Reducing Air Pollution Challenges and Opportunities

1. Reducing Air PollutionChallenges and Opportunities New Jersey Clean Air Council April 14, 2010

2. Challenges • Reductions in upwind states • National Rules • Local controls • Low hanging fruit is all gone • Regional competition • Ports as an example • Regional coordination • Multi-Pollutant planning • Harmonizing control efforts across multiple pollutants

3. Topics Covered • What does the science say? • The MD Conceptual Model … or • Where does our air pollution come from and what do we do about it? • What are we doing? • Local versus regional control programs • What does the preliminary modeling tell us? • How are we doing with new local control programs? • Innovative state initiatives • How are we doing with “National” rules to reduce transport? • Will we make it? • Are we on schedule?

4. 1-Hour Ozone 8-Hour Ozone Daily Fine Particulate Annual Fine Particulate Progress in Cleaning Maryland’s Air *2008 data are preliminary. What Have We Learned from All of This?

5. Recent research has identified two new concepts that significantly affect: Our understanding of how ozone builds up each day The need for more national emission reduction programs These new areas are: The existence of an “Elevated Reservoir” or “Transport Cloud” of very high ozone sitting above the Mid-Atlantic during the early morning hours on bad ozone days The transport and build-up of ozone and ozone precursors at night Much of our work on ozone applies for summertime PM as well The Science Two Significant New Findings

6. Every bad ozone day, in the morning hours, a large reservoir of ozone sits, trapped aloft by a nocturnal inversion, above the Mid-Atlantic area waiting to mix down. Ozone levels in the reservoir are routinely measured at 60 to 100 ppb. In the morning, ozone levels at the surface are very low – 20 to 30 ppb. In the morning (9 to 11), the ozone in the reservoir mixes down to the surface and ground-level monitors surge from about 20 to 30 ppb to about 60 to 90 ppb. The morning surge The Elevated Ozone Reservoir

7. Hour By Hour Ozone - Back in 1990’s

8. Still Happening in 2000’s

9. So…Where Does Our Air Pollution Come From? Four Distinct Parts • Local emissions in Cities (nonattainment areas) • Reducing local emissions is very important • Three distinct types of transport • Short range - City to City – “local” transport • “Ground level” transport • Washington to Baltimore, Baltimore to New Jersey, Jersey to …etc. • Two different types of “aloft” (up-over-and-down) transport • Westerly, Long range transport • “Aloft” transport - 100s of miles • Generally from W or NW • Southerly, Nocturnal Low Level Jet (NLLJ) • “Aloft” transport at night !!! • 100s of miles • SW to NE funneled along the Atlantic by the ocean and the mountains Aloft transport creates and fills the “Elevated Reservoir” of air pollution (measured above the Mid-Atlantic during the night and morning) before all bad ozone days

10. A Two Part Control Strategy We must continue to adopt aggressive local control measures to reduce the local contribution We will need significant help to reduce the transported ozone and ozone precursors in the elevated reservoir

11. Local Controls or National Controls? • Both • Local Controls • Clearly help reduce air pollution • “Clean Hands” are critical when pushing for controls in upwind states • Local controls for other concerns (toxics/nuisance) are essential • National Controls • Clearly a huge priority • Have earlier actions like the NOx SIP Call worked? • What additional emission reductions are needed?

12. 22.3%of Units 55.5%of Units Scheduled Startup Units Phase I Phase II Large Number of SCR Units InstalledExpect SIGNIFIANT NOx ReductionsEspecially after 2003-2004Air Qualityshould decrease dramatically Minimal SCR UnitsExpect Minimal NOx Reductions 2004 Regional NOx “SIP Call” BY 2011, ABOUT 50 TO 70 PERCENT OF THE COAL FIRED CAPACITY IN THE EAST WILL BE CONTROLLED BY SCRS 77.8% of Units Installed between 2003-2007 Data courtesy of The Institute of Clean Air Companies (ICAC).

13. Preliminary Screening Modeling • NY DEC did a screening modeling run, assuming an additional 40% NOX reduction from all sectors domain-wide • Results showed almost all sites below 75 ppb • New “reconsidered” standard likely to be lower • Other states east of the Mississippi were assumed to make similar NOx reductions • Analysis used for all of the 13 states in the Ozone Transport Region (OTR)

14. We’ve used the screening modeling to come up with a very rough estimate of the OTR’s share. The OTR’s share of the 40% reduction is about 500,000 tons per year of NOx Reductions Inside the OTR Reductions – through 2012 - that are “on-the-books” or “on-the-way” New Reductions

15. Stationary and Area Source Controls • Looking at 13 new control measures • Many just within the OTR • Some that should be national rules • Working with stakeholders • Measures include: • Electricity Generating Units (EGUs) • Other stationary sources • Area sources like consumer products and paints • Non-traditional programs like HEDD (High Electricity Demand Days) • More

16. Mobile Source Controls • Looking at 5 to 10 new control measures • Many just within the OTR - Some that should be national rules • Includes • Tailpipe standards, fuels, VMT (Vehicle Miles Traveled), idling and non-road sources like ports, ships, diesel equipment, lightering and more

17. State Innovations • Both MD and NJ have a reputation for pushing innovative state programs • Maryland’s Healthy Air Act • “Code Orange” telework • High electricity demand days • Smart growth and VMT strategies • Integrating climate change and criteria pollutant control programs • Innovations are sometimes non-regulatory and more difficult to quantify and enforce • Non-traditional programs are likely to become a more significant part of the solution with a new ozone standard in the 60 to 70 ppb range

18. Good News For NJ • Maryland’s Healthy Air Act now being implemented • May 2009 and 2012 deadlines for NOx controls • January 2010 and 2013 deadlines for SO2 and Hg controls • All controls installed on time • 6 plants – 9 units • Major investment in Scrubbers, SCRs, ACI, baghouses and other controls • Almost $3 Billion investment into state-of-the-art pollution control equiptment • Yes … Maryland is pretty much directly upwind of NJ

19. So … How Are We Doing? • Using 500,000 TPY NOx reduction as a target • “New” reductions that are under development are currently estimated to get us close • New measures being worked on by the OTC Committees • Inside-the-OTR reductions from new national rules (eg. the CAIR replacement rule) • Continuing benefits from existing programs (eg. new mobile reductions resulting from fleet turnover)

20. Reducing Transport - National Rules • Significant progress under way • Partnership with Midwest States, EPA and stakeholders working well • September 2, 2009 State Collaborative letter signed by 17 states • Strong recommendation on new national rules

21. The Collaborative Modeling • Joint effort between Midwest and OTC states • Looked at what would be needed to adequately address transport and satisfy the transport provisions - Section 110(a)(2)(D) - of the Clean Air Act • Showed that a national program that focuses only on EGUs will not be enough

22. The Collaborative Letter • Asks for … “A timely and robust federal program that requires substantial regional emission reductions from mobile sources, area sources and large point sources such as EGUs…” • Specifically mentions national rules for: • Electric Generating Units (EGUs) • Industrial, Commercial and Institutional Boilers • Other large stationary sources of NOx (like cement kilns) • Architectural and Industrial Maintenance Coatings • Consumer Products • Mobile sources (such as new engine standards and fuels)

23. Priority National Rules • OTC statement and Collaborative letter identified priority national rules • Recommended national rules • Highest Priority • EGUs (CAIR replacement rule) • ICI Boilers • Cement Kilns • New federal tailpipe standards • Others • Other large stationary sources of NOx • AIM Coatings • Consumer products • Cleaner, environmentally sensitive fuel • Several others

24. The Schedule • On September 16, 2009, EPA announced that it will reconsider the ozone standard that was set on March 12, 2008. • They also announced an expedited schedule • Because of the expedited schedule, there will be very little delay and no change to the OTCs current schedule

25. Updated Timeline States begin rule development process Identify control measures & develop technical information Final SIPs submitted to EPA Begin inventory work; do preliminary modeling Complete air quality modeling of measures States propose SIPs State Attainment Demonstration SIPs Due to EPA Dec. 2013 EPA Proposed Reconsidered Ozone NAAQS 12/2009 EPA Final Reconsidered Ozone NAAQS 8/2010 EPA Final Designations No later than 8/2011 Likely Attainment Dates for Reconsidered Ozone Standard Moderate – 2017 (Requires 3 years of clean data in 2014, 2015 and 2016) Serious – 2020 (Requires 3 years of clean data in 2017, 2018 and 2019)

26. Wrap-Up • Ozone and fine particle levels continue to drop • This is great news • Tougher ozone and fine particle standards are on the horizon • Still lot’s of work to do • The regional air quality planning process is on schedule • Suite of new local measures identified and scheduled for adoption in June 2010 • National measures to reduce transport are critical • Will need significant help from EPA