Air Quality Management in the United States (2004) / Chapter Skim
Currently Skimming:
3 Designing and Implementing Control Strategies Through the SIP Process
3 Designing and Implementing Control Strategies Through the SIP Process
Pages 88-132
The Chapter Skim interface presents what we've algorithmically identified as the most significant single chunk of text within every page in the chapter.
Select key terms on the right to highlight them within pages of the chapter.
From page 88... ...
It provides the basic link between state regulations, EPA oversight of state actions, and federal enforcement. In addition to addressing criteria pollutants, SIPs are used by EPA to formally establish state and local agency obligations to meet emission standards and goals related to regional haze, acid rain, and hazardous air pollutants (HAPs)
|
From page 89... ...
. The 1990 CAA Amendments authorized EPA to "treat tribes as states" for purposes of developing, administering, and enforcing air quality regulations within reservation boundaries, irrespective of land ownership (42 USC § 7601(d)
|
From page 90... ...
States have no environmental regulatory jurisdiction on tribal lands. EPA administers a Title V operating permits program for major stationary sources on tribal lands along with a prevention of significant deterioration (PSD)
|
From page 91... ...
a national primary or secondary ambient air quality standard for the pollutant. 2EPA is authorized to direct a state to revise its SIP if the agency finds that the SIP is substantially inadequate to attain the NAAQS.
|
From page 92... ...
Because the major efforts in air quality management (AQM) for criteria TABLE 3-1 Classification of Nonattainment Areas for O3 and CO Mandated in the CAA Amendments of 1990 Attainment Date for Area Classification Design Value, ppm Primary Standarda O3 Nonattainment Areas Marginal 0.1210.138b Nov.
|
From page 93... ...
An area's attainment or nonattainment status with regard to a criteria pollutant is determined by comparing the NAAQS with the area's "design value"a for the pollutant. The design value is derived from air quality monitoring data gathered by local or state authorities following guidelines specified by EPA.
|
From page 94... ...
In addition to the items listed in part A, the SIP must · Provide a plan for the implementation of reasonably available control tech nologies (RACT) and attainment of primary NAAQS, for the offsetting of emissions of new or modified major stationary sources, and for the installation in major new stationary sources of technology capable of achieving the lowest achievable emis sion rate (LAER)
|
From page 95... ...
· Demonstrate that reasonable progress is being made through appropriate 3% per year reductions in VOC emissions (or its O3-equivalent in NOx emissions) and submit triannual compliance demonstrations beginning in 1996 showing emis sion reductions are being met.
|
From page 96... ...
THE MAIN COMPONENTS OF AN ATTAINMENT-DEMONSTRATION SIP The key elements of an attainment-demonstration SIP are the following: · An emissions inventory. · An analysis involving air quality model simulations as well as observational data and related evidence to determine the amount and types of emission reductions needed to bring about compliance by the appropriate date.
|
From page 97... ...
As a result of the requirements in the Acid Rain Title of the 1990 CAA Amendments, increasing numbers of electrical utility boilers are now using CEM systems. The data from them are posted quarterly on the internet, providing hourly emissions as well as values averaged quarterly and annually (EPA 2003g)
|
From page 98... ...
Depending on the source, various types of activity levels can be chosen -- for example, the total amount of fuel used by the source, the amount of product produced or consumed, the population density, or the vehicle miles traveled. In some cases, an emission factor is derived for an uncontrolled source.
|
From page 99... ...
. A major contributor to the large uncertainties in current emission inventories arises from the use of emission models to derive the inventories (that is, estimating the emissions from a source as the product of an emissions factor and an activity level)
|
From page 100... ...
The first step involves the enhanced use of ambient air measurements in conjunction with diagnostic tests, such as source apportionment, to evaluate emission inventories independently (see Figure 3-1)
|
From page 101... ...
EPA has indicated that documents prepared by EIIP should be used instead of existing federal guidance when appropriate. Mobile-Source Emission Inventories The emission inventories for mobile sources are particularly noteworthy.
|
From page 102... ...
The NONROAD program is used for the computation of emissions from other mobile sources. As in all emission inventories, the accuracy of the estimated on-road and off-road emissions depends on two components: the emission factors and the activity levels.
|
From page 103... ...
. The projections and the attainment demonstration based on simulations of the extreme events that contributed to the design value introduce uncertainty into the process beyond that arising from intrinsic uncertainties in the emission inventories and models.
|
From page 104... ...
In other words, if Po is the current concentration of a pollutant in an airshed, Eo is the current rate of emission, and El is the hypothetical emission rate after the introduction of emission controls, the new pollutant concentration, Pl, predicted by a rollback model would be Pl = Pbackground + Po (El /Eo)
|
From page 105... ...
in time and space to determine the relationships between pollutant emissions and pollutant concentrations. Because these models require the input of pollutant emission rates, they are sometimes referred to as emissions-based models.
|
From page 106... ...
Control of ground-level O3 pollution in an urban area can be achieved in principle by reducing the emissions of VOCs or NOx locally or in areas upwind of emission sources. However, the formation and transport of O3 in the atmosphere is a complex chemical and physical process, and determining the most effective combination of VOC- and NOx-emission controls to mitigate O3 pollution has proved to be a challenging task (see Box 3-4)
|
From page 107... ...
Results using more sophisticated models, such as the UAM (urban airshed model) , based on essentially the same emission inventories, generally (continued on next page)
|
From page 108... ...
the 1990 CAA Amendments allowed states some latitude in substituting NOx reductions for VOC reductions in some cases; and (3) the 1990 CAA Amend ments required RACT and NSR controls for stationary-source NOx emissions.
|
From page 109... ...
DESIGNING AND IMPLEMENTING CONTROL STRATEGIES 109 FIGURE 3-2 Appendix J curve. Required hydrocarbon emissions control as a function of photochemical oxidant concentration.
|
From page 110... ...
provided important insights into the source-receptor relationships in the acid deposition problem in the United States and Canada. Although these models ultimately played a relatively minor role in the development of the Acid Rain Program enacted in the CAA Amendments of 1990,6 they represented a major step in the development of CTMs -- namely, the expansion of the algorithms used in urban-scale CTMs for O3 into a more comprehensive regional-scale model able to simulate processes related to the formation, transport, and deposition of PM as well as gaseous pollutants.
|
From page 111... ...
These tools, sometimes referred to as "observation-based methods," use ambient air quality measurements rather than emission inventories to determine the relative effectiveness of VOC and NOx emission reductions on O3 pollution mitigation. The advantage of these methods is that they are not affected by uncertainties in emission inventories.
|
From page 112... ...
On the one hand, the evolving needs of the regulatory community promoted and catalyzed the scientific and engineering communities to develop increasingly sophisticated air quality models; on the other hand, insights gained from advanced models have prompted members of the regulatory community to rethink their approaches to air quality management. What Is Not Working Well · As a general rule, models should be subjected to comprehensive performance evaluations using detailed data sets from the atmosphere before using them in regulatory applications (Roth 1999; Seigneur et al.
|
From page 113... ...
Despite these limitations, air quality models remain the only tools available for quantitatively simulating or estimating future outcomes. Although challenging to use, air quality models are essential to the current AQM system.
|
From page 114... ...
It implicitly acknowledges the limitations of air quality model simulations and allows planners to use information and insights from existing data and other analytical procedures to develop a more comprehensive and conceptual understanding of the relationship between pollutant emissions and the concentration of a criteria pollutant. In principle, such an understanding can make it possible for SIP developers to arrive at a more robust estimate of the emission reductions that will be needed to reach attainment.
|
From page 115... ...
Emission-Control Strategy Development in an Attainment-Demonstration SIP When the total amount of emission reductions required to reach attainment of the NAAQS has been determined though modeling and weight-ofevidence analysis, air quality planners must devise a strategy of emission controls and enforcement to bring about these reductions by the required date. In principle, these reductions can be derived from measures designed to change sociological and behavioral factors that influence pollutant emissions as well as from technological changes that directly affect emissions.
|
From page 116... ...
were met with such intense political resistance that EPA was expressly prohibited in the 1977 CAA amendments from imposing the more stringent measures on any area. The 1977 CAA Amendments did include, however, the requirement that transportation-control measures be enacted in certain nonat tainment areas.
|
From page 117... ...
. Although some of these areas have submitted SIP revisions more recently, the ones chosen were those with the most comprehensive discussion of emission reduction strategies since passage of the 1990 CAA Amendments and are thus most appropriate for our discussion here.
|
From page 118... ...
118 for 1999) in needed e 625 Pennsylvania)
|
From page 119... ...
119 for d a PA; DE nsylvania)
|
From page 120... ...
In response, Congress included provisions in the 1990 CAA Amendments for implementing multistate air pollution mitigation strategies through the creation of regional planning organizations (RPOs)
|
From page 121... ...
Phases II and III committed OTR states to further regional NOx emission reductions in 1999 and 2003 via an integrated interstate emissions-trading program.9 OTAG was established in 1995 by EPA and the 31 states east of the Mississippi River. The major impetus for establishing OTAG was the inability of O3 nonattainment areas in the eastern United States to submit complete SIPs by the 1994 deadline mandated in the 1990 CAA Amendments.
|
From page 122... ...
EPA's Regional Haze Rule Section 169(a) of the 1990 CAA Amendments required EPA to establish regulations to ensure reasonable progress in improving visibility in 156 national parks and wilderness areas (Class I areas)
|
From page 123... ...
Grand Canyon Visibility Transport Commission and the Western Regional Air Partnership Along with the OTC, the 1990 CAA Amendments also instructed EPA to form GCVTC to deal with fine-particle haze that impaired visual air quality in the Grand Canyon National Park (42 U.S.
|
From page 124... ...
. Institutional Accountability in the SIP Process The original 1970 CAA Amendments required SIPs to demonstrate that the primary NAAQS would be achieved in every area within a state by 1977 at the latest.
|
From page 125... ...
Nevertheless, one district court ordered EPA to make the required nonattainment finding in a timely fashion, and three courts of appeals found the downwind extension policy to be invalid.10 In addition to the bump-up provision, the 1990 CAA Amendments provide other more tangible penalties and sanctions for states that fail to submit a SIP or submit an inadequate SIP. These include the authority for EPA to write a FIP as well as to impose two types of sanctions: (1)
|
From page 126... ...
THE EFFECTIVENESS OF THE SIP PROCESS Two basic metrics can be used to assess the effectiveness of the SIP process. The less stringent metric is based on an assessment of whether implementation of SIPs has resulted in a general decrease in pollutant emissions and concentrations and, more specifically, in a decrease in criteria pollutant concentrations in nonattainment areas.
|
From page 127... ...
is an area that has designated an O3 nonattainment area as of the date of enactment of the CAA Amendments of 1990 and that has not violated the national primary ambient air quality standard for O3 for the 36-month period beginning January 1, 1987, and ending December 31, 1989. eThis category includes areas that violate the O3 standard and have a design value of less than 0.121 ppm.
|
From page 128... ...
It allows state and local agencies to take into account emission controls adopted at the federal and multistate levels and then choose a suitable suite of additional local emission-control measures to reach attainment. On balance, this process should provide an appropriate division of responsibility.
|
From page 129... ...
The rigidity of federally mandated requirements for SIPs containing areas that are clas sified as serious and above may represent a congressional recognition of the fail ure of more flexible SIP requirements to achieve attainment during the 20 years before the enactment of the 1990 CAA Amendments. Although federally mandated sector-specific measures reduce local flexibility, they should have the benefit of accelerating the EPA approval process, but in general, they have not done so.
|
From page 130... ...
Single-Pollutant Focus of SIPs Air pollutants occur in complex mixtures, and yet SIPs are constrained to address only individual criteria pollutants. As a result, the entire, relatively cumbersome SIP process must be undertaken for a pollutant such as O3 and then again for PM in a separate process and on a different timetable, despite the fact that the exposures are simultaneous, the sources are often the same, and the two pollutants share many common chemical precursors.
|
From page 131... ...
Of particular importance will be the need for mechanisms to induce states upwind of emission sources to take actions that have little direct benefits for them but that are needed for successful attainment of the NAAQS in states downwind of the sources. SUMMARY Strengths of the SIP Process · The SIP process provides a reasonable mechanism for state and local agencies to take into account emission controls adopted at the federal and multistate levels and then to choose a suitable suite of additional local emission-control measures to attain the NAAQS.
|
From page 132... ...
· The SIP process lacks sufficient mechanisms and governmental infrastructure for addressing multistate airshed aspects of air pollution. 11Recommendations are provided in Chapter 7.
|
Key Terms
This material may be derived from roughly machine-read images, and so is provided only to facilitate research.
More
information on Chapter Skim is available.