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 Change in average concentration since 1990 • Carbon Monoxide (CO) 8-Hour, 74% • Lead (Pb) 3-Month Average, 82% (from 2010) • Nitrogen Dioxide (NO 2 ) Annual, 57% • Nitrogen Dioxide (NO 2 ) 1-Hour, 50% • Ozone (O 3 ) 8-Hour, 21% • Particulate Matter 10 microns (PM 10 ) 24-Hour, 26% • Particulate Matter 2.5 microns (PM 2.5 ) Annual, 39%(from 2000) • Particulate Matter 2.5 microns (PM 2.5 ) 24-Hour, 34%(from 2000) • Sulfur Dioxide (SO 2 ) 1-Hour, 89% Source: https://gispub.epa.gov/air/trendsreport/2019/#highli ghts
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
Air Quality Management Planning Process THE AIR QUALITY MANAGEMENT CYCLE Characterize the problem; Assess expected improvement Identify air quality ambient monitoring, inventories, from existing national/provincial policies; goal data analysis; regional planning evaluate potential emission reduction with other cities/provinces strategies for future year Scientific Research Ongoing evaluation: Attainment planning process: modeling to identify strategies to meet air quality monitoring, target; adopt regulations and submit plan; implementation of control implement control strategies, permitting and enforcement programs; programs, track emissions update emergency episode plan 4
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 5
STATE IMPLEMENTATION PLANS Designating areas, State Implementation Plans, Demonstrations • 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. 6
STATE IMPLEMENTATION PLANS Elements of non-attainment area 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 ) 7
EMISSION SOURCE PERMITTING For accountability and continuous improvement in air quality as cities grow 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 8
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.
AirNow.gov 10
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 opportunities. 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 11
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 15
ध�वाद Thank You Thank You Gracias Dale M Evarts Former Director, Climate and International Group, US EPA Office of Air Dale.Evarts@gmail.com
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