Download Congressional Clean Air Act Forum - National Association of Clean

Congressional Clean Air Act
Forum
John A. Paul
RAPCA
NACAA Fall Meeting, 2012
What I Will Cover
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Background
What I Submitted in Writing
What I Said at the Forum
What I Heard from Others
What I Wrote in Follow-up
Background on RAPCA
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Regional Air Pollution Control Agency
Six-county local agency—Dayton, Ohio
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Agency roots from the 1950’s under the City
Health Department authority—Direct grant from
USEPA and annual contract with Ohio EPA
One of nine local agencies in Ohio
History of nonattainment for ozone and
particulate matter and currently borderline air
quality for both
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Background on RAPCA
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At one time Dayton was a Major Manufacturing Area
15 Foundries
5 General Motors Plants
National Cash Register
Dayton Press (McCalls/Readers’ Digest)
Three Paper Mills
Two Large Electric Generating Stations, Downtown
Steam Stations
Two Large Municipal Incinerators
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RAPCA - Ambient Air Quality Monitoring Program
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15 ambient air quality monitors at 12 locations:
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60
2012
2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2001
2000
1999
1998
1997
1996
1995
1994
1993
1992
1991
1990
1989
1988
1987
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1983
1982
1981
1980
1979
1978
1977
ppbv
Preble County, Ohio 4th max 8 hr Ozone
120
110
100
90
80
70
6
60
2012
2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2001
2000
1999
1998
1997
1996
1995
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1993
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1991
1990
1989
1988
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
ppbv
Clark County, Ohio 4th max 8 hr Ozone
120
110
100
90
80
70
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VOC Emissions Inventory, tons per year
Area
Mobile
Point
TOTAL
1977
15000
35000
23000
73000
1999 NEI
27000
27000
2000
56000
Current
(2008 NEI)
16000
19000
1700
37000
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NOx Emissions Inventory, tons per year
Area
Mobile
1977
Point
TOTAL
18000
1999 NEI
3000
40000
8000
51000
Current
(2008 NEI)
3000
36000
5000
44000
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What I Wrote
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Current EPA is doing their duty under the
CAA
Current NAAQS process is scientific and
should be retained
CAA is very detailed legislation
NSR has a detailed history and is precedent
driven—very complicated
BACT is the bottom line for NSR
Control of air pollution is our goal.
What I Said
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This is an approachable EPA that is
responsive and good to work with
Great working relationship with EPA through
NACAA in coordination with other states and
locals
The importance of timeliness and certainty in
regulation
NAAQS—follow the science and set these
standards at levels protective of public health
What I Said
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National controls on EGUs, vehicles, fuels
are essential
Funding is needed
Climate change should be addressed in
legislation
Multi-pollutant approach to control
What I Heard
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The SIP process needs address
Maintain state/local flexibility
NAAQS promulgation and SIP guidance at
the same time
Integration of air quality, energy, and climate
change
Keep the NAAQS process, but extend the
time to 10 years
What I Wrote in Follow-up
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NAAQS should remain science-based and not
include costs
Meeting the NAAQS is where costs are
considered
SIP process—look to NACAA/ECOS/EPA
workgroup for recommendations
National controls needed
Resource and funding shortfalls are serious
Climate change should be addressed in
legislation