How the federal and S/L/T governments would interact under a scheme that envisions
sharing the responsibilities previously reserved for S/L/T governments, and how
jurisdictional responsibilities would be defined;
2. How risk and economics would be factored into the decision-making process;
3. What is the role of energy, land use and transportation planning under the new
paradigm;
4. How innovative solutions (including pollution prevention) are incorporated into the
approach;
5. How the responsibility of various sources/sectors is determined under this process;
and
6. How the various pollutants relate to each other and the environment in a
multipollutant program.
These challenging questions should be addressed in any future discussions on recommendations
for a long-term course of reform. Answering these questions and properly evaluating all of the
nuances and implications of the options described above, as well as other possible options, will
require detailed consideration by the CAAAC and an extensive dialogue between stakeholders.
The Work Group recommends that this process of evaluation be carried forward during the next
year, along with the implementation of the near-term recommendations outlined in this report.
Conclusions
The Clean Air Act has been one of the most successful and cost-effective environmental statutes
enacted since 1970. As described at the outset of this report, over the last three decades the
nation has achieved major reductions in air pollution while population, energy consumption,
gross domestic product, and vehicle miles traveled have expanded. The Clean Air Act provides
a strong foundation for the protection of public health and the environment, offering powerful
control mechanisms to combat serious pollution problems while also remaining flexible enough
to accommodate advances in scientific knowledge and new policy priorities.
Despite the substantial improvements in air quality over the past 30 years, however, there are
important challenges ahead. As the most obvious pollution problems have been solved, other
problems have moved into the spotlight. Advancing scientific research indicates that human
health is threatened at very low levels of pollutant exposure, and toxic hotspots continue to affect
localized populations. The impact of air pollution on ecosystems also needs further scientific
study and policy action.
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In order to address these challenges, we must adopt new approaches to air pollution control. In
addition, we must acknowledge that traditional approaches to controlling air pollution, while
effective, have not always been efficient. Recent experience with cap-and-trade mechanisms and
other market-based approaches has shown that there is room to improve the efficiency with
which pollution reductions are achieved. As we move forward with air quality management
efforts, we must look for additional opportunities to streamline processes and enhance program
efficiency.
The recommendations presented in this report offer concrete opportunities to improve the
efficiency and effectiveness of current air quality programs. These recommendations build on
the existing Clean Air Act and help enhance the current framework. They also serve as building
blocks for potential long-term change. The report only begins to describe some of the
possibilities before us as we move into anew era in air quality management. With the success of
the past thirty years behind us, we should carefully consider the opportunities for improving air
quality in the future, and move forward deliberately and enthusiastically to address new
challenges.
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Appendix A
Air Quality Management
Work Group
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Air Quality Management Work Group
Janet McCabe, Co-Chair
Indiana Dept of Environmental Management
Greg Green, Co-Chair
U.S. Environmental Protection Agency
MEMBERS;
Tad Aburn
Maryland Department of the Environment
Praveen Amar
Northeast States for Coordinated Air Use Management (NESCAUM)
William M. Auberle, P.E. (CAAAC)
Northern Arizona University
Robert V. Avant, Jr., P.E. (CAAAC)
Texas Food & Fibers Commission
John Bachmann
U.S. Environmental Protection Agency
William Baker
U.S. Environmental Protection Agency, Region 2
Elaine Barren, M.D. (CAAAC)
Joint Advisory Committee Paso Del Norte Air Quality
S. William (Bill) Becker (CAAAC)
Amy Royden-Bloom
State and Territorial Air Pollution Program Administrators
Association of Local Air Pollution Control Officials (STAPPA/ALAPCO)
Don R. Clay (CAAAC)
Koch Industries Inc.
Jeanette Clute
Jerry Roussel
Ford Motor Company
Kenneth A. Colburn (CAAAC)
Northeast States for Coordinated Air Use Management
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Patrick Cummins
Western Governor's Association
Pamela M. Giblin (CAAAC)
Baker & Botts L.L.P
Eric Ginsburg
U.S. Environmental Protection Agency
Lisa P. Gomez (CAAAC)
Sempra Energy
Charles H. Goodman
Southern Company Generation
Ned Helme (CAAAC)
Stacey Davis (alternate)
Center for Clean Air Policy
Jim Hendricks (CAAAC)
Duke Energy
Ben G. Henneke, Jr. (CAAAC)
Clean Air Action Corporation
John E. Hornback
Metro 4, Inc./Southeastem States Air Resource Managers, Inc.
Carter Keithley (CAAAC)
John Crouch
Hearth, Patio & Barbecue Association
Mike Koerber
Lake Michigan Air Directors Consortium
Douglas A. Lempke (CAAAC)
Colorado Department of Public Health and Environment
Mark MacLeod
Vickie L. Patton (CAAAC)
Environmental Defense
Patricia Marietta (CAAAC)
Gila River Indian Community
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Dennis McLerran
Jim Nolan
Puget Sound Clean Air Agency
Jeffrey M. Mears
Oneida Tribe of Indians of Wisconsin
J. Mark Morford
Stoel Rives LLP
Chuck Mueller (CAAAC)
Texas Commission on Environmental Quality
Jeff Muffat (CAAAC)
3M Corporation
Sam Napolitano
U.S. Environmental Protection Agency Headquarters
Brock Nicholson
North Carolina Division of Air Quality
Janice E. Nolen
American Lung Association®
John A. Paul (CAAAC)
Regional Air Pollution Control Agency
Margie Perkins
Colorado Department of Public Health and Environment
Kimber Scavo
U.S. Environmental Protection Agency
Jim Scherer
Lone Schmidt
U.S. Environmental Protection Agency
John Seitz (CAAAC)
Sonnenschein, Nath & Rosenthal
David Shaw
New York State Dept. of Environmental Conservation
Eugene M. Trisko, Esq. (CAAAC)
Attorney at Law
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Peter Tsirigotis
U.S. Environmental Protection Agency
Jeff Underbill
New Hampshire
James Vickery
U.S. Environmental Protection Agency
Phillip J. Wakelyn
National Cotton Council
Lydia Wegman
U.S. Environmental Protection Agency
Roger Westman, Manager
Allegheny County Health Department
Richard D. (Dick) Wilson (CAAAC)
National Environmental Strategies
Catherine Witherspoon (CAAAC)
Lynn Terry
CA Air Resources Board
Robert A. Wyman, Esq. (CAAAC)
Latham and Watkins
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Appendix B
Recommendations Matrix &
Background Papers
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1.1 Emissions Measurements and Reporting; To enhance emissions data bases for more
accurate air quality assessments and tracking of progress, EPA, in conjunction with S/L/Tand
affected stakeholders, should improve emissions measurements and reporting.
Background/Explanation: Recent studies have noted many deficiencies with current emissions
inventories (e.g., "Improving Emission Inventories for Effective Air Quality Management
Across North America: A NARSTO Assessment", September 30,2004). The NARSTO report,
as well as the NRC recommendations, notes the benefits of collecting actual emissions data using
emissions measurement techniques, such as the continuous emissions monitors (CEMS) for
electrical generating units (EGUs) mandated by Title IV of the Clean Air Act. Improved
emissions inventories are needed to provide for more effective control strategy planning and to
meet future air quality management challenges.
Recommended Actions: A strong national effort is needed to require emissions measurements
and reporting for as many major source categories as possible. The primary objective of these
measurements is to produce accurate emissions data for supporting control strategy planning and
track progress. The Subgroup recommends that this can best be accomplished by the following
actions:
1) EPA should conduct a study to identify:
(a) relevant existing emission measurement methodologies for criteria
pollutants (and their precursors) and hazardous air pollutants (HAPs),
source categories for which these methodologies can be applied, and
protocols for conducting these measurements,
(b) efforts needed to develop new emission measurement methodologies and
technologies for other source categories (especially, those for which
current emission estimates are highly uncertainty), and
(c) costs to conduct emission measurements.
Emissions measurement methodologies that should be considered include CEMs
(which, as noted above, are already required by Title IV for EGUs, by the OTC's
NOx Trading Program for several source categories, including industrial boilers,
turbines, and cement kilns, and by numerous NESHAPS and NSPS); "random" stack
testing (which may be appropriate for minor sources); and remote sensing.
2) EPA should evaluate the need for and appropriateness of regulations to require
emissions measurements for as many source categories as possible. As necessary,
EPA should undertake rulemaking as soon as possible.
3) EPA should evaluate the need for and appropriateness of regulations to require
reporting of emissions measurements to a user-friendly central data base, similar to
EPA's Acid Rain database for EGUs. This would satisfy the compliance reporting
requirements of Title V and place the information in a location where all entities
could have access to it promptly. As necessary, EPA should undertake rulemaking as
soon as possible.
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Benefits: Collecting actual emissions data will reduce uncertainty in emissions inventories,
enhance ability to participate in emissions trading programs, support air quality modeling, and
increase certainty for compliance purposes. These data are also important to the success of most
of the other S&T recommendations. Making these data available through a central data base will
allow easier and more widespread access to the data.
Feasibility: This recommendation has a medium feasibility for implementation because it can
be completed under existing statutory authority, but will require a study to identify the source
categories and will take some time to implement.
Timing: The study can be performed in the next 6-9 months. The timeframe for establishing
emissions monitoring requirements and for implementing these requirements could take several
years.
Resources: The identification of source categories can be performed by EPA technical staff (or
by a contractor for less than $50K). The costs to conduct the emissions measurements (and
report the data), however, are unknown, but are likely to be substantial.
Priority Level: High
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1.2 Emissions Factors and Estimation Methods; Where emissions measurement-based
information is impractical to obtain for air quality assessments, or where improved projections
are needed, EPA, in conjunction with S/L/T and affected stakeholders, should improve
emissions factors and emission estimation methods.
Background/Explanation: Recent studies have noted many deficiencies with current emissions
inventories (e.g., "Improving Emission Inventories for Effective Air Quality Management
Across North America: A NARSTO Assessment", September 30, 2004). The NARSTO report,
as well as the NRC recommendations, note numerous weaknesses with current emission
estimates. Improved emissions inventories are needed to provide for more effective control
strategy planning and to meet future air quality management challenges.
Recommended Actions: A strong, systematic national effort is needed to improve emission
estimation methods for all major source categories, especially poorly characterized sources or
those for which there is uncertainty in current emission estimates. The primary objective of these
improvements is to produce better emissions inventories for supporting control strategy planning
and tracking progress. The Subgroup recommends that this can best be accomplished by the
following actions:
1) EPA, in conjunction with S/L/T and affected stakeholders, should review existing
emissions factors and consider the results of EPA's recent emissions factor workshop
("Revamping the Emissions Factor Program - A Workshop", August 25-26, 2004) to:
(a) identify the most significant emission factor needs,
(b) recommend and prioritize data collection and steps necessary for
improving emissions factors.
EPA should develop and implement procedures for quickly disseminating new
emissions factors.
2) EPA, in conjunction with S/L/T and affected stakeholders, should review existing
source profiles used in source-based (and receptor-based) modeling to:
(a) identify the most significant source profile needs,
(b) recommend and prioritize data collection and steps necessary for
improving or developing source profiles for poorly characterized sources.
3) EPA, in conjunction with S/L/T and affected stakeholders, should conduct a study to
reconcile current emission inventories with ambient measurements. The study should
build-upon the "top-down" evaluations summarized in the NARSTO emission
inventory assessment. Based on the study, EPA should work with S/L/T and affected
stakeholders to improve emission estimates. Examples of emission estimation
improvements include methods for mobile sources, ammonia sources (especially,
livestock operations, fertilizer applications, soil, and urban sources), and unusual or
infrequent events (e.g., forest fires, dust storms, chemical spillage or upsets,
unusually hot days).
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Benefits: Developing improved emission estimation methods will allow states and local
agencies with interest and resources to apply those methods to create inventories that are more
accurate and hence more useful for purposes of air quality modeling platform development and
validation, attainment planning, and progress tracking. The improved state and local inventories
would also be incorporated into the National Emissions Inventory used by EPA in developing
effective national or regional strategies. Some of the listed improvements in methods - those
dealing with non-point source categories - could also be applied directly by EPA in developing
the National Emissions Inventory.
Feasibility: These recommendations have medium to high feasibility for implementation
because they can be completed under existing regulatory authority. For some of the
recommended actions, specific steps towards have already been taken and EPA is currently
making further progress. However, later steps will require substantial resources above current
efforts.
Timing: Most of the desired methods, models, and guidance documents will take several years
to complete, even assuming resources are available.
Resources: The needed funding for this work is uncertain, but in the aggregate may likely
exceed a few million dollars per year over several years.
Priority Level: High
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1.3 Uncertainty in Emissions Inventories and Modeling; To improve the usefulness and
acceptance of technical information for planning and decision making, EPA, in conjunction
•with S/L/T and affected stakeholders, should quantify and take actions to reduce uncertainty
in emissions inventories and air quality modeling applications, provide guidance for
incorporating uncertainty assessments into SIP planning, and improve communication of
uncertainty to decision-makers.
Background/Explanation: Technical analyses performed to support policy-making need to
address complex and sometimes poorly understood problems. While serious attempts are made
to rely on the best science available at the time, there are, generally, limitations with these
analyses. For example, emissions inventories for some source categories are developed using
emissions factors of variable quality. Another issue with these analyses is that they may reflect
simplifications to facilitate communication with policy makers. For example, modeling analyses
of a given control scenario will generate a single, best estimate, rather than dealing with the
actual probability of success. An effort should be made to deal with the associated uncertainty in
the technical analyses, especially with regard to emissions inventories and modeling
applications. There is also uncertainty with monitoring data, but it can be better characterized.
Recommended Actions: The Subgroup recommends the following actions to address
uncertainty in existing emissions inventories and modeling analyses:
1) EPA, in conjunction with S/L/T and affected stakeholders, should conduct a study to:
(a) evaluate sources of uncertainty in emissions inventories and modeling
analyses for all sources,
(b) identify needed data collection activities (and associated costs) to reduce the
most significant emissions uncertainties,
(c) identify appropriate methods for incorporating uncertainty in preparing
emissions inventories, and
(d) identify appropriate methods for incorporating uncertainty in conducting
modeling analyses. Particular attention should be paid to probabilistic
approaches in evaluating the likelihood of "success" (i.e., meeting the
NAAQS) as part of the attainment demonstration.
2) EPA should provide guidance to S/L/T for incorporating uncertainly assessments in
SIP planning. In addition, EPA, in conjunction with S/L/T and affected stakeholders,
should improve communication of uncertainty to decision makers and the general
public.
Benefits: Air quality management decisions are more likely to achieve intended goals at least
cost if the decision makers have some information on the uncertainties in emissions estimates -
and on the uncertainty in other estimates derived from them such as pollutant concentration
estimates - versus having no such information. Public and industry acceptance may also be
greater if it is known that uncertainties have been responsibly addressed. Also, knowledge of
uncertainties can help target resources towards information collection that will have the largest
payoff in terms of reducing bias and uncertainty in the emissions estimates, leading again to
better air quality management decisions. Because real world experiences in using explicit
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uncertainty characterizations to make air quality management decisions are at best rare and
narrow in scope, it is not yet possible to say by how much or in what specific areas the air quality
management process is most likely to be affected.
Feasibility: Implementation of these recommended actions in the near term (i.e., next five
years) will be difficult, given that there is so much source-by-source uncertainty characterization
work to be done. The recommendations can be considered to have medium feasibility for the
longer term, if resources are present, because they can be completed within existing statutory
authorities.
Resources: Resource needs are uncertain, but may be high, if all important sources of
uncertainty are to be characterized objectively, especially if this is attempted retroactively (e.g.,
to characterize the uncertainty of a "legacy" emission factor). Resources needs would be lower
if well informed, but subjective expert opinion is considered sufficient. Also, resource needs
will be less, if the need to characterize uncertainty is part of the original data objectives for
development of new emissions factors, models, etc.
Priority Level: High
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1.4 Multipollutant Monitoring; In order to provide more scientifically relevant and
responsive air quality information, and to provide a more robust and spatially complete basis
for current and future air quality planning, EPA, in conjunction with S/L/T and affected
stakeholders, should promote and improve integrated, multi-pollutant monitoring.
Background/Explanation: Ambient monitoring data are an essential part of the nation's air
quality program. Monitoring objectives include determining compliance with federal air quality
standards, developing emission control plans, tracking effectiveness of these plans, and
providing information for the public, regulators, and affected stakeholders on the quality of the
air. Over the past 30 years, the air pollution situation has changed significantly, as control
programs have reduced emissions of many pollutants and as science has identified emerging
issues of concern. Accordingly, it is important that air monitoring efforts be dynamic and
responsive to meet the current and future public, regulatory, and scientific needs.
Recommended Actions: The Subgroup recommends the following actions to promote and
improve monitoring:
1) EPA should finalize its proposed national ambient monitoring strategy, and S/L/T
should, as appropriate, work together on a regional-scale to consider the need for,
and, if appropriate develop, regional monitoring strategies. The existing monitoring
networks are top-heavy on determining attainraent/nonattainment and light on
addressing other monitoring objectives, especially control strategy development and
tracking progress. An assessment of the existing networks, either through a national
or regional monitoring strategy, is needed to support redistribution of monitoring
resources to address current policy- and program-relevant objectives. In the longer
term, EPA should consider adopting a more inclusive and holistic national monitoring
strategy which considers all types of monitoring pursuant to health and non-health
(e.g., ecosystem) objectives.
2) As initial efforts in implementing the national monitoring strategy, EPA should:
(a) Establish six Level I (research-grade) NCore sites with reasonable
geographic coverage (e.g., one each in the NE, SE, MW, and S, and two in
the W). Additionally, EPA should work with the Level I researchers to
prepare and implement a data management and analysis plan. Funding for
the operation and maintenance of these sites, and the data management
and analysis work, should be provided by EPA (ORD). EPA should also
sponsor a workshop every three years to report on the lessons learned and
to promote technology transfer from the Level I sites.
(b) Establish, in conjunction with S/L/T, the Level II (multi-pollutant) NCore
sites. (The appropriate number and location of these sites should be
determined by the S/L/T and the respective EPA Regional Offices.)
Additionally, EPA should work with the S/L/T, to prepare and implement
a data management and analysis plan. Any resource savings from network
changes provided by a regional monitoring strategy should be directed to
help pay for the operation and maintenance of these sites, and the data
management and analysis work.
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3) EPA should support research and development (for example, through the Level I
NCore sites) to improve monitoring methods for:
(a) PM2.s-mass: Establish a continuous federal equivalent method for PMzs-
mass (i.e., resolve difference between current filter-based FRM for PM2.5-
mass and continuous PM2.5-mass methods).
(b) PM2.5-species: Establish a consistent filter-based method for measuring
and reporting OC and EC (i.e., adopt the IMPROVE methodology for both
rural and urban measurements), identify appropriate measurement
methods for supporting source apportionment studies for OC, and
establish reliable continuous methods for individual PMzs species. EPA
should recognize and report the uncertainty in these measurements.
(c) PM2.s & PMi0: Investigate the potential for over-sampling with the PMio
and PM2.s FRM samplers in areas where the mass median diameter
(MMD) of the PM is larger than the size of interest (10 or 2.5 AED) and
determine whether additional research, altered inlets, or implementation
guidance should be provided.
(d) PM-coarse (PMc): Establish a federal reference method for PMc. Using
the difference between PMio and PM^s as measured with PMio and PM2.5
FRM samplers is not acceptable. The method should be capable of
determining the amount of crustal material.
(e) Air Toxics: Need reliable methods for acrolein, hexavalent chromium,
and other species. A portion (e.g., 10 percent) of federal funding for the
national air toxics monitoring program should be used for methods
development.
(f) Dry deposition measurements, particularly for mercury species (see
Recommendation 1.5).
4) EPA should promote policies to avoid disincentives for monitoring. The necessary
changes in ambient monitoring networks, as called for by the national and regional
monitoring strategies, should proceed without any negative ramifications. Specific
actions include:
(a) Support concept of performance-based measurement systems (PBMS) in
EPA's national monitoring strategy (i.e., monitoring intended for
investigative, not compliance, purposes). Although these measurements
should meet minimum data quality requirements (developed through the
Data Quality Objectives process), these data will not be used to assess
attainment or nonattainment with the NAAQS. Note, this concept is
similar to the FACA recommendation to "decouple the use of research
data for regulatory purposes for a period of several years." Prior to
deploying PBMS (including untested, research-grade monitors), states and
the EPA regional office should document in writing the non-compliance
monitoring objectives and the appropriate response to any measured
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values in excess of the level of the NAAQS (e.g., deployment of an FRM
monitor).
(b) Acknowledge EPA's Exceptional Events policy, which avoids counting
(for compliance purposes) high pollution events due to certain unusual or
extreme conditions.
(c) Avoid monitors taking "root" by having state and local agencies specify
monitoring objectives for their existing networks (including the expected
period of sampling to meet these objectives) in their regional monitoring
strategy. For any new monitoring, encourage identification of the
monitoring objectives up-front (including expected period of sampling to
meet objectives). Provide the agencies with discretion in moving monitors
upon completion of the intended sampling period.
(d) Promote the concept of sharing monitoring data in a timely manner with
potential sources as a means to help identify and minimize pollution
problems rather than a strict enforcement tool. This would require the
expansion of real-time monitoring and data transfer capabilities at existing
and new monitoring sites. This effort and the resulting data could be
utilized, with appropriate input on potential pollution emission activities
and sources, for targeting more cost-effect control strategies.
5) EPA should, whenever possible, promote co-location of atmospheric dry and wet
deposition monitoring with long-term monitoring of ecological conditions (see
Recommendation 1.5).
Benefits: Implementation of the national monitoring strategy will demonstrate EPA's
commitment to a multi-pollutant air quality management framework, given that the developing a
measurements infrastructure is a critical component upon which further technical and program
adjustments can be based. From a strict technical perspective, the national monitoring strategy
will broaden the scope of monitoring services beyond the historical regulatory emphasis and
allow for more credible program accountability assessments, air quality model evaluation,
support to forecasting venues such as AIRNow, and enhanced support to the research
community, especially in the health effects area Support for Level I sites would demonstrate
EPA leadership in bridging the gap between research and applications and engaging the nation's
scientific expertise directly into its air program infrastructure.
Feasibility: Implementation of the national monitoring strategy is underway and most
components of the Level II NCore sites should be implemented within current resource
allocations. There are no currently identified resources for the Level I sites. Failure to fund
these sites will jeopardize successful implementation of the strategy.
Timing: EPA could finalize the national monitoring strategy, and S/L/T could work together
and prepare regional monitoring strategies during CY200S. Assuming the availability of
funding, EPA could establish these sites in CY2006. EPA's national strategy implementation
plan targets a phased implementation of the NCore Level II sites in 2007.
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Resources: A minimum base of $3M per year would be needed to fund basic operations for six
Level I sites. EPA's national strategy implementation plan recommends an outlay of $10M per
year (OAR or ORD) to support these sites. Internal OAQPS funding of approximately
$150K/year for FY05 and FY06 is estimated to be needed to support training needs associated
with implementing the strategy.
Priority Level: High
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1.5 Framework for Accountability; To promote understanding and characterization of the
impacts of air quality changes on health and ecological outcomes, and to improve the
scientific basis for more informed policy decisions, including the need for and nature of air
quality standards, EPA, in partnership with atmospheric scientists, health and ecosystem
experts, S/L/T, and affected stakeholders, should undertake a systematic effort to track air
qualify achievements and evaluate ah-program results. This effort should begin by focusing
on the progression and associations of air emissions as they interact and ultimately affect
health and the environment. In order to move beyond the current approach of relying
predominately on air quality measurements, we need to further develop and apply the capacity
to monitor, assess, and report on how changes in emissions impact air quality, atmospheric
deposition, exposure, and effects on human health and ecosystems. Emphasis should be
placed on developing and enhancing appropriate health-and ecosystem indicators,
benchmarks, and subsequent analyses within this overarching accountability framework.
Background/Explanation: To guide future improvement of the air quality management system,
the NRC identified as a longer-term objective the need for a results-oriented approach which
emphasizes "performance rather than the process" in determining the efficacy of air policies and
programs. Building on the current paradigm of accountability, EPA could better track, assess,
and communicate significant results of emission control programs, including changes in
source/emissions, air quality/atmospheric deposition, exposures, and effects. Emphasis is placed
on systematically measuring progress and assessing benefits of air quality management through
enhancing and expanding the suite of benchmarks and indicators of health and ecological
outcomes. It is important to recognize that public health and ecosystem responses to emissions
reductions occur over time and not always in the same time context as program assessments.
The plan would, in a very general fashion, be based on the framework described above. That is,
ideally accountability efforts would follow the "source/emissions - to air quality - to exposure -
to dose - to effect" paradigm producing an improved understanding of cause/effect associations
and input for meaningful program changes (or mid-course adjustments). It may be impossible to
establish these links for health or ecosystem effects following strictly this linear progression.
Plans for accountability will need to grapple with the difficult issue of tracking what are often
small changes in health effects, on a relative basis, in large populations.
Recommended Actions: The Subgroup recommends a 3-part approach involving health effects,
ecosystem effects, and SIP planning for systematically ensuring mat air policies and programs
are achieving intended results.
For public health, the Subgroup recommends that EPA work with health effects experts (e.g.,
federal agencies under the CENR Air Quality Research Subcommittee, CASAC/NAS,
State/CDC/EPA environmental public health tracking partners, and HEI) to develop measures to
define and assess human health impacts of air pollution and by developing ways to track and
evaluate progress in reducing those impacts. Specific actions include:
1) Strengthen the partnership among atmospheric science, health research, and program
accountability efforts.
(a) Produce a summary report on air quality and health accountability as a
first assessment of findings/capability.
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(b) Sponsor a collaborative workshop to promote involvement in developing
the overarching framework.
2) Expand on-going efforts into public health and air quality accountability
(a) Assign a specific group to focus on public health and air quality
accountability.
(b) Study effects of AQI advisories on exposure-reduction behaviors and
whether behaviors lead to health benefits.
(c) Fund grants to State/local health departments in collaboration with
State/local environmental agencies to assess health impact of specific
environmental regulations/actions and whether they align with projected
health impacts.
(d) Develop methodologies to detect changes in human health
indicators/responses, as a result of changing from meeting 1-hr ozone
standard to meeting a more stringent 8-hr ozone standard.
(e) Develop methods and collect data to better assess population exposure to
air pollutants of ambient origin, considering indoor exposure and variables
impacting personal exposure (time spent indoors, exercising, etc.)
(f) Enhance exposure assessment activities through expanded collection of air
pollution biomarker data and development of additional biomarker
detection methods for priority air pollutants.
(g) Develop further epidemiological and biostatistical approaches in
assessment of exposure and dose, selection of health outcomes, and study
design and data analysis
(h) Review/critique the PHASE project (this winter), learn from PHASE and
expand indicators work, and consider expanding PHASE into a functional
air quality public health tracking program.
(i) Identify additional projects, additional research, and explore further:
building tools and develop methods for making air quality-public health
linkage, expanding the NAT A connection to criteria pollutant analyses,
building on NATA and Criteria Document preparation to develop
indicators and protocols, and ensuring appropriateness of ambient and
health monitoring systems for public health tracking.
3) Undertake specific accountability efforts
(a) Undertake "intervention" studies for cities with largest expected, overall
air quality improvements.
(b) Examine the usefulness and implementation of accountability measures in
the context of "natural" experiments.
(c) Design and implement a study of accountability measures for changes in
multiple air compositions
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(d) Study health indicators for ozone and particle air quality in areas with
contemporary improvements
(e) Study particle and CO effects in areas with winter time programs to reduce
pollution from wood stoves
(f) Develop processes to identify and implement accountability research for
health effects resulting from long term air quality improvement trends.
Methodologies may need to be developed to account for life-style and
other interferences.
(g) Develop/improve biological indicators or biomarkers of early
effects for long-term and acute exposures.
For ecosystems, the Subgroup recommends that EPA work with others to develop benchmarks
and measures to assess ecological impacts of air pollution, and improve ways to track and
evaluate progress in reducing those impacts. Specific actions include:
4) Improve tracking and assessing the effects of multiple air pollutants on aquatic and
terrestrial ecosystems to assess the response to air pollution control policies.
(a) Identify a comprehensive suite of air quality-ecosystem indicators or
measurements for tracking status and trends in exposure and condition
consistently across broad regions of the U.S
(b) Increase the density and spatial coverage of long-term ambient air quality
and atmospheric deposition monitoring stations in rural, remote forest,
agricultural, and coastal areas.
(c) Co-locate long-term measurements of ambient air quality and atmospheric
deposition with long-term ecological research studies to answer key policy
questions over time and a range of scales.
5) Conduct and/or facilitate integrated assessments and research to develop and
implement an appropriate suite of measurements for detecting ecosystem response to
air pollution control programs within a long-term monitoring and assessment
framework.
(a) Improve methods for monitoring atmospheric inputs to ecosystems and
ecosystem response. Consider developing routine methods for measuring
ammonia, organic nitrogen, dry deposition of mercury, and various dry
measurements in a network mode (e.g., NADP, CASTNET), including in
under-represented areas, such as coastal and western ecosystems.
(b) Improve methods to evaluate the status, trends, and response to air
pollution control over regional scales, such as total nitrogen deposition
rates and loadings, delivery of atmospheric loads to ecosystems relative to
other sources, and simple, effective indicators of ecological condition.
(c) Improve models for characterizing the transfer of air pollutants through
water, soil, and food chains over time.
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6) Collaborate with federal and state agencies, and the academic research community to
pursue focused, integrated assessments and the integration of ecologically-relevant
monitoring networks.
(a) Identify and develop institutional arrangements to initiate focused air
quality-ecosystem, integrated environmental assessments.
(b) Identify and leverage existing models of successful collaboration in
atmospheric, aquatic, and terrestrial environmental monitoring and
assessment.
(c) Standardize data collection activities across agencies, where possible and
look for ways to offer air-quality ecosystem datasets in centralized
locations.
7) Examine the possibility of using critical loads and thresholds, and other
environmental benchmarks to quantify impacts on ecosystems.
(a) Initiate a series of focused technical workshops with stakeholder groups
on the state-of-the-science to inform the development of environmental
benchmarks or measures which define and assess the impacts of air
pollution on ecosystems, and the expected time scales of recovery.
(b) Synthesize the results of the workshops for possible EPA policy
development consideration; begin to develop a framework or strategy for
applying the scientific assessment information.
(c) Conduct air quality-ecosystem benchmark assessments (e.g. critical loads)
to better characterize air to ecosystem effects.
Finally, the Subgroup recommends that EPA work with S/L/T to determine appropriate metrics
which should be used to more effectively track progress. Specific actions include:
8) For the major control programs in a given SIP, determine quantifiable metrics for
characterizing the program (e.g., for the NOX SIP Call, the change in monthly or
seasonal average NOX concentrations from rural/regional ambient monitors, and the
monthly or seasonal average NOx emissions from power plants).
9) Determine emissions or ambient measurement methods (and measurement plan) for
each metric (e.g., for the NOX SIP Call, a regional network of ambient NOX monitors
and CEMs on power plants). Note, this may require enhancing or expanding
emissions or ambient measurement activities, such as rural measurements for total
reactive nitrogen (N0y), nitric acid and ammonia, and PIVh.s speciation to better
detect measurable progress of ozone and PM precursors in support of major national
rules and in concert with Recommendation #4.
Benefits: A science-based framework to track and evaluate air quality achievements will enable
EPA to allocate resources effectively. Shared data/information and joint prioritization of
cooperative projects with other agencies allow resources to be used more effectively.
Partnerships among the air quality community can support agency planning efforts, facilitate
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coordination activities, help to resolve issues between agencies, and improve involvement of
non-federal organizations.
Feasibility: This recommendation is considered to be feasible given that models already exist
for tracking program outcomes used throughout EPA, states, and by health and ecosystem
experts. The likelihood this recommendation can be successfully implemented is enhanced by
building on the existing "accountability" infrastructure under the current CAA authority,
including health and ecosystem monitoring and assessment, and leveraging known effective
models of collaboration.
Timing: Develop multi-year, high intensity indicators in years 1-3 that track effectiveness and
progress of emission control programs in concert with the established framework. Indicator
application is a complex process that will require additional time to further define ecosystem and
health changes and expected time-scales of recovery.
Resources: EPA has a number of projects underway that support tracking and assessing the
results of emission control programs. Several activities can build on these efforts and begin
immediately with relatively little additional resources. Some of the recommended health and
ecosystem actions entailing developing new metrics and performing integrated assessments, in
particular, would necessitate additional staff resources and funds in OAR. Additional resources
may be available and leveraged through collaboration with other EPA programs and non-EPA
partners, such as states, non-governmental organizations, and industry.
Priority Level: High
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2.1 Industrial. Commercial, and Institutional Boilers. EPA should complete as soon as
possible a review of the contributions from this category and the technical and economic
feasibility of further controls, given the high priority assigned to this sector. EPA should then
initiate development of a regional or national emissions control regulation for this category as
quickly as is practicable, or take alternative action consistent with the results of Us analysis.
Background/Explanation: Industrial, commercial, and institutional (ICI) boilers combust coal,
oil or gas to produce heat and process steam in numerous sectors, including chemical
manufacturing, petroleum refining, commercial buildings, hospitals, and universities. ICI boilers
should be evaluated by EPA for possible regulation due to: 1) their significant contribution to
projected 2010 criteria pollutant emissions; 2) the availability of cost-effective control measures;
and 3) the likely contributions to nonattainment of the national ozone and fine particle standards
as well as the other environmental impacts associated with boiler emissions.
Recommended Actions: To determine whether regulation of ICI boilers is warranted and to
improve existing ICI boiler inventories and data, EPA should:
1) Evaluate the ICI boiler sector in detail using the agency's existing authorities under the
Clean Air Act. EPA should identify which measures are likely to be cost-effective for
specific boiler sizes and types and identify the total emissions reductions this would
imply for the sector.
2) Close data gaps pertaining to characterization of the ICI boiler population and emissions,
potentially by hiring a technical consultant to improve the quality and completeness of
the ICI boiler inventory and to develop a realistic emissions baseline. The consultant
would seek to integrate data from available data sources, including data in the NEI, data
reported as a result of the Consolidated Emissions Reporting Rule, and data pulled
together to support MACT regulation and the OTAG effort. The goal would be to create
a comprehensive and systematic database listing key unit-level data for all states that is
properly maintained and updated over time.
3) Support a mechanism for reporting emissions from ICI boilers, potentially by
maintaining and fully implementing the Consolidated Emissions Reporting Rule or
developing a new Information Collection Request.
4) Demonstrate the effect of reductions from ICI boilers on attainment (through air quality
modeling or other means deemed appropriate) to ensure that any action proposed for this
sector will help meet the desired air quality objective.
5) Develop improved, peer-reviewed estimates of the cost-effectiveness of the various
emission reduction measures that might be used with ICI boilers. This effort should
include estimates for a range of sizes and should reflect recent experiences with NOX and
SC>2 control technologies in the ICI boiler and similar sectors (e.g., electric power
sector).
6) Make a final determination regarding whether and/or how to regulate ICI boilers that
includes consideration of the potential penetration of cost-effective control measures.
7) Issue regulations, if warranted, that are national or regional in scope due to the broad-
based distribution of ICI boilers and the potential for emissions transport. Emissions
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trading should be utilized where appropriate due to the successes in using this approach
in the NOX SIP Call and the ability of this source to use continuous emissions monitors
(CEMs). Any regulation of this sector should include requirements for CEMs or other
reliable emissions monitoring methods. EPA could also consider alternative regulatory
approaches for smaller ICI boilers, considering administrative and emissions
measurement costs and other factors.
Benefits: Emissions reductions from the ICI boiler sector have the potential to achieve
significant reductions in criteria pollutants nationwide. In 2010, ICI boilers are projected to
account for over 16 percent (2.7 million tons) of total NOX, 16 percent (2.4 million tons) of total
SC<2, and 5 percent (0.3 million tons) of total PM^s emissions nationwide.1 The projected 20iO
SC>2 and NOX emissions from ICI boilers are second only to the projected emissions from the
power sector (without CAIR). Emissions of NOX, 862 and PMj.5 contribute to an array of
environmental problems, including ground level ozone, acid rain, fine particle pollution,
eutrophication and regional haze. Reducing emissions from ICI boilers could therefore
contribute to reducing the impacts of these emissions on human health. A comparison of
projected emissions from ICI boilers and nonattainment areas also suggests a potential
relationship between regulation of ICI boilers and improving local air quality. In fact, ICI
boilers are expected to represent a sizeable share of emissions in many States that are projected
to have one or more counties in nonattainment for the 8-hour ozone and fine particle standards in
2010.
ICI boilers are a potentially cost-effective source for additional emission reductions. Preliminary
data indicate that control technologies for industrial boilers can achieve emissions reductions
cost-effectively—often well below current allowance prices for NOX and SC«2, and in many
cases, below the levels deemed to be "highly cost-effective" under the proposed CAIR rule for
the electric power sector ($1,300 per ton of NOX and $700 per ton of SO2 in 2010).2
Feasibility: There do not appear to be any major technical or legal barriers to the proposed
analyses or other measures to close information gaps. In addition, if regulation of ICI boilers is
deemed appropriate, we do not see any barriers because authorities exist under Sections 110,
111, and potentially other sections of the Clean Air Act. The main hurdle is anticipated to be the
likelihood of industry lobbying and legal action. This can be mitigated in part by providing a
reasonable horizon within the framework of the fine particle and ozone attainment deadlines and
by offering as much compliance flexibility as possible through emissions trading or other means.
Timing: Implementation of an emissions reduction program would need to take place no later
than the 2010 to 2012 timeframe to help States meet attainment for ozone and fine particle
1 Note that these percentages assume only existing regulations—they do not assume implementation of the proposed
Clean Air Interstate Rule (CAIR) that would control emissions from the power sector. If implementation of CAIR
were assumed, industrial, commercial and institutional boilers would constitute an even greater share of 2010
emissions. For example, with implementation of CAIR, the ICI boiler share of 2010 SO2 emissions would be
expected to increase to 22%.
2 It should be noted that EPA did not assume reductions from ICI boilers in the CAIR because they did not believe
there was sufficient information to determine that controls met the highly cost effective criteria.
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national ambient air quality standards.3 Consequently, the suggested improvements to the data
and rule development should begin as soon as possible to give the industry a long lead time for
compliance, if regulation is deemed appropriate.
Resources: EPA staff time would be required to develop peer-reviewed cost-effectiveness
estimates, study the effects of ICI boiler control on attainment, and oversee the database
development consultant. Funds would also need to be set aside to compensate the consultant. If
national or regional regulation is deemed to be appropriate, EPA staff time would be needed to
develop proposed and final rules and design the trading program infrastructure or other
regulatory approach. The State role would be limited to monitoring and source permitting.
The cost of implementation would depend on the type of regulation used and the number of
sources covered. For example, the cost of administering an emissions trading program would be
generally lower than a command-and-control approach. In addition, costs would be expected to
increase somewhat if all ICI boilers are included versus those accounting for the majority of
pollutants or those exceeding a boiler size or throughput threshold.
Priority Level: High
3 Attainment deadlines are as early as 2007 in some cases. In most cases, the NAAQS compliance deadline is April
IS, 2009. However, extensions may be granted through April IS, 2014 or even April 15,2016, if the required
showings are made. The limited number of areas designated "severe" for the 8-hour ozone standard have even
longer to meet attainment. States will need to know whether national/regional measures are going to be successful
several years before the final deadlines so that they can ramp up additional programs of their own, where needed.
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2.2 Industrial Surface Coatings. EPA should complete as soon as possible a review of the
contributions from this category and the technical and economic feasibility of further controls.
EPA should then initiate development of a regional or national emissions control regulation
for this category as quickly as is practicable, or take alternative action consistent "with the
results of its analysis.
Background/Explanation: VOCs from industrial surface coating represent about 11% of
national VOC emissions. Reductions beyond current Control Techniques Guidelines (CTG)
recommendations and New Source Performance Standards have been demonstrated and achieved
by sources in all previously regulated industrial surface coating categories. While scheduled area
source, residual risk rules, and 112(d)(6) review may result in further emissions reductions in this
sector, there may still be significant emissions from facility maintenance operations and surface
coating of miscellaneous wood products that have not been regulated previously. There exist
two primary approaches for addressing these emissions - the use of low-VOC/low-HAP
coatings, and the use of capture and control equipment.
Recommended Actions: EPA should: (1) review nonattainment contributions from this
category; (2) assess the technical and economic feasibility of a more stringent performance
standard and revised CTGs; and (3) proceed with the appropriate action(s) based on this review
and analysis.
Feasibility: It would probably require 2 to 3 years to develop a new standard for this category.
Resources would be devoted to review and analysis, necessary data collection and rule
development.
Timing: Any regulatory effort would take 2 to 3 years at a minimum. However, updates to
existing CTGs could be completed in shorter timeframe.
Resources: EPA resources would be required to undertake the required research and possible
promulgation of a new NSPS, and also for the development of relevant CTGs. At the local level,
resources associated with the adoption and enforcement of CTGs would potentially be required.
Priority Level: Medium
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2.3 Non-industrial Solvents. EPA should initiate a rulemaking to establish minimum
performance standards fie., a national rule) for non-industrial solvents using the VOC
content limitations contained in, and regulating the products covered by, the model rule
developed by the Ozone Transport Commission.
Background/Explanation: Non-industrial solvents are projected to be responsible for 16% of
nationwide VOC emissions in 2010. NIS/CCP are specifically subject to Section 183(e) with
regard to VOC emissions. There is an existing national rule (40 CFR 59 subpart C) that
regulates 24 categories of household consumer products. In addition, there are Control
Techniques Guidelines (CTG) and alternative control techniques documents pertaining to
categories such as cutback asphalt paving and agricultural pesticide application. The non-
industrial nature of the products generally removes many of them from the authority of sections
111 and 112. There is no known authority to directly regulate HAP emissions from the use of
consumer products.
The existing federal consumer products rule regulates only 25 categories of products. This rule is
estimated to have reduced VOC emissions from these categories of household and institutional
products by approximately 20 percent, or 90.000 tons per year nationwide, from a 1990 baseline.
These reductions were achieved at a cost effectiveness of about $250/ton. California and several
other States have regulated, or are in the process of regulating, many more categories of
products, and at lower VOC limits than the federal rule requires. As discussed above, several
northeast States have been developing rules based on an Ozone Transport Commission (OTC)
model rule for consumer products. The basis for the OTC model rule was the existing California
rule.
It is possible that further regulation might not result in appreciable reductions. The reason for
this is that most consumer products are manufactured and distributed nationwide, and that the
major manufacturers formulate their products to be distributed nationwide. Accordingly,
nationally distributed products must meet the most stringent requirements. This results in
"compliant" products being distributed and used nationwide, even in areas with no regulations.
However, smaller, regionally distributed products should be affected by further federal action. In
proceeding with this recommendation, EPA should quantify the potential achievable emissions
reductions associated with tightening VOC content limitations.
Recommended Actions: EPA should research the potential to gain additional VOC reductions
from non-industrial solvents, focusing on:
• potential gains from regulation of additional product categories at the federal level and
the of updating current standards;
• potential reductions from updating existing CTGs to reflect tighter State limits; and
• the extent to which regionally distributed products (from areas with no additional
standards) contribute to total national VOC emissions and the magnitude of potential
reductions from this group of products
Following its review, EPA should take regulatory action consistent with its analysis.
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Feasibility: Further regulation of consumer products beyond the existing federal rule is
possible and has been pursued by California and by some of the northeast States using an Ozone
Transport Commission model rule based on California's rule.
Timing: Any regulatory effort would take 2 to 3 years at a minimum. However, updates to
existing CTGs could be completed in shorter timeframe.
Resources: Either a regulatory acton or a revised CTG would probably require less than 1 FTE
and $25K to S100K per year per category on EPA's part, depending on how much work was
performed in-house. At the local level, resources associated with the adoption and enforcement
of CTGs will be required.
Priority Level: Medium
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2.4 Architectural Surface Coatings. EPA should initiate a rulemaking to establish minimum
performance standards (Le., a national rule) for architectural coatings using the VOC content
limitations contained in, and regulating the products covered by, the model rule developed by
the Ozone Transport Commission.
Background/Explanation: VOCs from architectural surface coating represent about 4% of
national VOC emissions. While this sector is already regulated under the national VOC rule
(183(e)), California has adopted a more stringent standard for VOC content and OTC States are
adopting rules based on the California rules. These standards could be extended nationwide.
There currently exist near-zero VOC content materials for some content categories (e.g., flat
interior wall coatings).
Recommended Actions: Research the magnitude of potential reductions that could be gained
beyond existing rules, and if significant reductions could be achieved cost-effectively, adopt a
more stringent national VOC content standard for this sector.
Feasibility: Implementation of additional controls for this industrial sector is a realistic
expectation. It would require revisiting the current VOC content standard in place under section
183(e). The existence of State standards that are well below the national standard and the
development of extremely low-VOC content materials, suggest that this activity would be
worthwhile.
Timing: It would probably require 1-2 years to develop anew standard for this category.
Resources would be devoted to necessary data collection and rule development.
Resources: EPA resources would be required to undertake the required research and rule
development for further regulatory action.
Priority Level: Medium
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2.5 Heavy-Duty Diesel Engines. EPA should reduce emissions from the existing fleet of
heavy-duty diesel engines by employing a multi-pronged approach.
Background/Explanation: Over the last decade, EPA has moved aggressively to strengthen
federal emission standards for a wide range of diesel engines. While these standards will serve
to dramatically lower emissions when fully implemented, the full human health benefits will not
be realized for 20 years or more. The figure below graphically shows the national particulate
pollution under the phase-in of the federal emission standards for diesel trucks and buses, and
nonroad engines.
Particulate Pollution Under
Phase-in of Federal Standards for
Diesel Trucks, Buses and Machinery
_
400000 -|
350000 -
300000
250000
200000
150000
100000
50000 -|
0
2000 2005 2010 2015 2020 2025 2030
Year
Figure 1. National PM2 5 emissions under phase-in of federal standards for on road diesel trucks
and buses, and nonroad diesel equipment. (Estimated from EPA, 2000 and EPA, 2004a)
The delay in achieving emissions reductions is attributable to two factors. The first factor is the
lapse in time before the emissions standards take effect for new engines. The standards finalized
in 2001 for highway engines take effect in 2007, while the new standards for nonroad diesel
engines are phased in based on engine size, beginning in 2008 with engines smaller than 25 hp.
Final standards for nonroad engines greater than 750 hp will not be effective until 2015. The
second factor that contributes to the lag in effectiveness of the diesel rules is the long lifespan of
diesel engines. Under typical operating loads and levels of use, large diesel engines can last for
more than one million miles and/or decades.
The ultimate consequence of the time lag in emissions reductions for diesel engines is a
corresponding lag in achieving the projected health benefits. EPA has estimated that by 2030, the
highway diesel rule will avoid 8,300 premature deaths per year, which otherwise would have
been caused by exposure to particulate pollution from diesel emissions (EPA, 2000, Table VII-
19). The rule is also projected to prevent more than 7,000 hospital admissions, 360,000 asthma
attacks and more than 1.5 million lost work days in 2030 (EPA, 2000, Table VII-19). The
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nonroad rule similarly projects tremendous health benefits in 2030, including the avoidance of
12,000 premature deaths and 8,900 hospital admissions per year from paniculate pollution
exposure (EPA, 2004a, Table 9-11). The nonroad rule is also projected to avoid 200,000 cases of
exacerbated asthma in children in 2030 (EPA, 2004a, Table 9-11). These projected health
benefits in 2030 are extremely important. However, the fact is that the same kinds of health
impacts that will be avoided in 2030 are occurring now, and will continue to occur until today's
high-polluting diesel engines and equipment are replaced or cleaned up.
Policy action is needed to accelerate the transition to cleaner diesel engines and realize more
immediate public health protection. In principle, emissions from these existing engines can be
reduced either by incentivizing their early retirement, by improving their current emissions
performance (e.g., by add-on emissions control system, changes in the engines themselves, repair
of high-emitting engines or improved fuels), or by limiting the time that these engines operate
(e.g., through idling reduction programs and/or otherwise). Each approach has merit under
certain conditions and programs, and should be part of an implementation strategy. For example,
centrally operated and fueled fleets (e.g., school and transit buses and refuse trucks) are good
candidates for retrofit technologies or engine repowers. Some of these fleets can be excellent
candidates for replacement with advanced technologies (e.g., hybrids) or alternative fuels. In
addition, some mid-1990s engines can achieve lower emissions limits by reprogramming of
engine control systems. Finally, programs aimed at reducing idling time can lower pollution,
achieve substantial ancillary benefits from reduction of fuel consumption and greenhouse gas
emissions, and lower operating costs.
Recommended Actions: EPA will continue to employ a variety of strategies to monitor and
reduce emissions from the in-use fleet and enforce its emissions standards. These strategies are
outlined below:
Heaw-Dutv Compliance Programs
• Continue to work with manufacturers to ensure compliance with existing and new
emissions standards through manufacturer testing of new and in-use engines and effective
EPA enforcement.
• Ensure that manufacturers of consent decree engines reprogram control systems to reduce
NOX emissions.
• Develop, evaluate and provide guidance to the States on a heavy-duty vehicle testing
approach that will be appropriate for use in heavy-duty vehicle inspection and
maintenance (I/M) programs as a replacement for the existing snap-idle (smoke) test.
• Work closely with California Air Resources Board (CARB) to develop a harmonized,
nationwide set of requirements for Heavy Duty On-Board Diagnostics (HD OBD) in the
US for gas and diesel vehicles for implementation in 2010.
• Investigate the development of portable emission measuring equipment to quickly and
accurately measure diesel particulate matter (PM) emissions.
Voluntary Programs
• Develop a national initiative, building upon the success of EPA's voluntary programs, to
provide federally funded incentives for diesel emissions reductions using California's
Carl Moyer Program and Texas's Emissions Reduction Plan as models.
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• Investigate low-interest loan programs and other creative financial methods to help
private fleets retrofit or rebuild existing engines to reduce emissions.
• Work toward the goal of reducing the emissions of the existing 11 million engines in the
fleet today by concentrating on the construction, port, freight and school bus sectors.
• Meet with States and engine manufacturers to develop a voluntary program that educates
owners on ECM reflash strategies (to achieve NOX reductions) and urge their
participation.
• Continue building industry support through voluntary, market-based approaches.
• Work with General Services Administration (GS A) and Department of Defense (DOD) to
establish, by January 2006, government-wide procurement and contracting guidelines on
emissions performance standards for existing diesel engines.
• Work with private and public fleets to develop operational strategies to reduce in-use
emissions, such as idling reduction programs.
EPA should also consider a mandatory program that would:
• Dramatically expand current federal programs to cut pollution from existing diesel
engines through accelerated retirements, retrofits, repowering, replacement and anti-
idling measures. EPA should pursue a dual, complementary strategy to achieve the goal
of retrofitting all heavy-duty diesel engines by 2012 by: (a) establishing mandatory
measures to cut pollution from existing diesel engines and (b) considerably multiplying,
through expanded congressional appropriations, the funding for both mandatory and
voluntary programs with funding contributions from other federal agencies as well.
Feasibility: Continuation of the existing program is feasible; the compliance programs are
operating under existing statutory authority and the voluntary efforts are currently partnering
with States and fleet operators across the country. Legislation to secure expanded federal
funding to sustain and enlarge voluntary programs to clean up existing diesel engines is also
feasible, but would present a substantial challenge. The cost to retrofit all diesel engines would
be high.
Timing: Several specific actions recommended here are currently a part of EPA's ongoing
efforts. As noted above, EPA and CARB are working toward implementation of national HD
OBD requirements in 2010. It is anticipated that other actions can be implemented in 3-4 years
as current studies are completed and new testing technologies are established.
Resources: Continue existing efforts. Redirection of existing efforts/personnel may be
required.
Priority Level: High
References
EPA. 2000. Regulatory Impact Analysis: Heavy Duty Engine and Vehicle Standards and
Highway Diesel Fuel Sulfur Control Requirements, EPA420-R-00-026, December.
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EPA. 2004a. Final Regulatory Analysis: Control of Emissions from Nonroad Diesel
Engines, EPA420-R-04-007, May.
EPA. 2004b. Median Life, Annual Activity and Load Factor Values for Nonroad Engine
Emissions Modeling, EPA420-P-04-005, April.
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2.6 Emissions from Ships. Locomotives, and Aircraft, and Mobile Source Air Toxics. EPA
should address emissions from ships, locomotives, and aircraft, and mobile source air toxics
through national emission standards.
Background/Explanation: Over the past decade, EPA has adopted several groundbreaking
rules that will dramatically reduce emissions from the nation's passenger vehicles, trucks and
buses, and nonroad equipment. Collectively, these rules will eliminate tens of thousands of
premature deaths and create tens of billions of dollars of health and other social benefits. Indeed,
new engines covered by these regulations will be more than 90 percent cleaner than their
predecessors.
As these vehicle sectors get progressively cleaner, thanks to vehicle turnover and an increased
emphasis on retrofit and other strategies to reduce emissions from the existing fleets, EPA should
address the growing percentage of emissions from engines outside the scope of these
rulemakings i.e., from ships, locomotives and aircraft. Moreover, EPA should address mobile
source air toxic emissions that have not been addressed by these rulemakings.
Regulating Additional Mobile Sources: Aircraft. Locomotive and Marine Diesel Engines
While emissions from most categories of mobile and industrial sources have stabilized or
decreased over the past two decades, emissions from locomotives, marine diesel engines and
aircraft have increased, and are forecast to continue growing. For example, airplanes at U.S.
airports emitted 350 million pounds of smog-forming pollutants in 1993, more than twice their
1970 total. The FAA estimates that aircraft-related NOX emissions will double by 2030. At the
local level, an airport's arriving and departing planes can emit as much smog-forming pollution
as many power plants and other large industrial sources.1
The situation at our nation's ports and rail yards is no different Ships are projected to be the
second largest source of mobile source PM emissions in 2020, emitting roughly one-fifth of the
nation's soot particles,2 thanks to the clean-up of highway and other nonroad diesel engines and
the sharp projected growth in port activities. Locally, this growth will be even more
significant—the Port of Los Angeles expects its trade-related traffic to triple by 2020.
Although these emissions can be significant local emission sources, States are largely preempted
from regulating them through their SIP process or otherwise. Moreover, exhaust emission
standards do not effectively address aggregate aircraft, ship or locomotive emissions on any
given airport runway, at a crowded port or in a busy rail yard. Many of these sites are near
residential neighborhoods, increasing the need for meaningful emission reduction strategies.
Regulating Additional Emissions: Mobile Source Air Toxics
Mobile source air toxics (MSATs) are among the most pervasive and hazardous pollutants
regulated by EPA. Indeed, EPA's National Air Toxics Assessment data show that MSATs
exceed cancer health benchmarks in all areas of the country and are up to 10 times higher in
' NRDC, Flying Off Course: Environmental Impacts of America's Airports, 1996, pp. 36-37.
2 EPA, Nonroad Diesel Rule, Draft Regulatory Impact Analysis, EPA 420-R-03-008, April 2003, Section 3.2.
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urban areas. Mobile source programs such as Tier 2, highway diesel and nonroad diesel will
significantiy reduce mobile source air toxics. However, an analysis conducted by the Northeast
States shows that nationwide, even with the full implementation of all mobile source programs,
benzene, 1,3 butadiene, formaldehyde and other potent toxins will continue to exceed health risk
benchmarks. EPA is required by CAA section 202(1) to reduce the threat posed by MSATs.
Recommended Actions: EPA should:
1) Promulgate technology-forcing Tier 2 emission standards for all new marine diesel
engines, including compression-ignition marine engines at or above 30 liters per cylinder
(Category 3 engines), that are more stringent than the international MARPOL Annex VI
NOX limits. Section 213 of the Clean Air Act Amendments directs EPA to set nonroad
standards that "achieve the greatest degree of emission reduction achievable through the
application of technology which the Administrator determines will be available for the
engines or vehicles to which such standards apply." Such standards should achieve
emission reductions comparable to those required of other mobile source categories under
EPA's recent highway and nonroad diesel rules. These regulations should apply to all
ships in U.S. ports, whether U.S.- or foreign-flagged.
2) Promulgate technology-forcing emission standards for new and rebuilt locomotive
engines. Again, Section 213 of the Clean Air Act Amendments clearly authorizes EPA to
do so. Such standards should achieve emission reductions comparable to those required
of other mobile source categories under EPA's recent highway and nonroad diesel rules.
3) Promulgate technology-forcing emission regulations for aircraft that are comparable in
stringency to other mobile source emissions standards, while maintaining the aviation
industry's outstanding safety record. As with marine diesel engines, EPA is not limited
by the ICAO process, and is authorized by Section 213 of the Clean Air Act to adopt such
technology-forcing emission standards.
4) Develop strategies (including, to the extent permissible, permitting requirements and SIP
control strategies) for reducing aviation, ship and locomotive emissions at airports,
seaports and rail yards that can be employed at the State and/or Local level.
5) With respect to controlling ground-level aviation emissions within their SIP processes,
EPA should encourage States and airport operators to consider strategies such as reduced
engine idling and taxiing, differential landing fees, using gate-powered electricity rather
than auxiliary power units, among others.
6) Provide guidance to States and airport operators so they consider emissions reduction
strategies for ground service equipment as part of their SIP strategies. Such strategies
could include accelerated retirement, engine repowers, emission control retrofits, reduced
idling measures and replacements with the cleanest available engines and fuels, including
alternative fuels.
7) Study toxic aircraft, ship and locomotive emissions and develop a strategy for reducing
them. Studies have shown that these sources generate significant hazardous air
pollutants, yet they are exempt from the Toxic Release Inventory (TRI) program.3
' See, e.g., http://www.arb.ca.gov/diesel/documents/rrstudy/Fcexecsum.pdf.
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8) Dramatically expand the agency's programs to cut diesel PM from existing engines
including both voluntary and mandatory measures.
9) Promulgate a protective national benzene cap. Expanding low-RVP gasoline
requirements beyond ozone nonattainment areas would also lower benzene and other
toxic VOCs and secondary toxics like formaldehyde and acetaldehyde.
10) Consider regulations to reduce other mobile source air toxics such as formaldehyde,
acetaldehyde, acrolein and 1,3-butadiene.
11) Consider national gasoline standards that further reduce sulfur and also address other fuel
parameters.
12) Address the high sulfur content in the distillate/bunker fuel used in Category 3 ocean-
going marine vessels.
13) Consider requiring catalysts on nonroad gasoline engines such as forklifts.
Feasibility: High.
Timing: Current plans call for an NPRM on gasoline outboard, sterndrive, inboard and personal
watercraft engines in the Spring of 2005; an NPRM on locomotive and marine diesel standards
in mid-2005; an NPRM on air toxics in mid-2005; a final rule adopting the existing International
Civil Aviation Organization NOX standards for aircraft engines in 2005; and a final rule on
ocean-going marine diesel engines by mid-2007.
Resources: Several of the recommended actions have already been funded and staffed.
Priority Level: High
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2.7 Cement Manufacturing. Petroleum Refining, and Pulp and Paper. The cement
manufacturing, petroleum refining, and pulp and paper industrial source categories are
already under substantial regulation but continue to be significant sources of pollutants and
warrant further consideration by EPA. EPA should evaluate potential national or regional
emissions reduction strategies for criteria pollutants and air toxics in these categories. This
should include improving emissions inventories if necessary and assessing their impacts on
nonattainment areas or other sensitive areas. EPA should carefully consider the cost-
effectiveness of imposing additional controls as it determines whether additional emissions
reductions are justified and should take action consistent with the results of this analysis.
Background/Explanation: Cement plants, petroleum refineries, and pulp and paper mills are
major emitters of criteria pollutants and hazardous air pollutants (HAPs). While boilers from
refineries and pulp and paper mills would be considered under the ICI boiler recommendation,
process sources associated with these two sectors present an additional challenge. It is much
more difficult and costly to monitor and report emissions from process sources, such as catalytic
cracking units, flares, and sources of fugitive emissions.
Petroleum refineries are major sources of HAPs and emit large quantities of criteria pollutants.
There are 146 petroleum refineries located in 33 States. However, fifty-five percent of the U.S.
production capacity is located in three States - Texas, Louisiana, and California
Based on EPA's projections for 2010, the cement industry in the U.S. will emit approximately 5
and 2 percent of the overall NOX and SC«2 emissions, respectively, excluding the emissions from
EGUs. The sources of these emissions are about 200 active cement kilns in this country. Since
cement industry was included under the NOX SIP Call rule, some of these kilns have already
been retrofitted with NOX controls.
Pulp and paper mills are projected to be responsible for 2 percent of both nationwide PM2.5
emissions and organic carbon emissions in 2010. The recent air toxics rules included a PM limit
as a surrogate for metal HAPs, but PM2.s has not been specifically addressed.
Recommended Actions:
1) EPA should evaluate further potential national or regional emissions reduction strategies
for criteria pollutants and HAPs in these categories. This should include improving
emissions inventories and assessing their impacts on nonattainment areas or other
sensitive areas.
2) EPA should carefully consider the cost-effectiveness of imposing additional controls as
it determines whether additional emission reductions are justified.
3) EPA should and take action consistent with the results of its analysis of these sectors.
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Feasibility: High, given apparent lack of technical or legal barriers to analysis and/or rule
development.
Timing: This recommendation should be implemented in a timeframe that would allow for at
least some emissions reductions to be achieved by 2010.
Resources: EPA staff time would be required to develop peer-reviewed cost-effectiveness
estimates and study the effects of further control on these sectors on attainment If national or
regional regulation is deemed to be appropriate, EPA staff time would be needed to develop
proposed and final rules.
The cost of implementation will depend on the type of regulation used and the number of sources
covered. For example, the cost of administering an emissions trading program is generally lower
than a command-and-control approach.
Priority Level: Medium
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2.8 Residential Fossil Fuel Combustion. EPA should evaluate the potential for expanding
the Energy Star voluntary program to gain additional criteria pollutant emissions reductions
(as well as improve energy efficiency) from the residentialfossilfuel sector. As part of this
effort, EPA should continue to gather information on the characteristics of residential fossil
fuel emissions and their contributions to non-attainment, and the magnitude and cost of
potential emissions reductions under a voluntary program and/or expanded use of law-sulfur
fuel EPA should also coordinate with Regional Planning Organizations (RPOs) and
companies that produce lower-emitting appliances to assess the potential for programs that
promote the installation of such technologies.
Background/Explanation: Residential fossil fuel use generally comprises natural gas, fuel oil,
LPG and kerosene combustion for space heating, water heating, and cooking. This source
releases emissions of several criteria pollutants, most significantly SO2 and NOX.
Geographically, emissions are more significant in the Northeast and Midwest. Opportunities for
emissions reduction generally include actions or technologies that improve energy efficiency,
such as high efficiency boilers, furnaces and water heaters, and insulation and air sealing, or
energy-conserving behaviors (e.g., heating only rooms being used). Other emissions control
opportunities include low-NOx space and water heaters, or the use lower sulfur fuel oil. Because
residential sources are numerous and small, implementation of a strict cap or rate requirement
would be impracticable. However, a voluntary program could be an effective means of reducing
emissions. Energy Star is a national voluntary program (jointly run by EPA and the Department
of Energy (DOE)) that focuses on reducing CO2 emissions through energy efficiency measures.
Many of the energy efficiency measures promoted for reducing residential CO2 emissions also
reduce emissions of criteria pollutants. In addition, DOE issues energy efficiency standards for
appliances. Considering the significant amounts of emissions from residential fossil use, the
availability of control measures, and the potential for collaboration with the existing Energy Star
program, this is a potential area for further Federal action.
Because many of the actions to reduce criteria pollutants from residential fossil use are measures
that improve energy efficiency, these actions can generate cost savings for homeowners. Energy
Star has a program to promote whole house retrofits, which is estimated to save homes an
average of 30 percent of the total energy bill. DOE has a program that provides air sealing and
insulation to qualifying homeowners, and the Department estimates the cost at $2,672 per home
with energy savings paying for costs within a few years. Energy Star programmable thermostats
can save a home about $100 per year. Note that not all actions that improve home energy
efficiency will reduce criteria pollutants from residential fossil use, so not all of the cost savings
from these programs would be attributed to reducing criteria pollutants.
An EPA analysis estimated the costs of a rule that would require low-NOx residential water
heaters, and found that such a rule would not increase the cost of natural gas water heaters,
implying a cost effectiveness of $0 per ton NOX removed.
DOE research indicated that low-sulfur fuel oil might cost up to two cents more per gallon than
conventional fuel oil. The reduced sulfur levels may lead to net savings for consumers, due to
reduced maintenance and cleaning costs.
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Recommended Actions: EPA should:
1) Work toward establishing low sulfur fuel alternatives for residential fossil fuel heating
systems, and possible regulation of sulfur content of home heating fuels.
2) Talk with its Energy Star staff about the potential for an expanded voluntary program to
promote actions that both improve energy efficiency and reduce criteria pollutants.
3) Talk with NESCAUM and other regional organizations to raise awareness of the extent to
which residential fossil fuel emissions are a regional concern, and to ascertain their
thoughts on voluntary programs promoted at the regional level.
4) Talk with companies that currently produce and/or market high efficiency appliances that
reduce emissions, to assess their interest in engaging in programs to promote the
installation of emissions-reducing technologies (e.g., by offering rebates).
5) Continue to gather information about the characteristics of residential fossil fuel
emissions and their contributions to nonattainment. Also gather information about the
extent to which further action would gain meaningful emissions reduction beyond what
has been achieved under Energy Star and what is projected to be achieved under DOE's
forthcoming revised energy efficiency standards.
Feasibility: This recommendation has a high feasibility for implementation. A Federal
voluntary program implemented in collaboration with the existing Energy Star program
presumably would be implemented under the same statutory authority as Energy Star. This
recommendation does not establish any prescriptive mandates that would require regulatory
action. No major obstacles have been identified. Regulation of sulfur-content of home heating
fuel would require a longer timeframe.
Timing: It is anticipated that discussions with Energy Star staff, NESCAUM and other regional
organizations, as well as further information gathering, can be completed in 6 months. Once
decisions are made to pursue Federal and/or regional voluntary programs, full implementation
can be achieved within a year to a year and a half. Regulation of sulfur-content of home heating
fuel would require a longer timeframe.
Resources: Collaboration with Energy Star will provide significant savings in resources,
drawing on existing expertise and experience. Some additional personnel at the Federal level
would be required to accommodate the expanded scope beyond CCfe reductions. If regional
programs are implemented then some additional resources will be required at that level.
Priority Level: Medium
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2.9 Guidance for Local Control Measures in Key Sectors. EPA, in conjunction with S/L/T
and affected stakeholders, should prepare guidance for local (urban-scale) control measures
to support the upcoming round of ozone andPM2S SIPs, and, if possible, optimize
multipoUutant control benefits and opportunities for criteria and hazardous air pollutants.
Background/Explanation: Many states are starting to prepare State Implementation Plans
(SIPs) to address nonattainment requirements for ozone (8-hour) and PM2.5, and reasonable
progress requirements for regional haze. These nonattainment (and regional haze) problems are
due to impacts from nearby (local) and more distant (regional) sources. The N AS recognized
that additional federal emission control measures and guidance would be useful in assisting
states to effectively attain air quality standards for ozone and PM2.5. This recommendation will
focus on providing guidance for local (urban-scale), multi-pollutant control measures, which are
most properly dealt with by States in their SIPs. Specifically, this recommendation will focus on
the current round of SIP development for ozone, PIVh.s, and regional haze (i.e., SIPs which are
due in 2007/2008 and address attainment in the 2010 timeframe). (It should be noted that
absolute and relative amounts of emissions by source sector is expected to change beyond 2010,
with significant reductions expected for at least mobile sources and EGUs.) Another
recommendation by the Regional/National Strategies Team will address regional/national control
measures for certain source categories, which are most effectively dealt with by EPA as part of
federal rulemaking.
Recommended Actions: Federal guidance is needed now to assist states in preparing SIPs to
address nonattainment requirements for ozone (8-hour) and PM2.s (i.e., attain ambient standards
by 2010), and visibility/regional haze requirements (i.e., satisfy first reasonable progress
milestone in 2018). The Subgroup recommends that EPA, in conjunction with S/L/T and
affected stakeholder, undertake the following actions:
1) Issue technical guidance for source categories that would benefit from local (urban-
scale), multi-pollutant strategies and technologies. The identification of these source
categories should be based on an evaluation of existing ambient monitoring data,
source apportionment studies, modeling analyses, and future year emissions
inventories. Consideration should also be given to emission reduction potential (and
uncertainty in emission estimates), timeliness, cost effectiveness, completeness of
existing guidance (e.g., STAPPA/ALAPCO's forthcoming "Menu of Options for
Control Fine Paniculate Matter"), and reactivity (if relevant). Additional studies and
analyses may be necessary to provide a comprehensive list of local strategies and
technologies.
2) Given that ozone (8-hour) and PM2.s (and haze) SIPs are due in mid-2007 and early
2008, respectively, EPA should issue guidance now for those source categories
considered to be associated with residual nonattainment problems (in the 2010
timeframe). Based on a preliminary review of available ambient monitoring data,
source apportionment studies, modeling analyses, and emissions inventories, it is
suggested that guidance should be prepared now for the following source categories:
• Residential woodstoves and fireplaces
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• Mobile sources (e.g., high emitting vehicles and diesel retrofit programs)
• Open burning
• Industrial operations (e.g., cement manufacturing, petroleum refineries,
pulp and paper, metals, and surface coating)
Note, the other factors identified above (e.g., emission reduction potential, timeliness,
cost effectiveness, completeness of existing guidance, and reactivity) were not
considered in identifying this list of source categories, but should be considered by
EPA in prioritizing development of the guidance, and by S/L/T in implementing the
guidance. It should also be noted that some of the source categories addressed by this
local-scale guidance may also be appropriate to address at the national/regional level
through federal rulemaking.
Benefits: This recommendation would result in guidance to help S/L/T meet the demands of
preparing SIPs for ozone, PM2.5, and haze over the next couple of years. In addition, it should
help support integrated, multi-pollutant emission reduction strategies, which should allow S/L/T
to develop control plans more effectively (e.g., targeting source categories considered to be
associated with residual nonattainment problems) and efficiently (e.g., less the time and
resources compared to develop SIPs on a pollutant-by-pollutant basis).
Feasibility: There do not appear to be barriers associated with developing guidance for local
control measures. The statutory authority for integrating area source standards into the guidance
might include sections lll(d), 112(d)(4) and (5), 112(1) or 112(k)(3) and (4) of the Clean Air
Act.
Timing: The development of the initial round of guidance would require immediate attention in
order to be useful for the first round of ozone (8-hour) and PM2.s (and haze) SIPs, which are due
in mid-2007 and early 2008, respectively. As such, the first round of the guidance should be
issued by October 200S and, as such, will likely be able to a few source categories.
Resources: The guidance can be prepared by EPA contractors and is estimated to cost around
$75K per source category.
Priority Level: High
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2.10 Residential Wood Smoke. EPA should further develop the Residential Wood Smoke
initiative that includes -working with States, Locals, Tribes, industry, non-governmental
organizations and others to support and facilitate the changeout of dirty, inefficient
"conventional" (pre-New Source Performance Standard or NSPS) tvoodstoves with new,
cleaner and more efficient heating appliances (e.g., EPA certified woodstoves and gas
appliances). Concurrently with the development and implementation of the voluntary
initiative, EPA should commence efforts to revise the NSPS.
Background/Explanation: Residential wood smoke contains PMxs and various types of
hazardous air pollutants (e.g., polycyclic organic matter). Wood smoke emissions occur in
neighborhoods where people live. Wood burning is done throughout the United States, in
varying degrees depending on the location. Large emissions reduction potential (60%-80%)
exists and there are programs that have been successfully implemented. Residential wood smoke
makes up 420,000 tons of total direct PM2.s emissions, with 80 percent of the total coming from
woodstoves. Nationally residential wood smoke contributes approximately 22 percent of all
seven of the carcinogenic PAHs identified in the EPA's National Emissions Inventory. There
are approximately 10 million wood stoves in use at this time, and 80 - 90 % of those are pre-
NSPS stoves.
Recommended Actions: Build on and implement EPA's Office of Air Quality Planning and
Standards (OAQPS) voluntary residential wood smoke reduction initiative started earlier this
year. Currently, EPA plans to pilot test the concept of wood stove changeouts in three locations
in FY 05, and then three to six more in FY 06. In FY 06-07 EPA would work to grow the
woodstove change out initiative into a grant program like the diesel retrofit program.
Concurrently with the development and implementation of the voluntary initiative, EPA should
commence efforts to revise the NSPS.
Woodstove Changeout Campaign
a) Build strong partnerships with States, communities, hearth trade association, non-
profits and others;
b) Implement 3 pilot woodstove changeout demonstration projects in FY OS;
c) Develop education and outreach materials, including website;
d) Evaluate and document FY05 successes and lessons learned;
e) Develop model woodstove changeout program template;
f) Distribute template and encourage States/Locals/Tribes to implement at local
level; and
g) Issue guidance on how to quantify the emission reductions from the wood stove
change outs for SIP purposes.
Fireplaces
a) Support development of ASTM consensus test method; and
b) Use the EPA website to educate consumers on more efficient and less polluting options.
Outdoor Wood Boilers
a) Gather information on the nature and magnitude of air quality impacts;
b) Support development of ASTM consensus test method; and
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c) Determine whether a regulatory or non-regulatory approach is warranted.
There are several examples (e.g., Crested Butte, CO) in various sizes of communities where
voluntary residential wood burning programs have been effectively implemented, particularly in
the western part of the U.S. to address PM10.
Feasibility: This recommendation is technically feasible because the cleaner technologies (50-
70% fewer PM emissions) are available and woodstove changeout programs have been
successful in the past. The idea is to greatly expand the effort and find creative ways to fund the
woodstove change outs, particularly for low income families. There are no federal standards that
require wood stove owners to replace their old dirty wood stoves (that owners often believe are
"working just fine" and appear to last forever) with a cleaner technology. Although changeout
programs in the past have depended heavily on manufacturer rebates and tax incentives, many of
the people who depend on wood as a primary heating source are low income and are not in a
situation such that they can take advantage of these incentives. Addressing this need will be a
challenge.
Timing: The initiative would be gradually ramped up from demonstration projects to a program
between now and 2008 in those areas where wood smoke is a significant contributor to
nonattainment for PM2.5 and for those areas that may be close to nonattainment for PMu. If
communities could identify foundations, businesses or other sources to obtain funding to
purchase stoves for low income families, the program could be especially effective and
woodstoves could be changed out by 2008, the likely attainment dates.
Resources: The estimated costs to EPA for FY '05 and FY '06 are $300,000 and 3-4 FTE for
each year. If the pilots are sufficiently successful, the cost to EPA could grow to $1M in FY 07.
The cost to State/Local/Tribal areas could be up to .5 FTE per location selected to assist in
EPA's pilots. If States/Locals or Tribes elect to conduct change out programs on their own
using EPA's model program developed, the cost per location would likely be up to 1 FTE. If
communities are successful in identifying sources of funding to purchase stoves for low income
families, the amounts they would need in FY '05 would be as little as S1-2M, and would grow
in the out years to $50M or more across the country. Manufacturers and retailers of woodstoves
have historically provided rebates of 10% to 20% per stove. Regardless of whether communities
are successful in securing funding to purchase stoves for low income people, some emission
reductions will occur from the outreach activities that EPA and the State/Local air pollution
control agencies conduct and the economic incentives provided by the manufacturers and
retailers, however the magnitude of the reductions would be significantly lower. Additional
funds would be needed for EPA to revise the NSPS.
Priority Level: High
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2.11 Open Burning. EPA should work with States, their respective local air pollution control
agencies, and Tribes to encourage more vigorous control of open burning, especially in, and
adjacent to, counties with Class I areas and counties classified as nonattainment for fine
particles or ozone.
Background/Explanation: Open burning has been a difficult source of emissions to control due
to the complexities of alternative waste disposal methods, associated costs, and the mindsets of
many Americans who view open burning as acceptable and of little consequence to their health.
Yet, open burning releases substantial emissions of fine particles, volatile organic compounds,
and carbon monoxide and lesser amounts of organic carbon, oxides of nitrogen, and other
pollutants of concern. Emissions from open burning, released near the ground and most often in
relative proximity to inhabited areas, contribute to urban smog, regional haze, and elevated fine
participate and ozone readings and cause periodic localized exposures in excess of acceptable
risks.
Recommended Actions: EPA should:
1) Survey State and Local agencies and Thbes, identify current levels of control of open
burning nationwide, and update open burning emissions and control information.
2) Develop SIP guidance for States, Locals, and Tribes to outline procedures and calculation
methodologies for determining emissions reductions credit for more stringent regulation
of open burning activities.
3) Consolidate information on open burning emissions and health impacts into updated
informational documents, brochures, and flyers.
4) Develop an outreach strategy designed to inform States, Locals, and Tribes of the impacts
of open burning on air quality and to encourage tighter controls in areas with inadequate
regulation of open burning.
5) Encourage States, Locals, and Tribes to include bans or more stringent restrictions on
open burning in counties with anonattainment area or a Class I area and in counties
adjacent to, or impacting, those areas.
6) Consider making open burning control strategies a component of nonattainment SIPs.
7) Develop a model open burning, rule for use by States, Locals, and Tribes.
8) Work with EPA's Office of Solid Waste to determine if a national open burning rule is
worthwhile and, to the extent that such a determination is made, pursue development and
implementation of such a rule.
States, Local agencies, and Tribes should:
1) Review available data on emissions from open burning.
2) Seek tighter controls on open burning within their jurisdictions and especially so in the
vicinity of nonattainment and Class I areas.
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3) Mount substantial public education campaigns to advise citizens of the impacts of open
burning and disposal alternatives.
4) Develop comprehensive waste management and disposal methods that reduce the
inclination of citizens to bum waste materials.
Benefits: Implementation of this recommendation would benefit public health by reducing
exposure to fine particles, ozone, NOX, VOCs, carbon monoxide, and toxic air pollutants.
Improvements in visibility would also be achieved which would help address the aesthetic goals
of the regional haze program. The nation's air pollution control agencies would benefit through
the resultant additional emission reductions that would contribute to meeting national ambient air
quality standards and aid in meeting reasonable further progress goals of the criteria pollutant
and regional haze programs.
Feasibility: This recommendation has a high feasibility for implementation because it can be
completed under existing statutory authority. It does not establish any prescriptive mandates that
would require regulatory action, with the exception of the recommendation to consider making
open burning control strategies a required component of nonattainment SIPs and to review the
possibility of creating a national open burning rule. Concerns include additional staff time to
conduct research and prepare informational documents, local reluctance to impose additional
regulatory controls on citizens, and inadequate regulatory agency staffing to enforce the
requirements at the Local, State, and Tribal level.
Timing: It is anticipated that the bulk of this recommendation could be implemented within one
year because only research and informational brochure development must be competed. The
exceptions are development of implementation guidance requiring open burning controls in SIPs
and possible development of a national open burning rule.
Resources: Redirection of existing efforts and personnel would be required. No significant
additional EPA resources are anticipated to implement this recommendation because the protocol
is non-regulatory and does not have to go through a formal public process. At the State, Local,
and Tribal level, enforcement of open burning requirements would place additional demands on
compliance staff, only some of which could be absorbed with current resource levels.
Priority Level: Medium
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2.12 High-Emitting Gasoline Vehicles. EPA and States/Locals/Tribes should reduce
emissions from high-emitting gasoline vehicles that are believed to contribute a high fraction
of mobile source emissions.
Background/Explanation: Most people are aware that increasingly stringent regulations on
new vehicle tailpipe emissions and improved durability of emissions controls have had a large
and positive effect on reducing overall fleet emissions. What is less well known is that an
increasing portion of the remaining emissions result from a relatively small fraction of high-
emitting vehicles, and that future emissions reduction will depend to an increasing degree on
developing an effective and politically acceptable means of identifying and dealing with these
vehicles.
To date, the primary program for identifying high-emitting vehicles has been periodic tailpipe
testing within vehicle inspection and maintenance (I/M) programs. Some I/M programs have
begun to phase out tailpipe testing for more recent (1996 and later) vehicles in favor of using the
onboard diagnostic (OBD-II) systems included in these vehicles. While other methods,
especially on-road vehicle remote sensing, have proven effective, in some cases, at evaluating
fleet emissions and, in a more limited role, in "clean screening" and "high-emitter identification"
programs, existing systems and methods have not yet been demonstrated to be sufficiently
effective to serve as the basis for a large scale high-emitter identification program.
California is considering a catalyst replacement program for model year 1984 to 1994 vehicles.
The replacement would be an OBD-compliant aftermarket converter. Preliminary testing has
shown significant, cost effective emission benefits. Incentives may be required to encourage
replacement when a vehicle is still meeting the required standards.
Recommended Actions: EPA and States/Locals/Tribes should:
1) Determine the aggregate impact of high-emitters on today's mobile source vehicle
inventory. Identify those areas where emissions from high-emitters contribute
significantly to the mobile source inventory. Analyze available data and develop new
data sources such as EPA's Kansas City study. Use untapped existing or new data
sources such as I/M databases and new manufacturer-run in-use data as it becomes
available.
2) Develop better means for analyzing EPA and manufacturer in-use testing data and
vehicle I/M records to identify patterns of vehicle emissions failures both as an aid in
repairing these vehicles and to provide feedback to manufacturers for improvements in
the durability of emissions control systems.
3) Encourage the continued development of on-road vehicle remote sensing or other
technologies that show promise for serving as the basis for future high-emitter
identification programs for pre-1996 vehicles. Until an effective and appropriate
alternative is available, encourage States to maintain their I/M infrastructure and to
continue testing pre-1996 vehicles.
4) Continue to evaluate the effectiveness of OBD systems, tailpipe emissions testing, and
new technologies to identify post-1996 high-emitting vehicles.
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5) Make use of new technology as it becomes available in remote sensing and OBD to
improve detection.
6) Continue to work with State and Local I/M programs to provide technical information to
assist repair technicians regarding emissions-related failures and appropriate corrective
actions and, where appropriate, to advocate and support programs that remove from
service and scrap high-emitting vehicles, especially those not OBD-II equipped, for
which cost-effective repairs cannot be made.
7) Continue outreach on OBD to increase public response to repair high-emitters after they
are detected.
Feasibility: High. Some programs to gather needed data are already underway, such as the
OBD high-mileage study and the Kansas City study. EPA (or other stakeholders) would need to
devote additional resources to collect additional data to accurately determine the impact of high-
emitters. Other steps depend on development of new technology by others.
Timing: It is anticipated that these recommendations can be implemented in 3 to 4 years as
current studies are completed, new data becomes available for I/M and manufacturer in-use data,
and additional studies are initiated and completed.
Resources: Redirection of existing efforts and personnel would be required for new work while
existing resources would be used for work already underway.
Priority Level: Variable (depends on the impact of high-emitters on inventory)
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2.13 Conformity. Conformity should be retained as part of the nation's AQM system.
Background/Explanation: The NRC found that "although individual vehicle emissions have
been reduced substantially over the past 30 years, those improvements have been offset at least
partially by continued increases in vehicle miles traveled (VMT)" (Air Quality Management in
the United States, p. 139). The technology-based emissions standards under Title II of the Clean
Air Act limit pollution levels from each vehicle but not the total pollution from in-use motor
vehicles. Conformity is the key Clean Air Act program designed to manage cumulative
emissions. Transportation conformity requires that the overall air pollution levels from motor
vehicles on highway segments and in a metropolitan area, including emissions due to planned
transportation projects, will be consistent with emissions levels necessary to assure the timely
attainment and maintenance of the health-based national ambient air quality standards.
The NRC found that the transportation conformity program has "fostered greater interaction"
between transportation planning and air quality regulatory agencies (p. 141). As a result, these
agencies have gained "more knowledge about and a greater appreciation for one another's
missions, responsibilities and procedures"; furthermore, "most transportation officials also seem
to accept the legitimacy and high priority of environmental values in transportation decision-
making" (141).
The NRC also determined that "the conformity requirement has had the largest impact on
NAAQS nonattainment areas experiencing rapid growth" (141). A pivotal prospective question,
in the NRC's judgment, is how "the conflicts between transportation and air quality goals in such
areas will be resolved and whether the federal government will remain firm in enforcing the
regulation" (142).
Recommended Actions:
1) Transportation conformity must be retained.
2) Conformity's current key requirements and schedules must be retained and effectively
enforced as an important measure to help achieve and maintain compliance with the
national ambient air quality standards. The current planning timetable requiring
transportation plans to have a 20-year horizon is consonant with the long-term planning
and investment in new highway projects as well as central Clean Air Act timetables for
nonattainment and maintenance plans. To ensure durability and integrity in the air
quality planning and management process, EPA must continue to require conformity to
attainment emissions budgets after the year of attainment has passed. The requirement to
revise transportation conformity analyses every three years is necessary to ensure
conformity is based on current data and is consistent with EPA's recently adopted State
requirement for triennial emissions inventory reporting.
3) Future administrative action should consider: (1) protection of sensitive populations
from localized, elevated particle pollution concentrations due to vehicle emissions near
highways, interchanges, terminals, and schools; and (2) expansion of emissions budgets
under the general conformity program to limit emissions from other significant
transportation sectors including, for example, marine ports, rails, airports and freight.
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Feasibility: Maintaining the current requirements and schedules is highly feasible. It is
uncertain whether legislation supported by the administration, that would shorten the period of
time covered by conformity determinations, will be adopted.
Timing: No program disruption will occur if the current requirements and schedules are
maintained. If legislation to shorten the time period covered by conformity becomes law, it
would take effect immediately.
Resources: Maintaining the current requirements and schedules requires no additional
resources. Legislation shortening the time period covered by conformity determinations would
not require any significant resources and might reduce the conformity-related burden in some
areas. However, long-term air quality impacts of on road emissions will no longer be evaluated.
EPA headquarters would be required to revise the conformity regulation to account for this.
Priority Level: Low
(Note: Priority is low because there is an effective program in place. At this time, areas are not
having significant problems demonstrating conformity for the final year of their transportation
plan. This is most likely due to emission reductions attributable to the Tier 2 and heavy-duty
diesel rules.)
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3.1 Align SIP Submittal Dates. Because ozone, PMj.s, and regional haze SIPs have similar
elements and are likely to contain similar control strategies, EPA, the States /Locals / Tribes,
and other stakeholders should strive to align the submittal dates of the three SIPs. This
recommendation is not intended to suggest changes to any deadlines for attainment or
implementation of control strategies, or to imply that a single SIP should be required for
ozone, PMis, and regional haze. It is further recommended that, in the future, EPA should
align designation dates, as appropriate, to promote muMpottutant SIP development.
Background/Explanation: Finding a way to combine all of these SIPs would provide immense
efficiencies for the States, regional planning organizations, the public and EPA. The deadlines
are close enough in time that a way should be found for States to be able to develop the three
SIPs together.
For many States there is likely to be overlap between the technical basis for, and the ultimate
development of, control strategies necessary to address the 8-hour ozone, PM2.s and regional
haze SIPs. For example, regional NOX reductions from the same source categories will likely be
a necessary element for all three plans. The resources saved from a holistic analysis and the
development of a single strategy as opposed to incremental adjustments within a few months
time has the potential of being significant. Similarly, whether the State develops a single SIP or
separate SIPs, the logistical resources associated with the processing of SIPs and the public
participation process has the potential to be reduced if multiple hearings, analyses and responses
to comments are not necessary due to the disparate deadlines.
Recommended Actions: Because PM2.5, ozone and regional haze share some of the same
precursors and because the timelines are similar, EPA, the States / Locals / Tribes, and other
stakeholders should strive to align the submittal dates of these three SIPs. However, recognizing
that it is difficult for States to accelerate adoption of the PM2.s and regional haze SIPs to coincide
with the schedule for 8-hour ozone SIPs, EPA should identify incentives (modeling assistance,
other technical assistance, resources, detailing of personnel, etc.) it could provide States in order
to assist them in accelerating the States' preparation of regional haze and PM2.s SIPs.
Feasibility: The time frames for regional haze and PM2.5 are aligned; however, the time frames
for ozone and PM2.s are offset by 6 to 8 months. Aligning all three SIPs or developing a
multipollutant SIP will require an acceleration of planning for PM2.5 and regional haze.
There are also technical issues with multipollutant modeling (discussed below). However,
traditional modeling could still be used to develop a multipolluant SIP. States' unfamiliarity
with multipollutant modeling is a challenge for accelerating schedules. CAMx and CMAQ are
photochemical grid models that are being used to assess 8-hour ozone, PM2.s and regional haze.
These models are currently being used by States and EPA for various purposes but experience is
still limited. In addition, the modeling episodes for different pollutants will be different as
ozone is a summertime problem and PM is a year-round problem. This may reduce the resource
savings that can be obtained by developing these SIPs together.
Timing: For this option to be meaningful for the next round of SIPs, States would need
guidance/ability to develop such SIPs in the immediate future as SIPs will be due in the 2007
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(ozone) to 2008 (PM2.s/regional haze) time frame. Even if developed within a year, guidance
may not be timely enough for States to use, particularly those that have long rule making time
frames.
Resources: Whether States develop these SIPs together or separately, States and EPA will need
to develop the resources to implement these SIPs. Implementation of a multipollutant approach
may require increased resource commitment in the beginning in order to achieve resources
savings in the long term.
Priority Level: High
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3.2 Protocol for SIP Development. Each State should work with the appropriate EPA
Regional Office to develop and implement a protocol for SIP development and processing that
would lay out responsibilities, expectations, and timelines for all parties. While a model
protocol should be developed, the EPA Regional Office and each State should have the
flexibility to design a protocol tailored to their specific needs.
Background/Explanation: The lack of effective and consistent communication between States
and EPA historically has been an impediment to development and processing of SIPs. EPA does
not always provide assistance to State, Local and Tribal agencies early enough in their planning
processes to address issues such as inventories, modeling, quantification of reductions from
particular control strategies, and regulation review. Likewise States and Local agencies do not
consistently provide EPA with draft versions of SIPs to review and comment upon prior to the
formal public comment period and hearing. This lack of coordination has resulted in difficulties
in meeting Clean Air Act deadlines for submittal of required SIPs.
Many States will face the difficult challenge of having to develop three major SIPs, for ozone,
PM2.5 and regional haze, within the next three years. There will be many issues requiring EPA
input and approval which must be accomplished in a methodical way. Consequently, some
States and Regions may wish to take advantage of this protocol concept to ensure the timely
development, submittal and approval of these SIPs.
Recommended Actions: To avoid delays in the SIP approval process and to limit the insertion
of new demands by EPA late in the process (after public hearings and legislative action are well
underway at the State level):
1) EPA should develop a model protocol that, if desired, could be used by its Regional Offices
in negotiating specific protocols with their States.
2) EPA Regional Offices and their States should jointly foster the development of a protocol
outlining the SIP process. This protocol should:
(a) Include enough flexibility to address all types of SIP submittals, though more complex
control strategy SIPs may need an expanded version of the basic protocol to include
emission inventory development, model selection, etc. For example: attainment
demonstrations, and rate of progress (ROP) plans for PM2.s, ozone and regional haze.
(b) Lay out responsibilities and expectations of all parties as they move through the entire
process.
(c) Include input from not only the State and the EPA Regional Office, but also the Office of
Air and Radiation and the EPA Offices of Regional and General Counsel as appropriate.
(d) Be signed by the Regional Administrator and the State Secretary (may be delegated to the
EPA Regional Air Division Director and State Air Director).
(e) Identify the role of any Regional Planning Organizations (RPOs) or Multi-Jurisdictional
Organizations (MJOs) in process.
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(f) Incorporate regular mechanisms for communication (e.g., monthly State-EPA calls);
expected turnaround for EPA review of State materials (e.g., interim approval steps); and
more streamlined processes for simpler SIPs.
(g) Include accountability mechanisms such as a computer-based system which tracks the
scheduled dates and actual dates of completion of each step of the protocol to ensure that
EPA and the States follow the agreements. An analysis of both State and EPA
performance should be conducted annually and any corrective actions identified.
(h) Identify the role of any MJO or RPO in process.
(i) Recognize that under EPA's formal Delegation Manual, SIP approvals have been
delegated to the RAs.
(j) Include a process whereby a State consults with Tribal governments potentially affected
by the SIP.
(k) Include a process whereby a Tribe, especially one in a nonattainment area, may work
with the State in developing a SIP for that area.
Feasibility: This recommendation is certainly legally feasible to implement because it may be
completed under existing statutory authority and only requires that a State and Regional Office
develop and sign a protocol.
Issues/Obstacles may include:
• The model protocol may suggest timelines; however, each State and Region must have
the flexibility to negotiate the timelines in a specific protocol recognizing such issues as
the differences from State to State in the length of their adoption processes. Realistic
timelines will aid in long-term accountability.
• Some EPA Regional Offices have multiple SIPs being developed in as many as six to
eight States simultaneously. Therefore, any model protocol will recognize that work load
and be realistically tailored to fit the needs of a given State and Region.
• Not all States and Regions feel that such a protocol is a high priority dependent upon the
current State/Regional relationship and whether or not a significant SIP backlog exists in
the Regional Office.
Timing: It is anticipated that this recommendation can be implemented in 6-9 months for the
protocol itself to be developed. To be most useful, should be completed within that time frame.
Additional time will be needed for signature agreements and to establish a tracking mechanism
or to modify each Region's current tracking system to reflect the timelines of the protocol.
Resources: Redirection of existing effort and personnel. No significant additional resources are
anticipated to implement this recommendation because the protocol is non-regulatory and does
not have to go through a formal public process. The cost associated with this recommendation is
the time of the EPA Regional and State personnel charged with the development of the protocol.
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It is strongly recommended that personnel with experience in both SIP development and
SIP processing undertake the development of the protocol.
Priority Level: High
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3.3 Clearinghouse of Approved SIPs. EPA should develop a -website, similar to the Best
Available Control Technology (BACT)/Lowest Achievable Emission Rate (LAER)
clearinghouse, containing interpretations of rules and other SIP/TIP approval-related issues.
This website could contain both policy and/or technical information depending on how it is
developed. Each EPA Regional Office should develop a website, to be updated every 12
months on or about October 1, that identifies and provides links to all statutory and regulatory
requirements in the federally approved SIP, including associated State and federal legal
citations and effective dates.
Background/Explanation: Questions regarding general SIP/TIP approvability arise with some
frequency. Many times these questions have been already been raised and answered. Because
there is no central repository for this information, the process for finding answers, or even
creating an entirely new process to arrive at the same or different answers, can be very time and
resource consuming.
An October 1st update for the Regional Office website is important because the term "updated
annually" could result in updates occurring, for example, on January 1,2005, and December 31,
2006, which meet the "annual test" but would be in actuality a 2-year span.
Recommended Actions: EPA should develop this clearinghouse. This would probably be on
the Technology Transfer Network portion of EPA's website but could be developed by a Region
or Regions and/or OAQPS. It is important that information is easily accessed on the website or it
will have defeated its original intent.
Additionally, each EPA regional office should develop a website containing all of the statutory
and regulatory content of the applicable SIPs over which it has jurisdiction. For each statutory
and regulatory requirement in the applicable SIP, this website should contain at least the
following information: (a) a citation of (including title) and link to every State statute and
regulation that is included in the applicable SIP; (b) the State effective date; (c) the federal
publication date; (d) the federal effective date; and (e) the applicable federal register citation.
Each of the above websites should be updated no less frequently than by October 1 of each year.
Benefits: A centralized and publicly available database of SIP approval issues, responses to
comments, and other types of decisions would assist EPA staff, States and the public to
understand what issues have arisen previously and how they were decided. This would improve
efficiency and consistency of Federal, State, Tribal and Local agencies.
Feasibility: Feasibility is high. This would not require any legal, statutory or regulatory
changes. Possible hurdles include lack of resources.
Timing: Timing on this project is not critical as there are no deadlines that would render this
project obsolete. It could, however, be helpful in developing the upcoming ozone, PMis and
regional haze SIPs if it was done sooner.
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Resources: There may be direct monetary costs associated with this project if contractors are
used. Otherwise it will require personnel hours which would be spent finding information,
designing this website, actually building the website, filling in the database, etc.
Priority Level: Medium
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3.4 Streamline Minor SIP Revisions. For the SIP approval/disapproval phase of the air
quality management process, EPA should establish a de minimis level for SIP revisions and
streamline the processing of these revisions by the use of "letter approvals" or similar
expedited procedures signed by the Regional Administrator. EPA should, in consultation with
States/Locals/Tribes and other stakeholders, develop a listing of the types of SIP actions that
are eligible for streamlined processing.
Background/Explanation: There are certain SIP revisions submitted by States which revise
only administrative State requirements, apply to a very narrow and often specified group of
sources in a small geographic area, and/ or have quantifiable emissions changes (increases or
reductions) which have minimal (i.e., de minimis) impact on overall emissions levels or PSD
increment consumption in a given geographic area (especially designated attainment areas). Yet,
such official State submittals must still undergo the full administrative process that is required of
all Federal rulemaking actions. A survey of SIP revisions that are currently undergoing review
in the Regional offices is likely to reveal that a significant number (perhaps 25% to 35%) of all
formal SIP submittals consist of State provisions which would result made minimis impact
Because of the sheer volume of these revisions, the processing by EPA is often slow, and
becomes a source of frictions between States and the Regional Offices. This process includes a
separate review by the Office of Management and Budget (OMB) of all final rulemaking actions
where EPA announces full disapproval of a SIP revision request.
Recommended Actions:
1) EPA, with input from States and Tribes (both program offices and attorneys) should institute
a process for developing guidance which defines what could be considered de minimis with
respect to SIP revisions, both in terms of subject matter and emissions limit. Regulatory
change which could increase emissions on a nonattainment area or an OTC-like area or
which would result in consumption of a PSD increment might not be candidates for the de
minimis process. However, some source-specific emission limit changes might be
considered de minimis. Also, recodification actions which involve no substantive revisions
to a State's regulatory text could be considered de minimis, as might be revisions where
State incorporates by reference an existing Federal requirement.
2) EPA should revisit and update the January 30, 1989 policy memo on letter notices, and see
whether such actions could still be used for the processing ofde minimis actions. Also, if a
SIP revision is processed through a letter notice, then we need clear guidance from OGC as
to what the effective SIP date would be.
3) As an alternative, EPA could "bundle" in one rulemaking action (direct final, whenever
possible) a series of separate formal SIP submittals which meet the de minimis criteria.
4) EPA should work with the Office of Management and Budget (OMB) to explain the concept
ofde minimis actions and request an exemption to the OMB review process in the event of a
full disapproval of a de minimis SIP action.
5) EPA should apply, as often as possible, the de minimis review process to other low-key
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Federal plan actions such as Section 11 l(d)/129 plan revisions.
6) EPA should work with States to ensure that certain State administrative provisions
governing the State regulatory and enforcement process are not submitted as SIP revisions,
not even under a streamlined de minimis process. Section 110 only requires that States have
a public hearing process and an enforcement program. The State procedures, by which
public hearings are announced, held and recorded or how search warrants are obtained and
executed need not be in the SIP. The exemption of such State administrative provisions
from SIP review would prevent the tying-up of EPA resources to process SIP revisions that
have virtually no environmental impact.
Feasibility: The feasibility of this process depends on certain legal decisions:
1) Whether EPA, States, and Tribes can come to consensus as to what constitutes a de minimis
revision.
2) Whether the issuance of an approval letter notice can set the effective date of the SIP or
other plan revision. If the attorneys determine that only a Federal Register notice action can
set the effective date, then the use of letter notice procedures may not produce the desired
outcome of expeditious SIP processing. However, if the attorneys come to a consensus that
making SIP actions effective through the issuance of letter notices meets the requirements of
the APA, and results in expedited Federal effective dates, then the use of Letter Notices for
de minimis actions should be utilized to the fullest extent.
3) Whether OMB is likely to grant an exemption for its review of a full disapproval action, if
such action is taken for a revision that EPA has determined to be de minimis.
4) Whether further streamlining of the Direct Final Rule process could be considered.
Examples would be a 15-day comment period or an effective date of 45 days after
publication of the Direct Final rule notices.
5) How the RME Docket system, which enhances the public's ability to review and comment
on EPA decisions, would need to be modified to accommodate EPA decisions made through
a letter notice or similar expedited processes.
6) Whether EPA would have to develop and publish a blanket rulemaking action to explain to
the public how the rulemaking process ofdi minimis actions would be handled. EPA
followed this step to explain: 1) the use of the direct final rulemaking process; and 2) the
rule process which allowed Regional Administrators to sign final rulemaking actions. Such
a formal action on the process of handling de minimis actions may assure the legality of the
use of the expedited process for individual de minimis actions.
Timing: This recommendation could be implemented in 12 to 18 months since 1) processes and
procedures need to be developed; and 2) EPA would have to prepare a Federal Register notice
signed by the EPA Administrator, announcing to interested parties the streamlined rulemaking
process for de minimis SIP [and other plan] actions.
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Resources: EPA could utilize the standing National SIP Processing Work Group, comprise of
representatives from all 10 Regions, OAQPS and OGC. The Work Group also interacts with
EPA's Federal Register liaison as well as legal staff from the Office of the Federal Register. If
so determined, the Work Group could work with a committee of State and Tribal representatives
to help implement the process to define the scope ofde minimis SIP [and other plan] actions and
a process for providing expedited Federal Review.
Priority Level: High
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3.5 Timely EPA Guidance. EPA guidance should be issued in sufficient time for States to
meet their SIP development deadlines. EPA should involve States /Locals / Tribes and other
appropriate parties in its guidance development process. In cases where guidance is delayed,
EPA should take into consideration States' efforts to meet deadlines without the benefit of the
appropriate policy guidance.
Background/Explanation: States cannot develop SIPs without guidance. Frequently, States are
placed in the position of having to prepare SIPs under a specific deadline, but are dependent on
EPA to develop guidance for the SIP. Delay by EPA in preparing guidance can cause: 1) States
to be rushed in meeting their deadlines; 2) States to miss deadlines for submittal; and 3) States to
develop SIPs which may later have to be revised in order to be accepted. This can lead to
criticism of EPA due to lack of timely performance and blame of EPA for failure to make timely
SIP submittals. Missing deadlines can cause States embarrassment and criticism from the public,
at a minimum, and can cause sanctions, at worst. EPA is also criticized for not involving
stakeholders (States/Tribes and others) in development of guidance. Not involving stakeholders
usually results in guidance that is difficult to implement, requires excessive resources by the
States and invites litigation by the excluded stakeholders. This paper focuses on SIP actions;
however, if there are non-SIP actions where EPA guidance is critical and timing is of the essence
in order to avoid an adverse reaction, such as sanction clocks, then the product of this effort
should be implemented in those situations as well.
Recommended Actions:
1) EPA should institute a process for developing guidance which:
(a) Recognizes the timeline the States are under to implement the SIP involved.
(b) Establishes a priority and plan which will ensure that the guidance is published in time
for State's use to meet deadlines.
(c) Includes stakeholders in developing the guidance, guidance review and setting the
priority for guidance. The Clean Air Act Advisory Committee (C AAAC) could serve this
role, as could STAPPA. The chosen organization should also evaluate a restatement by
EPA of what the agency is doing now and determining if modifications to our stakeholder
process are necessary.
(d) Ensures that adequate EPA resources are applied to the guidance.
(e) Delegates decisions within EPA to facilitate more timely guidance.
2) This process should be accomplished as a pilot. The pilot should explore what
regulation/guidance development within EPA is felt by States and stakeholders to be
working well. In the short term, the best aspects of process(es) determined to be working
well should be identified and instituted into this process for developing guidance.
3) EPA responds best when under a deadline. This is especially true for actions under court
deadlines or consent decree deadlines. In order to set deadlines, EPA should indicate in the
final Federal Register notice if any guidance is still needed after a rule is finalized. The
Federal Register should identify the target date for completion of such guidance.
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Feasibility: The recommendation is feasible in that it only requires the establishment of a
process to ensure the timely development of guidance. One obstacle to accomplishing this may
include established organizational bureaucracies which have review and concurrence authority
and do not have responsibility for meeting deadlines in guidance development. In other words,
there should be as much urgency in developing guidance as there is in developing rules. Another
obstacle may be lack of staff resources necessary to develop the guidance in die necessary time
frame. Staff are often working on multiple projects at any given time and cannot always devote
the time needed to develop the guidance and follow it through the review and concurrence
process.
Timing: This recommendation should be implemented in six months. Since it would not be tied
to any one specific SIP schedule, it is difficult to specify a due date, other than as quickly as
possible.
Resources: Resources should be a small project team made up of staff with experience in
guidance document preparation, and process and procedures development. Guidance is
nonregulatory and will not have to go through a formal public process; therefore, no resources
required for public process.
Priority Level: High
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3.6 Avoid Unnecessary Public Hearings. EPA should work with States and Tribes to develop
a model regulation that would require a public hearing for SIP revisions only if one is
requested after public notice. This recommendation is not intended to restrict public comment
in any way; it is meant only to eliminate those hearings that no one attends.
Background/Explanation: The CAA has long been interpreted to require a public hearing be
held by States for all SIPs and SIP revisions prior to their submittal to EPA. Holding public
hearings is resource-intensive in terms of time and expense to the State. The use of State
resources is justifiable when interested parties testify at the hearing. However, those resources
are wasted in many instances where no comments or testimony are offered at the public hearing.
Section 110(a)(2) of the CAA requires that States hold a public hearing for any prospective SIP
revision. This requirement is repeated in regulations at 40 CFR 51.102. However, 40 CFR
51.102(g)(2) provides that "Procedures different from this part may be approved if they (i)
ensure public participation in matters for which hearings are required; and (ii) provide adequate
public notification of the opportunity to participate." Minimal case law exists to judge what
EPA might be able to approve as a
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Feasibility: Some subset of SIP revisions may be able to be identified for which the State could
provide the opportunity for a public hearing and hold one only upon request to satisfy section
110(a). To make the opportunity for hearing only upon request sufficient for all SIP revisions
may require a statutory change to section 110(a).
Timing: The legal workgroup could be convened by EPA, ECOs/STAPPA/ALAPCO, NTC and
charged with completing the recommended actions by a given date. The Recommended Actions
should be implemented as soon as possible and completed well before the next round of SIPs
revisions are required for 8-hour ozone, PMzs and regional haze.
Resources: The cost to EPA/States/Tribes would the time of their attorneys.
Priority Level: High
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3.7 Facilitate Redesignation Process for Certain Areas.. For those areas that have not
pursued and been granted redesignation when initially eligible, and have continued to
demonstrate violation-free ambient air quality data for several years, EPA should expedite the
redesignation process. EPA should ensure that all Regions and States are aware of the
simplified procedures. This recommendation is not intended to change the requirements for
redesignation under the Clean Air Act
Background/Explanation: States should not be required to meet needlessly complex and
resource-intensive requirements to redesignate nonattainment areas that have five or more years
of violation free ambient air quality data that has been quality assured/quality controlled and
entered into the national Air Quality Systems database. This is particularly true of areas with
slow or no projected growth in emissions over a ten-year maintenance period.
Recommended Actions: All EPA Regional Offices should disseminate and provide any needed
assistance on the implementation of both the May 10,1995 Clean Data Policy (CDP) and the
"Limited Maintenance Plan Option for Moderate PMio Nonattainment Areas, commonly referred
to as the Limited Maintenance Plan Policy (LMPP). The CDP allows the Part D SIP
requirements of an approved attainment demonstration, rate of progress (ROP) plan and their
associated contingency measures to be waived in areas with three or more years of violation free
data. Similarly, the Limited Maintenance Plan Policy (LMPP) can exempt an area from modeled
maintenance demonstration. These policies change and simplify the technical requirements for
redesignation, not the legal requirements.
Feasibility: This recommendation is feasible. It has already been implemented on a limited
basis by EPA Regions 3 and 4 during the processing of several state redesignation requests (and
associated maintenance plans) for ozone and PMio. The use of the CDP and LMPP has not yet
faced a legal challenge but, properly implemented, both policies are considered defensible by
EPA's Office of General Counsel.
Currently, there are issues restricting the use of the CDP and LMPP for SO2 and CO
nonattainment areas. These issues are addressed in the September 4,1992 memorandum
entitled, "Procedures for Processing Requests to Redesignate Areas to Attainment."
Many States choose not to redesignate because there are no regulatory drivers encouraging
redesignation; plus States may find advantages to retaining nonattainment status.
Timing: Can be implemented immediately.
Resources: The only resources necessary would be those in educating the EPA Regions,
State/Local/Tribal entities that are unfamiliar with these policies.
Priority Level: Low
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3.8 Effective Communications with Constituencies. EPA, States, Local agencies and Tribes
should develop a menu of options for effective communication to build support with a wide
variety of constituencies for clean air plans at the Local and State level
Background/Explanation: The NRC report concluded that the SIP process is overly
bureaucratic, drawing attention and resources away from the relevant issues of tracking progress
and assessing performance. Both State officials and the regulated community complain that the
planning process is cumbersome, lengthy and difficult for the public to comprehend, which
encumbers the goal of developing and adopting air quality control plans, and attaining and
maintaining national ambient air standards.
Recommended Actions: Elements of these plans are frequently the subject of public lawsuits.
Yet successfully engaging the public early in the SIP development process builds general
understanding and support. Although some States and local air agencies achieve this through
their current outreach programs, some do not. These discussions are timely as States prepare to
develop SIPs for new federal ambient air quality standards for 8-hour ozone and PM2.s.
A more aggressive marketing approach can help educate the public about the need to clean up
local air pollution; getting the public involved in the SIP process is much more difficult. Often
air agencies only hear from those members of the public who have 1) time and resources to send
representatives to meetings; or 2) financial interests at stake, which make the expenditure of time
and resources worthwhile. Even the environmental community often cannot participate fully due
to limited staff and financial resources.
Influencing community opinion leaders is a tested means of shaping public opinion, particularly
in the short-term. However, all too often State and federal agencies do not use these techniques
because of staff and resource limitations or department policies which constrain outreach.
Although transmitting a message to the people who help shape public opinion is critical, merely
sending press releases or letters of invitation to a community meeting is not effective. States and
local air agencies must engage them directly.
Building support for newer pollutant programs requires public education about the direct health
risks associated with ozone and PM Fine. Effective outreach is most often achieved at the local
level, where communities can relate to specifics and risks that may effect them and motivate
behavioral change. Some methods to collaborate with States and engage the public locally could
include the following actions:
• Target key opinion leaders.' States and local air offices should initiate or expand the use
of editorial board meetings to reach key media opinion leaders.
• States and locals should develop relationships with local reporters covering the issue.
• All States and locals should be sure that the Air Quality Index is forecast and reported in
weather reports in their communities.
• States and locals should meet with local leaders in the Chambers of Commerce in their
areas.
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• States and locals should make presentations to key civic groups in the community.
• States and locals should meet with leaders in the religious community and work with
them to reach out to their membership.
• States and locals should meet with leaders in neighborhood associations and work with
them to reach out to their membership.
• States and locals should meet with local and State environmental and public health
groups to enlist their involvement in the process and their partnership in outreach efforts.
• States and locals should meet with key elected officials early and often in the process to
keep them and their key staff informed.
• EPA should host focus group meetings to identify messages that build support for these
issues.
• EPA should develop outreach materials targeted to diverse communities that explain the
SIP process and the health effects of air pollution.
• EPA should offer training on efficient web content development for local government
sites, incorporating AIR NOW real-time ozone and PM projections.
• STAPPA/ALAPCO and EPA should identify and catalog existing resources and develop
additional appropriate tools based on targeted audiences.
• EPA should schedule State public meetings/workshops during SIP/rule development.
• STAPPA/ALAPCO and EPA should identify additional financial and staff resources to
help agencies develop, produce and disseminate appropriate tools that reach targeted
audiences, with the goal of garnering public support for the SIP process.
Feasibility: It is likely that these recommendations will be implemented if expertise between
federal, State and local agencies are shared. The STAPPA/ALAPCO Public Education and
Communications Committee may be an appropriate group to coordinate this effort. EPA's role
can include development and dissemination of outreach materials that are nationally applicable,
as well as improving how information may be made available on its website.
Timing: As SIP development progresses, public involvement should be actively encouraged
throughout the process.
Resources: Redirection of existing effort and personnel; additional resources should be
considered as outreach planning intensifies.
Priority Level: Medium
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3.9 Co-Benefits of Innovative Measures. EPA and States, Locals, and Tribes should work
collectively to communicate the co-benefits associated with innovative SIP measures.
Background/Explanation: The public is concerned with basic goals, such as improving public
health and increasing economic and environmental benefits. When considering pollution control
alternatives, broader support of a measure can be realized by determining and articulating the
range of co-benefits provided by the measure. Overemphasis on receiving SIP credit for new
and innovative types of pollution control initiatives limits public understanding and support for
such initiatives.
Recommended Actions: In evaluating an innovative measure, or bundle of measures:
• EPA and States should communicate how proposed strategies and innovations would
improve quality of life more generally.
Feasibility: This recommendation has a high feasibility for implementation because in August
2004, the EPA committed to continue to bring stakeholders from federal, State, local, and tribal
agencies, the public, and the regulated community together for an annual Air Innovations
Conference. The conference will highlight the benefits of new and innovative air quality
projects going on around the United States and encourage dialogue among stakeholders.
Timing: It is anticipated that this recommendation can be implemented in 6-9 months as EPA
has already committed to hold an annual Air Innovations Conference for the purpose of
improving the dialogue among stakeholders.
Resources: Only minor redirection of existing efforts and personnel would be required.
Priority Level: High
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3.10 Innovative and Voluntary Measures. EPA should encourage States'and Tribes'efforts
to implement innovative measures by providing enhanced flexibility, SIP/TIP credit guidance,
technical support, and funding for innovative and voluntary programs.
Background/Explanation: As areas continue to experience challenges in meeting air quality
standards many still have to adopt and implement additional measures to meet the SIP
requirements for attainment, reasonable further progress (RFP), rate of progress (ROP) or
maintenance requirements. Some areas have implemented most available traditional emission
control strategies and want to try new types of pollutant reduction strategies to attain or maintain
the NAAQS. The EPA needs to continue to develop policy and technical guidance for the
purpose of providing States and Tribes with the flexibility to test and use new and innovative
emission reduction strategies in their SIPs/TIPs.
Recommended Actions: To continue to encourage, foster and support innovative and voluntary
programs and measures in SIPs/TIPs, EPA should take the following actions:
1) EPA should clarify and expand the channels through which States and Thbes may gain
SIP/TIP credit for innovative measures by issuing additional enabling guidance and by
balancing the level of effort required for approval (recordkeeping, reporting, etc.) with
the level of environmental benefits anticipated. EPA has begun this process by issuing
new policy and guidance covering:
- SIP credit for voluntary and emerging measures
- SIP credit for energy efficiency and renewable energy initiatives
- SIP credit for reductions in truck and locomotive idling emissions
2) EPA should create a clearinghouse for information on new technologies, innovative
approaches, mentoring resources, and "off-the-shelf measures, pilot projects, and
quantification techniques. As an initial step, EPA is creating an interactive Innovations
website to assist State/local/tribal governments in their efforts to implement innovative
and voluntary programs.
3) Building off successful pilot studies, EPA should develop sector-based guidance that
would synthesize and clarify innovative technological approaches to reducing pollution
in the key sectors.
4) EPA should offer targeted funding to promote innovation. EPA has begun this process
by providing funding for the following specific innovative projects: 1) Pollution Control
Strategy Rapid Assessment & Optimization Tool (Response Surface Model) to provide
state/local agencies accurate and economical tools for quickly determining the most cost-
effective local strategies for meeting air quality standards; 2) Residential Wood Smoke
Reduction Initiative; 3) grants for State/Local Innovative Approaches to Reducing Air
Pollution; and 4) grant(s) for stationary diesel retrofit project.
Feasibility: This recommendation has a high feasibility for implementation because it can be
completed under existing statutory authority and only requires mat EPA continue to focus on
providing responsive and timely guidance and technical support.
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Timing: It is anticipated that this recommendation can be implemented in 6-9 months as many
of the action items are already under development or consideration by the EPA.
Resources: Only minor redirection of existing efforts and personnel would be required as many
of the action items are already under development or consideration by the EPA.
Priority Level: High
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3.11 SIP Credits for Bundled Innovative Measures. EPA should incentivize innovative
pollution control strategies by offering SIP/TIP credit for "bundled and discounted"
measures.
Background/Explanation: States and Tribes are often discouraged from adopting innovative
measures because those measures are typically too small-scale to result in significant SIP/TIP
credit. In addition, results of those measures may be hard to quantify or verify individually. In
the aggregate, however, such measures can significantly impact air quality. Currently, EPA has
increased the amount of SIP credit States can earn for stationary voluntary and emerging
(innovative) measures to a presumptive 6 percent through its latest guidance document on
Incorporating Emerging and Voluntary Measures in a SIP (September 2004).
Recommended Actions: EPA should encourage States to experiment with new and innovative
approaches to air pollution. Specifically, EPA should:
• Grant States and Tribes SIP/TIP credit upfront for a "bundle" of small, innovative
measures and evaluate the measures in the aggregate by looking at air quality
improvements after implementation. An appropriate discount factor should be applied to
the credit, considering the amount of credit claimed and the level of uncertainty
associated with quantifying the actual air quality benefits of the bundled measures.
Feasibility: This recommendation has a high feasibility for implementation because of EPA's
recent policy on "Incorporating Emerging and Voluntary Measures in a SIP" which enables a
State to receive SIP credit for emission reduction or pollutant reduction measures which are more
difficult to accurately quantify or enforce than traditional SIP emission reduction measures.
However, any approval of "bundled" measures in a SIP will need to be conducted through full
notice-and-comment rulemaking in the context of a particular state SIP revision.
Timing: It is anticipated that this recommendation can be implemented in 6-9 months as the
overall enabling policy framework is now in place in the form of EPA's recently issued guidance
on "Incorporating Emerging and Voluntary Measures in a SIP."
Resources: Only minor redirection of existing efforts and personnel would be required as a
policy and guidance framework is already in place.
Priority Level: High
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3.12 Regional Approaches to SIP Planning. For many areas, planning for new SIPs or
major revisions to existing SIPs for two or more separate nonattainment areas that are both
part of the same regional scale air quality problem should be coordinated. If requested by a
State, EPA should work -with the different nonattainment areas, Tribes and combinations of
multistate organizations and other stakeholders, as appropriate, to assist in the development of
regional approaches to planning. This could include technical assistance such as modeling,
national or regional control strategies, model SIPs, and model rules as templates for State/
Local/Tribal adoption.
Background/Explanation: The interstate transport of criteria pollutants and criteria pollutant
precursors make State-by-State planning both impractical and ineffective. Moreover, even the
appearance that neighboring States are developing SIPs regulating the same industrial sectors for
the same pollutant(s) with differing levels of stringency quickly brings delays to the SIP/TIP
development and adoption processes. The nature of many areas' 8-hour ozone and PM2.s
problems increasingly call for the development and implementation of regional control
strategies.
Recommended Actions:
1) Groups of States/Locals should redefine the role of existing Regional Planning
Organizations (RPOs) and Multi-Jurisdictional Organizations (MJOs) to include supporting
planning for all regional air pollution problems (e.g., 8-hour ozone, PNh.s, regional haze).
2) These organizations should amend their charters and by-laws as necessary for clarity of
purpose and eligibility for additional grants.
3) These organizations should continue their established stakeholder involvement procedures in
the development of model rules and model SIPs.
4) EPA personnel from multiple Regional Offices and OAR should review and comment upon
model rules and model SIPs with an eye to their eventual adoption by State/Locals/Tribes
such that any potential approval concerns are addressed up front.
5) In addition to model rules, RPOs/MJOs should develop standardized Technical
Support/Analysis Documents for SIPs/TIPs being adopted by their member States/Tribes.
6) RPOs/MJOs should develop procedures for inter-RPO/MJO coordination to ensure
consistency, as needed, in their air quality planning processes and comparability in their
work products.
7) EPA should pursue discussions with OMB to ensure the flexibility of the use of grant funds
allocated to RPOs/MJOs so they address multiple ambient air pollution problems as "one
atmosphere" under a single grant such that the most scientifically valid and cost effective
approaches can be studied and implemented.
8) The technical activities of RPOs/MJOs should be closely coordinated with the technical
support activities and R&D programs of EPA.
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Pilot Studies: Examine the benefits of the STAPPA/ALAPCO, OTC and WRAP model rules
along with other model rules and SIPs developed by NESCAUM, LADCO, SES ARM, VISTAs,
CENSARA, CENWRAP, MARAMA, MANE-VU.
Feasibility: No statutory changes are necessary. Ease of feasibility is dependent upon the
State/Local/Tribal desire to redefine/expand the role of RPOs/MJOs and to get charters and by-
laws amended, as necessary.
Large neighboring groups of States/Locals/Tribes are already using RPOs to develop model SIPs
and rules for regional haze. The successful efforts of the Western Regional Air Partnership
(WRAP) for the regional haze SIPs under section 309 in the West and the Ozone Transport
Commission for ozone SIPs in the Northeast are evident.
Timing: Should be implemented within one year to be effective for 8-hour ozone and PM2.s-
EPA needs to work with OMB in the next budget cycle to pursue flexibility in the use of federal
grants to RPOs/MJOs to work on multipollutant approaches to solving ambient air pollution
problems.
Resources: The MJOs/ RPOs are already established. While negotiations and coordination
between States/Locals/Tribes, Federal Land Managers and multiple EPA Regional Offices may
initially take longer than each State only having to develop its own SIP internally, once
procedures are established and schedules set, the time savings will be significant. The cost
savings, particularly in the areas of emission factor and emission inventory development and
modeling will be substantial. The regulated and environmental community and interested
citizens would save resources by participating in the RPO/MJO stakeholder processes rather than
having to spread themselves over each State's SIP development process.
Priority Level: High
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3.13 Federal and State Partnerships. EPA should participate with State and Local agencies
and Tribes in the SIP/TIP development process to identify and pursue emission reductions
from federal and international sources and other sources which the federal government has
primary responsibility to control The level of control sought from these sources should be
commensurate with their impact in the nonattainment area. As warranted by the nature of the
source, control strategy development should be carried out by State and Local agencies and
Tribes working either directly with EPA or with EPA and other federal agencies. For
attainment demonstration purposes, States should be able to take appropriate credit for
anticipated reductions from these sources (whether they are from regulatory or incentive
programs) so long as the control strategy and its anticipated impact are found to be consistent
with EPA regulation and guidance.
Background: States are generally unable to regulate emissions from sources under federal or
international jurisdiction, and have limited ability to regulate other on-road and non-road
sources. Such sources can be major contributors to the air quality problem in many
nonattainment areas. Under the Clean Air Act, EPA is given authority to regulate new mobile
sources and their fuels and is able to assist State and local agencies and Tribes in regulating
existing mobile sources and in achieving the desired control from federal sources either through
direct EPA regulation or by working with other federal agencies. Similarly, EPA has the ability
to work with other parts of the federal government in seeking the control of international sources.
Such emission controls can, as appropriate, take the form of the direct regulation of emitting
sources, incentive programs to reduce emissions, international agreements and other forms.
Under existing EPA guidelines all of these forms of emission reduction can be credited in SIPs.
Recommended Actions:
1) EPA should participate with State and local agencies and Tribes in the process of identifying
and pursuing measures to achieve the emission reductions from national and international
sources needed to attain the 8-hour ozone and PM2.j standards by the attainment dates in
each nonattainment area.
2) Early in the SIP development process, EPA should consult with State and local agencies on
preliminary emission targets for each federal sector, help develop options to achieve those
reductions, and aid in providing estimated benefits for State use in draft SIPs for public
review.
3) EPA should expedite the approval of new technologies such as retrofits and alternative fuel
formulations that can be applied to existing fleets within a nonattainment area.
4) When assessing controls, EPA should consider cost-effective technologies proven to control
similar sources not under direct federal authority.
5) In those cases where States have limited ability to control a category of sources, where such
sources are a key part of the problem and where national programs are not feasible, EPA,
working with State and local agencies and Tribes, should develop targeted strategies for
affected nonattainment areas, including multistate or regional strategies.
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6) For federal sources that EPA does not have the authority to control directly, EPA should
work with other federal agencies (such as the Federal Aviation Administration) to secure
significant near-term and long-term reductions.
7) EPA should negotiate with international standards-setting entities on actions to achieve the
reductions necessary to meet the attainment targets for these sectors (i.e., the International
Civil Aviation Organization (ICAO) and the International Maritime Organization (IMO)).
8) EPA should pursue international agreements with neighboring countries to address
international emissions outside States'jurisdiction.
Benefits: Identifying and pursuing the necessary emission reductions from national and
international sources will help ensure that the public health benefits of national air quality
standards are achieved and that States do not suffer the economically from sanctions due to
failure to comply with SIP requirements.
Feasibility: This recommendation calls on EPA to more directly address the attainment needs of
each area by becoming a fuller partner early in the planning process. Implementing some
potential strategies would require actions or funding by other federal agencies or Congress,
international organizations, and other countries.
Timing: Because States are already in the development process for 8-hour ozone and PM2.s
SIPs, this activity needs to be initiated immediately.
Resources: EPA could use existing resources. EPA staff is already familiar with federal
emissions sectors that could provide additional emission reductions. Additionally, States have
established incentive programs that could serve as models for federal incentive programs.
Priority Level: High
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3.14 Weight-of-Evidence Demonstrations: In order to move beyond the current approach of
relying on air qualify modeling, EPA, in conjunction -with S/L/T and affected stakeholders,
should modify its guidance to promote weight-of-evidence (WOE) demonstrations for both
planning and implementation efforts. In particular, these demonstrations should reduce
reliance on modeling data as the centerpiece for SIP planning, and should increase use of
monitoring data (and analyses of monitoring data) especially for tracking progress.
Background/Explanation: The current system is top-heavy on modeling for planning purposes
(especially, the preparation of an attainment demonstration) and light on tracking progress. The
NAS recommended that "a more useful approach would be to retain the attainment
demonstration as a planning tool but to place greater emphasis on follow-up measures to track
compliance and progress and on actions to be taken if compliance and progress are not
satisfactory." This recommendation will focus on defining a more effective use of technical
tools for a performance-oriented air quality management approach, and recognizes that S/L/T
need to accomplish this work with available resources. Enhanced tracking and ambient
monitoring (to track progress) is a better use of resources than intensive local modeling.
Recommended Actions: To move beyond the current approach of relying on air quality
modeling, the Subgroup recommends the following actions
1) Planning efforts should incorporate a weight-of-evidence (WOE) approach to provide
the most technically defensible basis for a control plan and to satisfy any statutory
requirement for a demonstration of attainment. A WOE approach is especially
important when the modeling shows that the area is projected to be either just above
or just below the ambient standard. (It should be noted that the WOE demonstration,
including the modeling, must be subject to public review as part of the SIP process.)
The WOE approach should include the following three elements:
(a) A prospective modeling analysis, performed in accordance with an EPA-
approved modeling protocol. Modeling should be used to identify the
appropriate control path. Unfortunately, over-reliance on modeling can
produce unnecessary debates over technical details, which can hinder
efforts in getting emission reductions and cleaning-up the air. EPA should
work with S/L/T and affected stakeholders to modify its guidance to
clarify the proper use of modeling and WOE for SIP planning.
(b) Analyses of air quality data, including preparation of a
conceptual/qualitative description of the area's nonattainment problem,
examination of historical air quality and emissions trends, assessment of
(incoming and outgoing) transport (e.g., trajectory analyses), and use of
observation-based methods (e.g., receptor models, and indicator species
and ratios).
(c) Summaries of current actual and expected future year emissions by species
(primary and secondary), by year (base year, attainment years, and
appropriate interim years), and by source sector. Assumptions used in
projecting emissions growth must be well documented.
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2) Implementation efforts (i.e., periodic progress assessments) should consider similar
WOE elements, including:
(a) A retrospective modeling analysis (as necessary) to assess progress in
meeting air quality standards and visibility goals.
(b) Analyses of air quality data, including examination of recent
(meteorologically adjusted) air quality trends and emissions trends.
(c) Summaries of actual emissions by species (primary and secondary
species), by year (base year, attainment years, and appropriate interim
years), and by source sector. Assumptions used in projecting emissions
growth must be well documented.
3) To assist S/L/T with these planning and implementation efforts, EPA should issue
WOE guidance, which clarifies the proper role of modeling for SIP planning,
establishes standard WOE procedures (e.g., when WOE considerations are
appropriate, how to ensure that use of WOE is a symmetric process, and how to
determine what additional evidence should be considered and how it should be used),
and identifies appropriate data analysis methods (e.g., methods for estimating
statistically significant trends which account for meteorological effects).
Benefits: Better use of modeling and monitoring data can provide a sounder basis for control
strategy development, and allow better tracking of compliance and progress.
Feasibility: All the technical tools are available for performing the necessary modeling and data
analysis activities, including work being performed by the RPOs and MJOs. The bigger issues
are likely to be the availability of sufficient air quality measurements, and the staffing/resources
needed to conduct these analyses. The EPA guidance should address the tools/methods, as well
as the data requirements and personnel needs.
Timing: Given the potentially large scope of this recommendation, it is important to break the
analyses into pieces and assess the time required to complete each of them. A workshop with all
interested parties should be held to develop further this recommendation. Once there is a general
framework of what is to be done and the data needed to support that framework, the guidance for
addressing the other activities can be prepared.
Resources: To conduct such extensive analyses, a wide variety of experts will be required (e.g.,
statisticians, meteorologists, air quality data analysts, emissions inventory experts). In addition,
someone with the ability to put the analyses into concise wording will be needed to communicate
the findings. Up to 4-5 FTEs that have the skills outlined above, as well as contract funds (e.g.,
$50K for workshop and follow-up actions) is estimated to develop appropriate guidance.
Resources for training for S/L/T personnel are also needed.
Priority Level: High
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3.15 Periodic Assessments to Track Progress; S/L/T and EPA should conduct periodic
assessments to ensure that areas are on track to meet NAAQS, HAP, and visibility goals, and
make mid-course adjustments, as necessary.
Background/Explanation: One of the long-term objectives identified by the NRC is to guide
future improvement of the air quality management system is to take a performance-oriented
approach. This approach would emphasize "performance rather than the process" and would
"create accountability for achieving results." The NRC recommended that "a more useful
approach would be to retain the attainment demonstration as a planning tool but to place greater
emphasis on follow-up measures to track compliance and progress and on actions to be taken if
compliance and progress are not satisfactory." This recommendation will focus on tracking
progress and what to do if areas are not on track to meet NAAQS, HAP, and visibility goals.
The previous recommendation (3.14) addressed the definition of a more effective use of
technical tools for a performance-oriented air quality management approach.
Recommended Actions: To begin to lay the foundation for a performance-oriented approach,
the Subgroup recommends the following actions:
1) States and EPA should work together on tracking progress, including a review of
changes in actual emissions and air quality concentration, as described in
Recommendation 3.14. In particular, a comprehensive progress report should be
prepared, which compares actual progress with expected emissions and air quality
trends for each metric (see Recommendation 1.5). Further discussion is needed to
determine the appropriate frequency for this report.
2) If actual progress differs "substantially" from the expected trend for a given metric,
then States should reexamine effectiveness of that attainment measure. If attainment
will be later than the statutory attainment date, then the State should determine
whether it is necessary to modify the SIP. Note, this determination should consider
the influence of weather conditions (e.g., very hot/cold, or very wet/dry conditions).
3) EPA should report annually on health and ecosystem impacts (i.e., indicators and
benchmarks established pursuant to Recommendation l.S). Also, EPA should report
annually on major control programs that they are coordinating (e.g., Title IV and NOx
SIP Call).
Benefits: On-going progress assessments will ensure that the correct and most cost effective
control strategies are in use. Joint State-EPA efforts should allow more effective use of available
resources and eliminate any redundancy in current efforts. Such comprehensive analyses can
also highlight limitations in existing data systems which would facilitate appropriate data quality
improvements (emissions, modeling, and monitoring).
Feasibility: This activity is a logical extension of EPA's annual Trends Report, and State RFP
and air quality assessments. Additional EPA and State staffing may be needed to ensure proper
interagency coordination. Refinements to existing tools will be needed (such as improved
adjustments for meteorology) some of which are already in development by EPA.
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Timing: Initial products could be expected within 1-2 years. A fully integrated State-EPA
analysis and report system may take several years.
Resources: EPA should bear the primary responsibility. Approximately 2-3 new FTE's and
S300K per year may be needed.
Priority Level: High
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3.16 Evaluation of Averaging. Banking and Trading in Gasoline Sulfur Program. EPA
should evaluate the averaging, banking, and trading (AST) provisions included in the Tier II
gasoline sulfur regulation to see if they are effective.
Background: Averaging, banking, and trading (ABT) provisions have been widely used in EPA
regulatory programs to provide flexibility to industry while aggressively attacking environmental
problems. The effectiveness of these provisions for fuels programs should be evaluated, since
ABT concepts are being built into new regulatory programs.
Recommended Actions: EPA should evaluate the ABT provisions in the gasoline sulfur
program as the program rolls out over the next few years. The evaluation should be phased to
include annual analysis of available information and a complete report when the program has
been fully implemented and patterns of credit usage are well-established. Below is a list of
topics that would be covered by the evaluation:
• Credit accumulation: Did the credit generation opportunity result in substantially lower
sulfur levels in '02 and '03? What volume of credits were generated and how much
flexibility did this make possible to refineries? How was credit generation distributed across
the industry?
• Allotment accumulation: Did facilities and companies take advantage of the allotment
generation opportunity in '03 thru '05? What volume of allotments was created, and how
much flexibility is thus available to refining companies?
• Trading and markets: (Separately for credits and allotments) How much trading took place
relative to the total volume of credits/allotments? How efficiently did the credit/allotment
markets function? Were credits and allotments readily available for purchase by challenged
facilities and companies? How much trading of credits was inter-company (as opposed to
trading between facilities within the same company)? How did the price of
credits/allotments vary over the course of the program? How was the trading system
perceived by refiners?
• Role of allotments in compliance with Corporate Average Standard (CAS): To what extent
did active trading of allotments contribute to companies' ability to comply (use of purchased
versus self-generated allotments)? How did CAS compliance strategies vary across the
industry (uniform reductions across facilities versus planned unevenness in facility
reductions)? How many allotments were retired?
• Role of credits in compliance with Refinery Annual Average Standard (RAAS): To what
extent did facilities use credits to come into compliance with the RAAS? What proportion of
the credits used in compliance were purchased rather than self-generated? How many credits
were retired?
• Reporting system's accuracy: Does accuracy of reporting indicate industry understanding of
ABT program? Do most reports of credit/allotment trades match up without EPA
intervention or troubleshooting? Do refiners perceive the ABT system as logical and
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workable in practice?
EPA should consider conducting a similar analysis for ABT when it implements the diesel sulfur
program.
Feasibility: This recommendation is generally very feasible. Existing EPA staff can perform
these analyses and write the final report. Possible obstacles include difficulties in enlisting
cooperation from industry sources, and the need to work around confidentiality concerns with
both reporting data and information obtained from confidential conversations.
Timing: Some aspects of the evaluation can be addressed in annual analyses beginning in mid-
to-late 2005. The more complete report on this effort cannot be developed until late 2007 at the
earliest, the first time data on a fully-implemented program will be available.
Resources: This evaluation will require less than one FTE for each report. Some contractor
time will be required to program certain analyses.
Priority Level: Low
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4.1 SIPs to Address Multipollutant Impacts; For the SIPs States are required to submit over
the next several years, EPA and States, locals, and Tribes should promote the consideration of
multipoUutant impacts, including the impacts of air toxics, and where there is discretion,
select regulatory approaches that maximize benefits from controlling key air toxics, as well as
ozone, PM2.5 and regional haze,
Background; The SIP process provides an opportunity for many urban areas to include key
HAPs in a comprehensive multipoUutant approach to air quality management, consistent with the
NAS recommendations. The NRC recommends (on p. 298 of Air Quality Management in the
United States) That:
EPA, States and local agencies should identify key HAPs that have diverse sources or
substantial public health impacts or both, which would merit their inclusion in an
integrated multipoUutant control strategy (for example, benzene).
Activities have been taken at the State/Local/Tribal and federal level to reduce emissions from
key HAPs. It is important to clarify that this NRC recommendation should not be interpreted as
deferring federal responsibilities (e.g., mobile source air toxics program, 112(k) area source
program, etc) to State and local agencies. Rather, this recommendation means that the air quality
management process being undertaken for SIPs/TTPs provides an opportunity to see how
State/Local/Tribal and federal efforts are working to reduce key HAPs, to identify what actions
could be taken at the State and local level to supplement current efforts, and to help identify
priorities for federal actions.
Recommended Actions: EPA, in consultation with states and stakeholders, should develop a
"short list" of critical HAPs that pose the highest risk to human health in urban areas. Likely
compounds for consideration on the short list would include:
• benzene and acrolein: these are national risk drivers in EP A's 1999 national air
toxics assessment (NATA).
• diesel PM: although not a "HAP" listed specifically in the Clean Air Act, the
workgroup recommends it for consideration on the short list.
The following additional steps should be taken to finalize the short list:
(1) EPA and States/Locals/Tribes should identify additional HAPs which are likely due to
ubiquitous sources for inclusion into the list of "key HAP". For example, the following
were identified in the 1999 NATA as contributing to more than 90% of the cancer risks in
531 proposed or final nonattainment counties:
Ethylene dibromide
Butadiene
Acetaldehyde
Bis 2 ethylhexyl pthalate (DEHP)
1,1,2,2, tetrachloroethane
Chromium VI
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• PAHs
• Napthalene
• Tetrachlorethylene
• Ethylene dichloride
(2) EPA and States/Locals/Tribes should review HAP monitoring results to identify any
high-risk pollutants which may be underpredicted by the NATA.
(3) States/Locals/Tribes should include on the list any additional HAPs which are high risk
in their area.
For the "short list," EPA should encourage States and Tribes, in developing their SIPs/TIPs for
PM2.S, regional haze and ozone, to evaluate opportunities for achieving co-benefits through
simultaneous reduction of these key "urban risk driver" HAPs.
EPA, working with one State and a short list of HAPs, should develop and test a model
integrated SIP as a pilot project before expanding to other States/Tribes. Possibly good
candidates for such a pilot, areas which are both ozone and PM nonattainment, and which are
part of the national air toxics trends sites (NATTS) network include: Detroit, St. Louis, Atlanta,
and Chicago.
Feasibility: Including a short list of HAPs in modeling and control strategy analyses for
SIPs/TIPs should not add substantially to the resource burden. Results for the HAP "short list"
could readily be derived from existing ozone or PM modeling. Control strategy analysis would
be somewhat more complex, but would benefit from a more thorough evaluation of multi-
pollutant interactions.
Timing: In order to extend this approach to the additional areas that will be submitting PM and
/or ozone SIPs, the pilot effort would need to be complete by the end of calendar year 2005.
Resources: For EPA, this effort could be completed with redirection of existing personnel
without a substantial additional financial commitment. For States, this might add perhaps 10-
20% to the cost of the SIP analytical effort.
Priority Level: High
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4.2 Multipollutant Benefits and Disbenefits in Standards Setting; EPA should explicitly
outline and quantify multipollutant benefits and disbeneflts when setting emissions standards.
Background: The current statutory, regulatory, and policy framework does not explicitly
provide an integrated approach for the consideration of criteria and air toxics. An opportunity
exists in the ongoing air toxic standards-setting processes (e.g., remaining MACT standards,
residual risk, and area source standards) to explicitly consider multi-pollutant effects of proposed
control strategies in selecting options.
Recommended Actions:
• EPA, in conducting engineering reviews to support emissions standards efforts, should
assess how identified options for Hazardous Air Pollutants (otherwise known as HAPs or
air toxics) reduce and/or increase direct PM^s emissions, and emissions of PM and ozone
precursors such as VOC, NOX and
• Engineering reviews for HAP standards should catalog available control options that
would reduce direct PM, SO2, VOC and NOX emissions even if those options would not
reduce air toxics.
Feasibility: The recommendation to quantify the benefits and disbeneflts has a high feasibility
for implementation, although the degree to which they can be considered is not clear under
existing statutory authority. Section 112 (d)(2) of the Clean Air Act explicitly states that
emission standards for HAP should consider non-air quality health and environmental impacts,
but it doesn't appear to preclude consideration of other air quality impacts. Regardless of a
change in statutory requirements, quantifying criteria pollutant benefits will result in better
decision-making and will boost overall acceptance of future MACT requirements.
Timing: It is anticipated that this recommendation to quantify the multi-pollutant benefits and
disbeneflts can be implemented immediately in ongoing development of remaining MACT
standards, MACT residual risk 112(d)(6) standards, and 112 (k) area source standards.
Resources: This effort will require some additional analyses in the MACT development
process, but we would not expect substantial additional financial commitments.
Priority Level: High
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5.1 Program Review to Improve Ecosystem Protection. EPA should, in parallel with
recommended scientific and technical work, begin now to examine current and alternative
clean air related policy and programs to develop approaches that would advance protection of
ecosystems from the adverse effects of air pollution. Alternatives that should be evaluated
include a regional cap-and-trade program, protection of ecosystems based on critical loads,
and a State-wide planning program for protecting and enhancing air quality in areas that
attain the NAAQS (including National Parks and Wilderness Areas).
Background/Explanation: The NRC stated that the system of air quality management in the
United States does not go far enough in protecting ecosystems and other aspects of public
welfare from the impacts of air pollution. The NRC noted specific policy-related deficiencies in
secondary standards, tracking of ecosystem outcomes from air quality changes, and accounting
for ecosystem effects in cost-benefit analyses.
Recommended Actions: To advance and support future policy decisions, it is important to
implement the recommendations of the science and technology subgroup regarding developing
innovative benchmarks and measures to assess ecological impacts of air pollution and improving
ways to track and evaluate progress in reducing those impacts. The examination of potential
policy alternatives does not, however, need to be delayed while these advances are being
developed. We have substantial information on direct and indirect effects of some air pollutants
on the environment amassed in criteria documents, and assessments such as that of the National
Acid Precipitation Assessment program. This information can assist in framing policy questions
and approaches in an exploration of how current and future information might be used to
increase environmental protection. This effort should be interactive with those groups who are
working on the scientific and technical recommendations.
Specifically, EPA should, in conjunction with other interested parties, begin with an assessment
of the relative effectiveness of major clean air programs under the CAA in terms of their
potential to provide additional ecosystem protection.
Recognizing that regulatory programs are in different stages of implementation and offer
different options, EPA should consider the following in the review of each program:
a) policy mandates, objectives, goals, definitions of ecosystem protection, historic/legal
interpretation
b) characteristics of air pollutant(s) regulated (e.g., toxics, criteria, mobile), may have
different potential magnitudes of impact (e.g., different temporal/spatial scales)
c) existing reporting measures of program/ecosystem protection progress (e.g., trends
report, acid deposition goals under GPRA and PART, NAPAP Report to Congress,
EPA's Report on the Environment, water quality measures, inclusion in regulatory
impact analyses etc.)
d) whether existing tracking efforts need modifications to specifically support their use
in different regulatory programs (i.e., networks needed to support secondary
standards vs. other CAA mechanisms, national vs. critical ecosystem coverage, etc.)
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e) current and future opportunities or impediments to expand use of ecological science
in the policy context, given additional ecological research, indicator/ model/monitor
development, consistent longer-term measurements/monitoring.
0 what policy innovations/revisions would be required to better translate ecosystem
science into effective ecosystem protection policies.
The policy assessment of air pollution and ecosystem protection should also consider non-
regulatory programs, including ongoing innovative approaches that examine multi-media
approaches to integrating air pollution effects with other ecological concerns, as is done in the
Sustainable Environment for Quality of Life (SEQL) project in Charlotte.
Benefits: This recommendation will accelerate consideration of ecosystem protection in clean
air programs as well as ensuring faster application of recommended enhancements to EPA's
scientific and technical assessment capabilities as they are developed
Feasibility: This recommendation is highly feasible and the work can be completed under
current Clean Air Act authority. The exercise could, however, identify impediments or desirable
policy approaches that are not currently available.
Timing: The recommended policy assessment of current programs could begin immediately.
The potential for developing new policy approaches would depend on the results of the activity.
If the scientific and technical recommendations are adopted, improved tracking could begin in
the near future. Longer-term consideration would be needed to determine whether current
and/or additional technical information/tools under development could be applied more formally
under the Clean Air Act.
Resources: Additional staff resources in the Office of Air and Radiation would be needed.
Priority Level: High
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Appendix C
Summary of Deferred Issues
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Issues and Potential Recommendations for Future Discussions
Listed below, with brief descriptions, are several recommendations that the AQM Work Group
considered but decided against advancing in final form at this time. There were various reasons
why these recommendations were deferred for future discussion: some recommendations were
added to the discussions late in the Work Group's process; others are so complex that they
require additional data and evaluation before they can be finalized; others are controversial and
require further discussion among stakeholders. This list does not include every issue considered
by the Work Group, but contains the issues that were considered most important to advance for
further discussion.
1) Emissions Inventories; EPA should improve the process for developing national, State,
and local emissions inventories.
Currently, states are required to prepare a comprehensive statewide inventory every three
years, pursuant to EPA's Consolidated Emissions Reporting Rule (CERR). EPA prepares
its National Emissions Inventory (NEI) using these state inventories and other information.
The timeliness and quality of these state and national inventories should be improved. For
example, EPA should consult with states to determine which source categories can be
inventoried more frequently (ideally, annually), such as EGUs, and EPA should work with a
few states on a pilot project to develop more efficient ways to prepare the NEI (e.g.,
examination of top-down (national-level) and bottom-up (state-level) approaches, and
streamline the reporting of state data and EPA's processing and compilation of these data).
2) Monitoring Networks; EPA and States should work together to increase the number of
air quality monitoring stations and improve their distribution.
To improve spatial coverage and comprehensiveness in existing state and federal monitoring
networks, additional monitoring sites and additional measurements are desired. The first
step in making improvements is to conduct spatial analyses of existing monitoring networks
and identify "gaps" in coverage. Based on results of the spatial analyses, EPA Regional
Offices and States should work together to establish appropriate monitoring sites. Possible
enhancements include increased sampling in rural areas (to promote ecosystem goals) and
reallocation of PAMS monitoring to ensure a Type II site in as many 8-hour ozone
nonattainment areas as possible (to promote tracking progress). To ensure that monitoring
networks are providing usable data, states should conduct a thorough assessment of their
monitoring networks every five years.
3) Short-Term Monitoring; States should consider conducting short-term monitoring
programs.
To complement on-going monitoring efforts (especially, to address particular air quality
problems and issues), special (short-term) field programs should be considered. Examples
of such field programs include summertime ozone field programs (e.g., SCAQS, LMOS, and
NARSTO-Northeast) and investigative studies (e.g., MRPO's urban organics study).
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4) Evaluation of Models; EPA should support the evaluation of air quality models.
To develop confidence in using models for regulatory purposes, it is important first to
evaluate the models by comparing model estimates and ambient measurements. EPA should
publish a report every three years on the state-of-the-science for ozone, fine particle, and
haze modeling. The report should include any current model-evaluation studies, and
assessments of special issues (e.g., model predictive capability of changes in air quality
concentrations due to changes in emissions, predictive capability of models at very low
concentrations, effect of model grid resolution on predicted concentrations, and suitability of
using point measurements for comparison with modeled concentrations). On a larger scale,
a measurement plan should be prepared for a regional (or sub-regional) field program in the
eastern half of the U.S. to support ozone, fine particle, and haze models. Note, resources for
a meaningful field study may approach a million dollars. Further discussion is needed to
address the scope, cost, and funding options for such a major study.
5) Evaluation of Control Measures; EPA should conduct retrospective evaluations of
control measures.
The NRC recommendations note that programs to systematically collect information on
what has worked (and how well or not so well) have been inconsistently funded and have
been limited in ability to independently validate user's estimates of compliance costs. Even
though NRC's emphasis above is only on costs (evaluated retrospectively), it seems equally
important to evaluate technical experience/feasibility with various technologies. As such, it
is recommended that EPA undertake written case studies in consultation with the affected
industries of cost and technology experience of representative stationary source and mobile
source categories (e.g., EGU NOX and SOX control, non-EGU NOX controls, motor vehicles
fuels and emission standards, and mobile source retrofit programs).
6) Communication of Technical Information to Policymakers; The scientific community,
both within EPA and outside the agency, should work to improve the communication of
technical information to policymakers.
Technical analysts often generate complex, highly scientific information to address air
quality problems. Communicating this information to policymakers and others who may not
have the same technical background is a challenge. As such, it is necessary for technical
analysts to be clear, objective, and relevant in presenting this information to policymakers,
and for policymakers to be willing to receptive to technical information.
7) Multipollutant Modeling; EPA should promote the use ofmultipollutant models.
EPA and states should use air quality models capable of addressing ozone, fine particles,
regional haze, and air toxics (e.g., mercury) in the upcoming round of SIP development.
Viable candidate multi-pollutant models include CMAQ (developed by EPA's Office of
Research and Development (ORD)), CAMx, and REMSAD. Although no endorsement of
these models is offered, it should be noted that CMAQ and CAMx appear to reflect the most
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up-to-date science. As these models advance, the transition from research to application
needs to be improved. For example, EPA's ORD and Office of Air Quality Planning and
Standards should make sure that CMAQ is usable (in-house) by RPOs/states for SIP
modeling.
8) Integration of Programs for Criteria Pollutants and Air Toxics; EPA should
investigate technical considerations associated with the potential integration of programs
to control criteria pollutants and air toxics.
The NRC, recognizing the long standing difference in the way criteria pollutants and toxic
air pollutants are regulated under the Clean Air Act, while also recognizing that in the air
they mix to form one atmosphere, recommended an evolution toward a common risk based
approach to regulating emissions of air pollutants and providing clean air. Setting aside the
policy and program issues, there are fundamental science hurdles that must be overcome to
weigh the options and alternative approaches in moving toward such a "one-atmosphere"
approach to providing clean air (e.g., dealing with large differences in the amount and
quality of data on emissions, ambient levels, personal exposures and environmental
deposition, health and ecosystem effects, thresholds, and risk factors for these many
chemicals). What is needed initially is a first order relative risk assessment and gap analysis
based on currently available information using existing practices. Ultimately gaps would be
filled and protocols.
9) Integrated Criteria/Toxics Controls at Individual Sources: Consistent with the goal of
controlling more air pollutants in a holistic fashion, States/Locals/Tribes should be
encouraged to address emissions from criteria pollutants and air toxics concurrently
during permuting or regulatory actions at individual sources.
The group believed that this recommendation had possible merit. However, the
recommendation was drafted late in the process and the group did not have adequate time to
consider it in detail.
10) Greenhouse Gas Co-benefits/Disbenefits; EPA should assist States to quantify the
potential greenhouse gas emissions increases and decreases for reduction measures
primarily designed to address ozone, PMi.5, regional haze, and air toxics.
The group could not achieve full consensus. Some members believed that accurate analysis
of greenhouse gas emissions co-benefits and disbenefits during the development of criteria
pollutant SIPs could assist States in making control measure decisions that might provide
economic multipollutant benefits. Others felt that the issue of greenhouse gases was not
central to the core focus of the air quality management system or the NRC report
(addressing criteria pollutants, air toxics and regional haze), and were not comfortable with
allocating resources to address them.
11) SIP Consistency Process; EPA should better document its internal processes to ensure
transparency in evaluating State/Tribal/Local or regional requests for a variance from
published policies.
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The Group believed that this was an important recommendation. However, there was a
general lack of understanding outside of EPA as to how EPA's internal process works to
ensure consistency in decisions across the different Regions. EPA agreed that such policies
need to be better documented and explained. However, there was insufficient time to do so,
so the recommendation was deferred for further discussion.
12) Electric Generating Units;
The electricity generating unit (ECU) sector makes a large contribution to multiple air
quality problems. Many believed that the active rulemaking underway on the Clear Air
Interstate Rule (CAIR) provided the proper forum for considering what this sector ought to
do for the next IS years or more; others did not. Since no agreement could be reached on a
recommendation regarding this sector, the Work Group recommends that discussions
continue by the new CAAAC subcommittee. Regardless of the outcome of any future
discussions, many of the stakeholders involved saw considerable value in State and Local
agencies and utilities consulting with each other after final promulgation of the CAIR (or
new legislation) to share compliance plans, evaluate likely emissions reductions and their
geographic distribution, and apply that information to further planning activities.
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Table B-1
Air Quality Management Work Group
Summary Recommendations Matrix
12/16/04
.VBC 1: Slivngthtfl sdenHHr and techjricai capacity
Number Recommendation Priority
. ,, Emissions Measurements and Reporting- To enhance emissions data bases for more accurate air quality assessments and tracking of progress, EPA, in
conjunction with S/L/Ts and affected stakeholders, should improve emissions measurements and reporting.
Emissions Factors and Estimation Methods - Where emissions measurement-based information is impractical to obtain for air quality assessments, or where
1.2 improved projections are needed, EPA, in conjunction with S/L/Ts and affected stakeholders, should improve emissions factors and emission estimation High
methods.
Uncertainty in Emissions Inventories and Modeling - To improve the usefulness and acceptance of technical information for planning and decision making,
. _ EPA, in conjunction with S/L/Ts and affected stakeholders, should quantify and take actions to reduce uncertainty in emissions inventories and air quality „
modeling applications, provide guidance for incorporating uncertainty assessments into SIP planning, and improve communication of uncertainty to decision-
makers.
Multlpollutant Monitoring - In order to provide more scientifically relevant and responsive air quality information, and to provide a more robust and spatially
1.4 complete basis for current and future air quality planning, EPA, in conjunction with S/L/Ts and affected stakeholders, should promote and improve integrated, High
multipollutant monitoring.
Framework for Accountability - To promote understanding and characterization of the impacts of air quality changes on health and ecological outcomes, and
to improve the scientific basis for more informed policy decisions, including the need for and nature of air quality standards, EPA, in conjunction with health
and ecosystem science experts, S/L/Ts, and affected stakeholders, should undertake a systematic effort to track air quality achievements and evaluate air
. g. program results. This effort should begin by focusing on the progression and associations of air emissions as they interact and ultimately affect health and the MI«II
environment In order to move beyond the current approach of relying predominantly on air quality measurements, we need to further develop and apply the
capacity to monitor, assess, and report on how changes in emissions impact air quality, atmospheric deposition, exposure, and effects on human health and
ecosystems. Emphasis should be placed on developing and enhancing appropriate health and ecosystem indicators, benchmarks, and subsequent analyses within
this overarching accountability framework
Pagel of 6
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Table B-1
Air Quality Management Work Group
Summary Recommendations Matrix
12/16/04
NRC i: KTpand national anil mnKlstatf tontrol sirategifs
Number Recommendation Priority
Industrial, Commercial, and Institutional Boilers - Nationwide, emissions of criteria and hazardous air pollutants from industrial, commercial, and
2,1 institutional boilers are substantial. The Work Group recommends that EPA complete as soon as possible a review of the contributions from this category and High
the technical and economic feasibility of further controls, given the high priority assigned to this sector. EPA should then initiate development as quickly as is
practicable of a regional or national emission control regulation for this category or take alternative action consistent with the results of its analysis.
Industrial Surface Coatings - Nationwide, emissions of criteria and hazardous air pollutants from industrial surface coating operations are substantial. The
2 2 Work Group recommends that EPA complete as soon as possible a review of the contributions from this category and the technical and economic feasibility of ....
further controls, given the high priority assigned to this sector. EPA should then initiate development as quickly as is practicable of a regional or national
emission control regulation or control technique guidelines for this category or take alternative action consistent with the results of its analysis.
Non-Industrial Solvents - Nationwide, emissions of criteria and hazardous air pollutants from non-industrial solvents are substantial. The Work Group
2.3 recommends that EPA initiate a rulemaking to establish minimum performance standards, (Le., a national rule) for non-industrial solvents using the VOC Medium
content limitations contained in, and regulating the products covered by, the model rule developed by the Ozone Transport Commission.
Architectural Surface Coatings - Nationwide, emissions of criteria and hazardous air pollutants from usage of architectural coatings are substantial. The
2.4 Work Group recommends that EPA initiate a rulemaking to establish minimum performance standards, (i.e., a national rule) for architectural coatings using the Medium
VOC content limitations contained in, and regulating the products covered by, the model rule developed by the Ozone Transport Commissioa
9 e If krh
Heavy-Duty Diesel Engines - EPA should reduce emissions from the existing fleet of heavy-duty diesel engines by employing a multi-pronged approach.
9 fi Uitvfi
* Ships, Locomotives, Aircraft and Mobile Source Air Toxics - EPA should address these categories through national emission standards. ™
Pag«>"M6
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Table B-1
Air Quality Management Work Group
Summary Recommendations Matrix
12/16/04
Number Recommendation Priority
Cement Manufacturing, Petroleum Refining, and Pulp and Paper - The cement manufacturing, petroleum refining, and pulp and paper industrial source
categories are already under substantial regulation but continue to be significant sources of pollutants and warrant further consideration by EPA. EPA should
2,7 evaluate potential national or regional emissions reduction strategies for criteria pollutants and HAPs in these categories. This should include improving Medulm
emissions inventories if necessary and assessing their impacts on nonattainment areas or other sensitive areas. EPA should determine whether additional
emission reductions are justified and should take action consistent with the results of this analysis.
Residential Fossil Fuel Combustion - EPA should work with its Energy Star staff to evaluate the potential for expanding the Energy Star voluntary program tc
gain additional criteria pollutant emissions reductions (as well as improve energy efficiency) from the residential fossil fuel sector, and also evaluate the
potential to reduce emissions through the expanded use of low-sulfur fuels. As part of this effort, EPA should continue to gather information on the
2.8 characteristics of residential fossil fuel emissions and their contributions to non-attainment, and the magnitude and cost of potential emissions reductions under Medium
voluntary program and/or expanded use of low-sulfur fuel. EPA should also discuss with RPOs (especially in the northeast and Great Lakes areas) to evaluate
the possibility of voluntary programs at the regional level, and discuss with companies that currently produce and/or market high-efficiency appliances that
reduce emissions, to assess the potential for programs that promote the installation of such technologies.
Guidance for Local Control Measures In Key Sectors - EPA, in conjunction with S/L/Ts and affected stakeholders, should prepare guidance for local (urban
2.9 scale) control measures to support the upcoming round of ozone and PM2.S SIPs, and, if possible, optimize multi-pollutant control benefits and opportunities High
for criteria and hazardous air pollutants.
Wood Stoves - EPA should further develop an initiative that includes working with states, locals, tribes, industry, and others to support and facilitate the chang
2.10 out of dirty, inefficient "conventional" (pre-NSPS) woodstoves with new, cleaner and more efficient heating appliances (e.g., EPA certified woodstoves and ga High
appliances). While it would begin as a pilot in several local areas, if successful, it would grow into a national voluntary program that would be applied in much
of the US. Concurrently with the development and implementation of the voluntary initiative, EPA should commence efforts to revise the NSPS.
3 ^ * Open Burning - EPA should work with States, their respective local air pollution control agencies, and Tribes to encourage more vigorous control of open
burning, especially in, and adjacent to, counties with Class I areas and counties classified as nonattainment for fine particles or ozone.
Page 3 of6
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Table B-1
Air Quality Management Work Group
Summary Recommendations Matrix
12/16/04
Number Recommendation Priority
2 < 2 High-Emitting Gasoline Vehicles - EPA and State and local governments should reduce emissions from high-emitting gasoline vehicles that are believed to
contribute a high fraction of mobile source emissions.
2.13 Conformity-Conformity should be retained as part of the nation'sAQM system. Low
NUC 3: Transform thy Sil' proem
Align SIP Submittal Dates - Because PM2.S, Ozone and Regional Haze SIPs have similar elements and are likely to contain similar control strategies, EPA,
the States/Locals/Tribes and other stakeholders should strive to align the submittal dates of these three SIPs. This recommendation is not intended to suggest
3.1 change to any deadlines for implementation of control strategies or for attainment Nor is intended to imply that a single SIP should be required for PM2.5, High
Ozone and Regional Haze. It is further recommended that, in the future, EPA should align designation dates, as appropriate, to promote multipollutant SIP
development
Protocol for SIP Development - Each State should work with the appropriate EPA Regional Office to develop and implement a protocol for SIP development
3.2 and processing that would lay out responsibilities, expectations, and time lines for all parties. While a model protocol may be developed, the EPA Regional High
Office and each state should have the flexibility to design a protocol tailored to their specific needs.
Streamline Minor SIP Revisions - For the SIP approval/disapproval phase of the air quality management process, EPA should establish ade minima level for
_ * SIP revisions and streamline the processing of these revisions by the use of "letter approvals" or similar expedited procedures signed by the Regional
Administrator. EPA should, in consultation with States/Locals/Tribes and other stakeholders, develop a listing of the types of SIP actions that are eligible for
streamlined processing.
Timely EPA Guidance - EPA guidance should be issued in sufficient time for States to meet their SIP development deadlines. EPA should involve
3.5 States/Locals/Tribes and other appropriate parties in its guidance development process. In cases where guidance is delayed, EPA will take into consideration High
States' efforts to meet deadlines without the benefit of the appropriate policy guidance.
Avoid Unnecessary Public Hearings - EPA should work with States and Tribes to develop a model regulation that would require a public hearing for SIP
3.6 revisions only if one is requested after public notice. This recommendation is not to restrict public comment in any way, just to eliminate those hearings to High
which no one attends.
Pap* - of 6
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Table B-1
Air Quality Management Work Group
Summary Recommendations Matrix
12/16/04
Number Recommendation Priority
Facilitate Redesignation Process for Certain Areas - For those areas that have not pursued and been granted redesignation when initially eligible, and have
». _ continued to demonstrate violation-free ambient air quality data for several years beyond, EPA should expedite the redesignation process. EPA shall ensure thi
all Regions and States are aware of the simplified procedures. This recommendation is not intended to change the requirements for redesignation under the
Clean Air Act
_ _ Effective Communications with Constituencies - EPA, states, local agencies and tribes should develop a menu of options for effective communication to
build support with a wide variety of constituencies for clean air plans at the local and state level. ™
3*9 Co-Benefits of Innovative Measures - EPA and States should work collectively to communicate the co-benefits associated with innovative SIP measures. High
, , _ Innovative and Voluntary Measures - EPA should encourage States' efforts to implement innovative measures by providing enhanced flexibility, SIP credit
guidance, technical support, and funding for innovative and voluntary programs.
_ ,,., SIP Credits for Bundled Innovative Measures - EPA should incentivize innovative pollution control strategies by offering SIP credit for "bundled and
a.il ,. ... Hum
discounted measures.
Regional Approaches to SIP Planning - For many areas, planning for new SIPs or major revisions to existing SIPs for two or more separate nonattainment
areas that are both part of the same regional scale air quality problem should be coordinated. If requested by a S tate, EPA should work with the different
3.12 nonattainment areas, Tribes and combinations of multi-state organizations and other stakeholders, as appropriate, to assist in the development of regional High
approaches to planning. This could include technical assistance such as modeling, national or regional control strategies, model SIPs, and model rules as
templates for State/ Local/Tribal adoption.
Federal and State Partnership - As part of the SIP development process, EPA, in consultation with States/Locals/Tribes, should identify and pursue
emissions reductions from federal and international sources, especially those which only the federal government has the ability to control. The level of control
3.13 sought from these sources should be commensurate with their impact in the nonattainment area. As warranted by the nature of the source, control strategy High
development should be carried out by State and local agencies and Tribes working either directly with EPA or with EPA and other federal agencies. For
attainment demonstration purposes, States should be able to take appropriate credit for anticipated reductions from these sources (whether the reductions are
from regulatory or incentive programs) so long as the control strategy and its anticipated impact are found to be consistent with EPA regulation and guidance.
Page 5 of6
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Table B-1
Air Quality Management Work Group
Summary Recommendations Matrix
12/16/04
Number Recommendation Priority
Welght-of-Evidence Demonstrations - In order to move beyond the current approach of relying on air quality modeling, EPA, in conjunction with S/L/Ts and
3-44 affected stakeholders, should modify its guidance to promote weight-of-evidence (WOE) demonstrations for both planning and implementation efforts. In „. .
particular, these demonstrations should reduce reliance on modeling data as the centerpiece for SIP planning, and should increase use of monitoring data (and
analyses of monitoring data) especially for tracking progress.
3 -t & Periodic Assessments to Track Progress - S/L/Ts and EPA should conduct periodic assessments to ensure that areas are on track to meet NAAQS, HAP, and
visibility goals, and make mid-course adjustments, as necessary.
_ . _ Averaging, Banking and Trading in Gasoline Sulfur Program - EPA should evaluate the averaging, banking, and trading (ABT) provisions included in the
Tier II gasoline sulfur regulation to see if they are effective.
NRC -4; BrvfUip an intiigratfd program for criteria polfaiatUfi and HAP*
- j SIPS to Address Multipollutant Impacts - For the SIPs States are required to submit over the next several years, EPA and States/Locals/Tribes should UL.I,
consider multipollutant impacts, including air toxics, and where there is discretion, select regulatory approaches that maximize benefits.
. 2 Multipollutant Benefits and DUbeneflts in Standards Setting - EPA should explicitly outline and quantify multipollutant benefits and disbenefits in setting
emissions standards.
N'RC' S: Knhant-f protection of ecosystems and public nvlfare
Program Review to Improve Ecosystem Protection - EPA should, in parallel with recommended scientific and technical work, begin now to examine current
and alternative clean-air-related policy and programs to develop approaches that would advance protection of ecosystei
Alternatives may include a regional cap-and-trade program, protection of ecosystems based on critical loads, astatewic
enhancing air quality in areas that attain the NAAQS (including National Parks and Wilderness Areas), among others.
„ - and alternative clean-air-related policy and programs to develop approaches that would advance protection of ecosystems from the effects of air pollutioa UL.I,
Alternatives may include a regional cap-and-trade program, protection of ecosystems based on critical loads, a statewide planning program for protecting and
Pap* "if 6
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