A Regional Response to New Air Monitoring Requirements

1. A Regional Response to New Air Monitoring Requirements Michael KoerberLake Michigan Air Directors Consortium October 3, 2011

2. Overview • Background • Air monitoring in Region 5 • Regional Network Review (July 1, 2010) • Region 5 States’ Plan to Address New Requirements (April 7, 2011)

4. Major Findings • Existing state/local monitoring networks provide valuable data and need to be maintained • A few improvements recommended – both shutdowns (disinvestments) and new monitoring (investments) • Many new EPA monitoring requirements expected over next several years • Sufficient funding/staffing not available to implement all of the requirements

5. New Monitoring Requirements

6. Costs Other (air toxics) PM2.5 (Sec. 103) Other Criteria Pollutants (Sec. 105) NCore Pb SO2 NO2 Existing S/L Monitoring Programs New Monitoring Requirements

7. Letters to EPA July 1, 2010: Due to lack of resources, we “believe that we will be unable to fully comply with all of the new requirements. We would like to discuss the implications of this with EPA.” April 7, 2011: Provides EPA with “our recommendations concerning implementation of the air monitoring requirements.”

8. What is the problem? States are struggling to maintain high value and high quality air monitoring data, due to flat/decreasing budgets and staffing, and: • rising operating costs for existing monitoring (and unfunded operating costs for new monitoring), • need for periodic equipment replacements, • increased reporting burden for quarterly progress reports, • increased staff costs (and staff turn-over), • increased travel costs, • changes in operating procedures, • limited ability to reduce design of networks due to more stringent standards, and • demands of increasing EPA monitoring requirements.

9. Summary of Recommendations • Phased approach for near-roadway NO2 and CO • 1 site in 2-3 cities • Establish new near-source Pb (Phase II) and O3 (smaller cities, rural) sites, as resources permit • No new SO2 sites • Reduce existing networks for PM10, PM2.5, CO

10. Top “10” Monitoring Programs • PM2.5 mass (FRM) • O3 - existing • PM2.5 mass (continuous) • PM2.5 speciation • Pb – Phase I • NCORE • NATTS • O3 – new • State air toxics • Pb – Phase II and SO2 – existing (tie)

11. NO2 Proposal: Phased approach with 1 NR site in 2-3 cities. Maintain/reduce network – satisfies population and EJ(?) requirements.

12. CO Proposal: Scale back existing network - move monitors to near-roadway sites, as needed.

13. SO2 Proposal: No new sites (and scale back existing network) – NAAQS implementation based primarily on modeling

14. PM10 Proposal: Scale back existing network

15. PM2.5 and O3 =current D.V. > NAAQS =current D.V. > NAAQS Question: Can we/should we cut PM2.5 and O3 now, in light of possible future tightening of these standards?

16. Summary • Near-roadway NO2 and CO • “Build and hold” goes beyond what we proposed (8 v. 3 sites), but can do if get new $$$ and site shutdowns (resource shifts) approved by EPA • Reduce existing networks for SO2, PM10, CO, and areawide NO2 • Need to free up resources/staffing to cover unfunded monitoring activities (e.g., O&M for Pb and near-roadway) • Establish new Pb (Phase II) sites • Sit tight on existing PM2.5 and O3 networks

17. Next Steps • Recent EPA actions encouraging • O3 – dropping proposal for more monitoring • Secondary NOx/SOx – proposed no new monitoring • NO2, CO – scaling back near-roadway monitoring requirement • Still need help…. • NO2, CO • S.103 $$$ for equipment/set-up (FY11 and FY12 grants) • Resources for O&M (???) • Do we continue NR monitoring if concentrations << NAAQS ? • SO2 – drop requirement for new monitoring • PM2.5 – need resolution of FEM v. FRM (and no new monitoring requirements, especially in light of pending funding transition from S.103 to S.105) • Approval of monitor/site shutdowns