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Inventory Needs and Legal Requirements

Inventory Needs and Legal Requirements. Martin Johnson Emission Inventory Workshop Air Resources Board March 13, 2006. Presentation Outline. Who Uses the Inventory? How is the Inventory Used? Agency Responsibilities Legal Requirements Reporting Guidelines and Requirements

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Inventory Needs and Legal Requirements

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  1. Inventory Needs and Legal Requirements Martin Johnson Emission Inventory WorkshopAir Resources Board March 13, 2006

  2. Presentation Outline • Who Uses the Inventory? • How is the Inventory Used? • Agency Responsibilities • Legal Requirements • Reporting Guidelines and Requirements • ARB Audit Program Emission Inventory Workshop Spring 2006

  3. Inventory Users • Local air districts • ARB and other state agencies • USEPA • Industry • Consultants • Academics • Environmental Groups • Public Emission Inventory Workshop Spring 2006

  4. Inventory Applications • Emission Trend Studies • State Implementation Plans (SIPs) • Control Measure Development • Regional Air Quality Modeling • Neighborhood Level Studies (EJ) • Cumulative Risk Analyses • Public Information Requests Emission Inventory Workshop Spring 2006

  5. Upcoming Inventory Priorities • 8-Hour Ozone SIPs – Districts with Nonattainment Designation • Preliminary modeling inventories completed Dec-2005 • Completing planning projections now • SIPs due to EPA June 2007 • PM2.5 SIPs - SC, SJV • Preliminary modeling inventories completed Dec-2005 • Completing planning projections now • A few external adjustments anticipated • SIPs due to EPA April 2008 • Regional Haze SIPs • Western Regional Air Partnership (WRAP) • Draft 2018 Milestone Projections completed Nov 2005 • 2064 attainment • SIPs due to EPA Dec 2007 • Statewide Risk Modeling - all districts • Fall 2006 (Tentative) Emission Inventory Workshop Spring 2006

  6. Agency Responsibilities for Inventory Development • Local Air Districts • Point sources • Some areawide source categories • ARB • On-road vehicles (EMFAC) • Off-road and other mobile (OFFROAD) • Some areawide source categories • Transition Categories • Statewide methodology for Ships for Goods Movement • Areawide source categories by agency available at: • www.arb.ca.gov/ei/areasrc/lstareasrccats903.pdf Emission Inventory Workshop Spring 2006

  7. Legal Requirements • State Health and Safety Code • California Clean Air Act • AB 2588 “Hot Spots” Act • ARB Environmental Justice Policies • Federal Clean Air Act Amendments • Federal Consolidated Emissions Reporting Rule (CERR) • Air Emissions Reporting Requirements (AERR) Emission Inventory Workshop Spring 2006

  8. State Health and Safety Code • ARB has responsibility for development of State Implementation Plans (Section 39602) • ARB must inventory all sources of air pollution and use local agency data to fullest extent possible (Section 39607(b)) • Districts have power to require facility operators to provide emission inventory data (Section 40701(g)) Emission Inventory Workshop Spring 2006

  9. California Clean Air Act • Adopted in 1987 • Requires all areas of the State to attain state standards as soon as possible (all feasible measures) • Limited to criteria pollutants • Authorizes ARB to require districts to impose fees on sources > 250 TPY of any nonattainment pollutant • Authorizes ARB to impose fees on consumer product and architectural coating manufacturers that sell a product in California resulting in emissions > 250 TPY of VOC Emission Inventory Workshop Spring 2006

  10. AB 2588 “Hot Spots” Act • Passed in 1987 • Limited to toxics pollutants • Objective is to reduce toxics risk from individual facilities • Includes public notification process • Quadrennial reporting schedule • Fee schedule adopted to support program • Risk-based program (i.e. not emission-based) Emission Inventory Workshop Spring 2006

  11. ARB Environmental Justice Policies • Adopted in 2001 • In response to SB 115, EJ must be considered in development, adoption, implementation, and enforcement of environmental laws and regulations • ARB must assess, consider, and reduce cumulative emissions, exposures, and health risks Emission Inventory Workshop Spring 2006

  12. Federal Clean Air Act Amendments • Passed in 1990 • Limited to criteria pollutants • Affects states with nonattainment areas • Requires submittal of comprehensive, accurate, and current emission inventories as revisions to SIPs Emission Inventory Workshop Spring 2006

  13. Federal Consolidated Emissions Reporting Rule • CERR adopted in 2002 • Limited to criteria pollutants • Large point sources must report annually (threshold varies) • All other sources must report every three years • 2002 inventory submitted June 1, 2004 • 2005 inventory to be submitted June 1, 2007 Emission Inventory Workshop Spring 2006

  14. Air Emissions Reporting Requirements • Replaces CERR • Rule to be phased in by 2011 • Accelerated reporting schedule to EPA • e.g. 2010 data would be due on June 30, 2011 • Until 2011, EPA plans on scaling back the requirements under the CERR Emission Inventory Workshop Spring 2006

  15. Reporting Guidelines and Requirements • ARB CEIDARS Reporting Guidelines • AB 2588 Reporting Requirements • www.arb.ca.gov/ab2588/2588guid.htm#current • USEPA CERR • www.epa.gov/ttn/chief/cerr/index.html Emission Inventory Workshop Spring 2006

  16. ARB CEIDARS Reporting Guidelines • Guidelines, not legal requirements • Published every year • Criteria and toxics pollutants • Basis for annual submittals to CEIDARS database Emission Inventory Workshop Spring 2006

  17. Point Source Criteria Reporting • All New or Closed Point Sources • Every year • Point Sources > 10 TPY • Every year • Point Sources < 10 TPY • Every 3rd year (2005 base year next) Emission Inventory Workshop Spring 2006

  18. Point Source Toxics Reporting • Report high-risk facilities annually • Risk 1 in a million; or • 10 TPY of any single HAP; or • 25 TPY of any combination of HAPS • Report AB2588 facilities annually • Needed for toxics inventory, HARP, Community Health, CHAPIS, NEI Emission Inventory Workshop Spring 2006

  19. Criteria for Facility Updates • Missing and incorrect data • emissions, codes, spatial • Change in criteria emissions • 5% or 10 TPY change • Change in toxics emissions • 10% change in process rate • Addition or removal of device or process since last year Emission Inventory Workshop Spring 2006

  20. Area Source Updates • Districts requested to update 1/3 of their area sources annually • Recognize resource intensive • ARB on-line clearinghouse of district methodologies www.arb.ca.gov/ei/areasrc/index0.htm • Encourage all districts to submit methodologies to assist others Emission Inventory Workshop Spring 2006

  21. Reporting Methods • Prefer electronic submittals • Batch • HARP • CEIDARS Web Forms • QA report tools are available on the web for districts to help correct errors Emission Inventory Workshop Spring 2006

  22. Merged Criteria and Toxics • ARB still in the process of merging criteria and toxics databases • Districts requested to submit merged data • ARB willing to assist with mergers Emission Inventory Workshop Spring 2006

  23. Important District Deadlines • November 1, 2006 • Submit point and area source updates for 2005 inventory year • Feb 15 – Apr 30, 2007 • QA Review Period for 2005 inventory • June 1, 2007 • Final 2005 inventory frozen and provided to NEI Emission Inventory Workshop Spring 2006

  24. District Audit Program • ARB staff audit all aspects of district programs http://www.arb.ca.gov/audits/audits.htm • Includes AB 2588 and emission inventory • Based on CEIDARS reporting guidelines • All districts audited • Audit frequency function of nonattainment status • Results published in report provided to ARB and district upper management Emission Inventory Workshop Spring 2006

  25. Summary • Improved air quality is top public priority • SIPs and other control programs need complete and current inventories • District and ARB partnership critical • Some legal mandates require district cooperation and assistance Emission Inventory Workshop Spring 2006

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