Ozone NAAQS Implementation

1. Ozone NAAQS Implementation WESTAR Fall Meeting September 29, 2010 Scott Mathias, Associate Director Air Quality Policy Division

2. Proposed Designation Schedules EPA proposed designation schedules in the January 2010 ozone NAAQS proposal Primary NAAQS: Proposed accelerated schedule Final designations in less than 1 year vs. 2 years States submit recommendations in 129 days vs. 1 year Seasonal secondary NAAQS: Took comment on 2 alternative schedules Same accelerated schedule as for primary standard, or Traditional 2-year schedule allowed under CAA; States submit recommendations in 1 year.

3. Designations Assistance Plan to offer early interaction/assistance to facilitate development of states’ recommendations. Revised designations guidance with description of each factor and information that might be used to assess. 5-factors: air quality data, emissions-related data, meteorology, geography/topography, jurisdictional boundaries. Guidance on qualifying for “rural transport area” classification. Potential for partial counties in certain cases. Plan to share information addressing designation factors shortly after NAAQS are final. Including ozone source apportionment modeling results which estimates the combined impact of multiple factors (emissions, meteorology, geography). 5-factor TSD template

4. Boundary Decision Criteria EPA’s goal is national consistency in decisions to ensure legally defensible designations. CAA Sec 107(d): NAA boundary must contain any area that violates the NAAQS or that contributes to NAAQS violation in a nearby area. Suggest Census-defined CSA/CBSA is starting point for technical analysis; analysis could support smaller or larger area. Possible decision guides?: Counties in CSA/CBSA that contribute at least ___ ppb ozone to any violating monitor in the CSA/CBSA are “presumed in”? NAA boundary to include sufficient area (e.g., counties or parts of counties) to account for at least ___% of total ozone contribution from CSA/CBSA counties to violating monitor(s)? “Nearby” includes any area within CSA/CBSA? Beyond that considered to be long-range transport?

5. Classifications Option 1 is consistent with the approach used for the 1997 standard. Results in largest number of “Marginal” areas (and moderate areas). Fewer mandatory controls; shorter attainment deadlines with higher probability of “bump-up.” Option 2 specifies the Extreme threshold as either the actual DV of the area with the highest DV at the time we designate, or a value approximately mid-way betweqen the two highest DVs at the time we finalize the implementation rule. Results in more areas in higher classifications. More mandatory controls, but with more time to attain w/o “bump-up.” Also considering proposing that where states submitted voluntary reclassification requests under the 1997 NAAQS we would treat those requests as applying to this standard unless the state says otherwise. Would avoid going through separate reclassification process. 5

6. 420 counties violate 0.070 ppm 161 additional counties violate 0.065 ppm for a total of 581 74 additional counties violate 0.060 ppm for a total of 655 Counties With Monitors Violating Proposed Primary 8-hour Ground-level Ozone Standards 0.060 - 0.070 parts per million (Based on 2007 – 2009 Air Quality Data) EPA will not designate areas as nonattainment on these data, but likely on 2008 – 2010 data which are expected to show improved air quality. Notes: 1. No monitored counties outside the continental U.S. violate. 2. EPA is proposing to determine compliance with a revised primary ozone standard by rounding the 3-year average to three decimal places.

7. Counties With Monitors Violating Proposed Secondary Seasonal Ground-Level Ozone Standards 7 – 15 parts per million - hours (Based on 2007 – 2009 Air Quality Data) EPA will not designate areas as nonattainment on these data, but likely on 2008 – 2010 data which are expected to show improved air quality. 83 counties violate 15 ppm-hours 424 additional counties violate 7 ppm-hours for a total of 507 No monitored counties outside the continental U.S. violate.

8. Additional counties that would violate a W126 secondary standard compared to alternative primary standards(based on 2007-2009 data)

9. Possible Number of “Areas” (as defined below) Violating Alternative Primary Standards (based on 2007-2009 data) Larger geographic area

10. Exploring Possible SIP Flexibility • Deadline alignment of multiple SIP obligations? • e.g., emissions inventories, RACT, I/M, attainment demonstration • Maximize use of Rural Transport classification • Marginal area requirements • Threshold for “self-contribution”? ___ ppb? ___% of design value? • NOx substitution in 15% VOC Plans? • Alternative to photochemical grid modeling for Moderate areas? • Attainment deadlines at the end of the calendar year 3, 6, 9, etc. years from designations?

11. Additional State Assistance • State Implementation Plan Status and Information Website: http://www.epa.gov/air/urbanair/sipstatus/ • SIP guidance materials database. • Menu of NOx/VOC regulatory control measures. • Local measures Web site: early implementation may result in suspension of planning requirements and redesignation before some CAA requirements are due. • Training materials (web modules, webinars, course materials). • National/regional rules: Transport Rules 1 & 2, tailpipe standards? • Possible national or presumptive RACT for selected source categories. • e.g., ICI boilers, cement kilns, glass manufacturing, oil & gas? • Possible national attainment modeling • Use of EPA national/regional modeling to support attainment demonstrations for moderate areas.

12. Southwest 1,872 1,021 851 ~ Boilers & Cement % ofTotal NOx % ofTotal NOx 11% 10.3% 4.8% 1.9%

13. West 2,340 1,299 1,042 ~ Boilers & Cement % ofTotal NOx % ofTotal NOx 2% 3.8% 0.9% 1.3% 0.6% 0.7%

14. Proposed Transport Rule • Proposed rule does not directly regulate any western states. • EPA estimates that implementation of the rulemaking, as proposed, would reduce annual nationwide emissions from EGUs by: • 4.7 million tons of SO2 in 2012, and 4.4 million tons in 2014. • 0.8 million tons of NOx in 2012, and 0.8 million tons in 2014. • Also, 0.1 million tons of NOx will be reduced in the 2012 and 2014 ozone seasons (these are included in estimate above). • IPM modeling for 2012 and 2014 predicts some small increases in SO2 emissions in western states due to modeled use of higher-sulfur coal in a few instances. • EPA intends to use TR1 “template” to assess 2010 ozone NAAQS. • Will include western United States in the analysis. • Work has begun on "linkage" modeling.

15. Proposed Transport Rule:States Required to Reduce Emissions

16. EPA/OAQPS Air Quality Modeling for Western U.S. • We are continuing to develop the model infrastructure needed to support air quality policy in the Western U.S. • Plan to use this modeling to support upcoming Federal rules (e.g., Transport Rule 2, Tier-3 mobile). • Preliminary model performance evaluation has shown relatively low errors and biases for regional ozone (see plot). However, we are always trying to improve. Current efforts include: updated emissions, better estimates of international transport, and improved meteorological inputs. • We intend to be a collaborative partner in assisting Regional, State, and Local agencies in their modeling efforts. • While the modeling process is iterative; we expect initial data sets to become available in early 2011. 16