U.S. AIR QUALITY MANAGEMENT LESSONS IN INCENTIVIZING ACTIONS FOR - - PowerPoint PPT Presentation

U.S. AIR QUALITY MANAGEMENT

LESSONS IN INCENTIVIZING ACTIONS FOR IMPROVED AIR QUALITY

Dale M Evarts

Former Director, Climate & International Group, EPA Office of Air October 21, 2019

OUTLINE

• U.S. air quality trends and challenges
• Air Quality Management (AQM) Cycle
• Overview of the elements of the U.S. air quality

management system

• Using enforcement, compliance and funding to

incentive effective AQM

• Program and policy recommendations

U.S. AIR QUALITY TRENDS

The U.S. has made great strides in reducing air pollution since the passage of the Clean Air Act Amendments

Source: https://gispub.epa.gov/air/trendsreport/2019/#highli ghts

Change in average concentration since 1990

• Carbon Monoxide (CO) 8-Hour,

74%

• Lead (Pb) 3-Month Average,

82% (from 2010)

• Nitrogen Dioxide (NO2) Annual,

57%

• Nitrogen Dioxide (NO2) 1-Hour,

50%

• Ozone (O3) 8-Hour,

21%

• Particulate Matter 10 microns (PM10) 24-Hour,

26%

• Particulate Matter 2.5 microns (PM2.5) Annual,

39%(from 2000)

• Particulate Matter 2.5 microns (PM2.5) 24-Hour,

34%(from 2000)

• Sulfur Dioxide (SO2) 1-Hour,

89%

CONTINUING AIR QUALITY CHALLENGES

• Despite this progress, an

estimated 132 million people (40% of the U.S. population) live in areas that exceed a NAAQS or that have been re- designated to attainment subject to maintenance

Source: https://www.epa.gov/green-book/green-book-map-download

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Identify air quality goal

Scientific Research

Air Quality Management Planning Process

Attainment planning process: modeling to identify strategies to meet target; adopt regulations and submit plan; implement control strategies, permitting and enforcement programs; update emergency episode plan Assess expected improvement from existing national/provincial policies; evaluate potential emission reduction strategies for future year Ongoing evaluation: air quality monitoring, implementation of control programs, track emissions Characterize the problem; ambient monitoring, inventories, data analysis; regional planning with other cities/provinces

THE AIR QUALITY MANAGEMENT CYCLE

NATIONAL STANDARDS AND REGULATIONS

• National Ambient Air Quality Standards
• Monitoring and Implementation Regulations
• Technology Based Emission Standards
• For both large and small stationary sources
• Toxic pollutants
• New Source Performance Standards
• Existing Source Guidelines
• Vehicle and Fuel Standards for Mobile Sources
• Light duty passenger vehicles
• Heavy duty and off-road vehicles
• Ships and locomotives

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STATE IMPLEMENTATION PLANS

• EPA designates areas as attaining or not attaining air quality

standards (based on monitored data)

• Nonattainment areas include violating areas and areas contributing to

violations

• Additional more stringent control requirements can apply based on severity of

pollution

• Once EPA has established air quality standards, States prepares
• Includes legal authorities, rules, and practices used to attain and maintain the

standards

• Plans must demonstrate that area can attain and maintain air

quality standards

• Plans impose controls on individual sources as necessary to

attain and maintain the standards.

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Designating areas, State Implementation Plans, Demonstrations

STATE IMPLEMENTATION PLANS

• Develop detailed emission inventory of sources
• Identify existing federal & state controls
• Evaluate technically and economically feasible new controls on

sources in nonattainment area and state

• Conduct air quality modeling to evaluate air quality improvement

from projected existing and new emission reductions

• Adopt enforceable regulations and control measures: emission

limits, test methods, monitoring and reporting for specific sources

• Ensure reasonable progress toward attainment
• Adopt contingency measures to apply in the event the area fails to

attain by its attainment date

• Include authority to stop air pollution that endangers public health

(emergency episode powers)

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Elements of non-attainment area plans

EMISSION SOURCE PERMITTING

Preconstruction Permits

• To protect public health and the environment as new industrial facilities

are built and existing facilities expand

• Ensure that air quality:
• Does not worsen where the air is currently unhealthy to

breathe (nonattainment areas)

• Is not significantly degraded where the air is currently clean

(attainment areas)

Operating Permits:

• Combine all applicable requirements (control limits, monitoring,

reporting) into a single document (the permit) for each source

• Levy fees to fund state/local administration of the program
• Hold a single person or entity accountable for compliance

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For accountability and continuous improvement in air quality as cities grow

THE IMPORTANCE OF REGIONAL APPROACHES

Scientific: Air pollution does not stop at state boundaries (i.e., transport) Legal: “Good neighbor” provision of U.S. Clean Air Act Political: Build trust and ensure cooperation Programmatic: Develop working relationships and technical capacity Financial: Leverage resources Challenges: increased number of stakeholders and interests to include in developing solutions. Successful example: NOx Budget Trading Program for eastern U.S.

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AirNow.gov

PROVIDING ADEQUATE RESOURCES

Agencies need to make a long-term investment in the future:

• Sufficient operating budgets and staff
• Ongoing technical training to develop and keep expertise in key

technical areas.

• Participation in regional planning efforts provides practical training
• pportunities.

Seek diverse sources of funding

• National, state and local governments
• Fees from air permits, enforcement penalties
• Private sector partnerships

Example: South Coast Air Quality Management District (Los Angeles, CA)

• 16 million population, 12 million vehicles, $130 million annual budget, 700

staff, 74,000 permits

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OVERALL GOALS OF ENFORCEMENT

• Compliance with the law, in a timely way
• Controls that will ensure future compliance
• Drive innovation to reduce future pollution
• Redress of harm caused by noncompliance
• Recovery of penalties (two components)
• Gravity component: reflects the seriousness of the

violation

• Economic benefit component: remove any economic

benefit and unfair advantage that violator gained by not complying

PENALTY POLICIES ARE DESIGNED TO:

• Encourage companies to stay in compliance, not wait until

the violations are discovered

• Violations start at initial date of non-compliance
• Level the “playing field,” so violators do not get unfair

financial gain for failing to invest resources for environmental compliance

• Provide incentives to fix problems quickly
• Violations and penalties continue until corrected
• Deter future noncompliance
• Provide consistent, but flexible and fair, approach

OTHER FINANCIAL INCENTIVE MECHANISMS

• Clean Air Act tools
• Withhold Federal highway funds
• Pre-construction permit offsets – up to 2:1 for the most

severely polluted areas

• Operating permit fees
• Leveraging State air pollution control grants and

priorities through State-EPA Agreements

• Federal funds, approved by Congress, to support State

air programs (current average ~25% of total funding)

RECOMMENDATIONS

• 1. Ensure adequate implementation and

enforcement with incentive actions and penalties

• 2. Set measurable air quality goals

(standards and plans) based on the best available science & information

• 3. Collect information (air quality and emissions) and use it to

educate and involve the public

• 4. Keep clean areas clean and clean up polluted areas using

best available technologies for control

• 5. Provide sustained resources (funding, people, training) to

build expertise, infrastructure, and institutional capacity

• 6. Integrate energy and air quality planning

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Dale M Evarts

Former Director, Climate and International Group, US EPA Office of Air

Dale.Evarts@gmail.com

धवाद

Thank You

Thank You Gracias