Ozone: Violations, NonAttainment & our Air Quality Future

Ozone: Violations, NonAttainment & our Air Quality Future Peter Bella Alamo Area Council of Governments Guadalupe County Workshop / Randolph Metrocom Chamber October 9, 2012

Key Questions Today 1. What does the ozone violation mean? 2. What actions has San Antonio taken to reduce its contribution to ozone? 3. Why are all counties in San Antonio – New Braunfels Metropolitan Statistical Area (MSA) included? 4. What can surrounding counties do to reduce their ozone contribution? 5. What kinds of sanctions might ensue? 6. What is the role of what we call "transport”? 7. Will the Eagle Ford possibly increase area ozone?

What is ozone? • Ozone is an odorless, colorless gas. • Ground-level ozone can cause: • shortness of breath • coughing or wheezing • headaches nausea • throat and lung irritation • Ground-level ozone’s effects are most profound on children, the elderly, and those with reduced lung capacity.

What Causes Ozone? Oxides of Nitrogen (NOx) & Volatile Organic Compounds (VOC) Note: NOx = NO + NO2 (<= criteria)

Emission Trends for VOC and NOx in San Antonio / New Braunfels MSA 1996 to 2018 San Antonio 8-County MSA Population

Population Growth in the SA-NB MSA Texas Water Development Board projects 41% growth in the SA-NB MSA between 2010-2040 from 2,142,508 to 3,029,300. Eagle Ford Shale not evident. Courtesy Bill Barker, OEP/CoSA

Regulatory O3 Monitors, AACOG / Bexar Co.: Camp Bullis C58, Calaveras Lake C59, SA Northwest C23 AACOG-operated Non-regulatory Ozone monitors: C500 series CPS Energy Owned and Operated Ozone monitors: C622, C678 http://www.tceq.state.tx.us/cgi-bin/compliance/monops/select_summary.pl?region13.gif

2008 Federal 8-Hour Ozone Standard 2008 8-hour average Ozone National Ambient Air Quality Standard • A community will meet the eight-hour standard when the three-year average of the annual fourth highest daily maximum eight-hour ozone concentration measured at each monitoring site is less than 76 parts per billion (ppb). * * Source: TCEQ's "Compliance with Eight-Hour Ozone Standard" page: http://www.tceq.state.tx.us/cgi-bin/compliance/monops/8hr_attainment.pl

Violation of the 2008 Standard Violation: the three year average of ozone levels on local monitors was too high. On August 21, two monitors violated the 2008 ozone standard. The “Three-Year Average” needs to be less than 76 parts per billion (ppb). Data: http://www.tceq.state.tx.us/cgi-bin/compliance/monops/8hr_attainment.pl

Requirements vs. Discretion Requirements: • The current 2008 ozone standard is now under review: • May be revised in 2013 according to the five-year review cycle. • IF the standard revised in 2013, and timeline did not change: • Proposal for a revised standard would be published in 2013 • Final standard promulgated in 2014. • Nonattainment designations promulgated in 2016 . • Designations would be made based on 2013-2015 data. • Next summer: possibly the 1st year in the 3-year average for designations under a more stringent ozone standard. • Now is a great time to initiate dedicated air quality improvements.

Requirements vs. Discretion EPA’s Discretion: • It is within the EPA Administrator’s discretion under the Clean Air Act to notify the Governor of any state that a designation revision should be revised. • “…on the basis of air quality data, planning and control considerations, or any other air quality-related considerations the Administrator deems appropriate...“ • Now is a great time to initiate dedicated air quality improvements, especially in light of the Ozone Advance program.

What is AIR Committee Doing? • Ozone Advance • EPA program to provide assistance to areas interested in staying in attainment • Voluntary program for voluntary progress • If we are subject to a nonattainment designation, AND we have implemented adequate reduction, EPA administrator MAY allow time.

What is AIR Committee Doing? • Ozone Advance • Outreach to local business and industry • TERP: Cleaner fuels for cleaner fleets • Catalogue existing “clean” practices • June 25, 2013: “Path Forward” letter to EPA with list of control strategies to put in place • Eagle Ford Shale (EFS) Emissions Inventory for Ozone Precursors • Develop best estimations for activities • AACOG staff under contract with TCEQ

Strong Commitment to Success and Recognition

Strong Commitment to Success and Recognition Photo: Forrest Mims III June 13, 2007: Hon. Jay Millikin presents recognition award to Tom Spaits of Capitol Cement for SNCR implementation

EPA Default Boundary: MSA* Metropolitan Statistical Area Atascosa, Bandera, Bexar, Comal, Guadalupe, Kendall, Medina, and Wilson Counties See page 3, “Area Designations for the 2008 Revised Ozone National Ambient Air Quality Standards”: http://www.epa.gov/groundlevelozone/designations/2008standards/documents/ 2008-12/Area_Designations_for_the_2008_Revised_Ozone_NAAQS.pdf

Surrounding Counties • Alamo Rural Transit – Mass Transit • Connect work-to-home with mass transit • TERP: Cleaner fuels for cleaner fleets • Energy Efficiency / Renewable Energy • Solar, wind, building code improvements • Building retrofits / AACOG Weatherization • SPEER / Energy Systems Lab + Consortium • Learn from CPS Energy • Avoid land clearing and agriculture burns on AQHA days

Key Programs under NA • Nonattainment New Source Review: • Seeks industry and business emission reductions • Allowances are reduced under emissions permits • Transportation Conformity • Requires that engineers demonstrate that “added capacity” roadway projects will not add pollution • One year from the date of a non-attainment designation, federally funded highway and transit projects require demonstration: no increase in emissions due to build-out

RACT/BACT/LAER Under EPA's "New Source Review" (NSR) program, if a company is planning to build a new plant or modify an existing plant such that air pollution emissions will increase by a large amount, then the company must obtain an NSR permit. • BACT, or Best Available Control Technology, is required on major new or modified sources in clean areas (i.e., attainment areas). • RACT, or Reasonably Available Control Technology, is required on existing sources in areas that are not meeting national ambient air quality standards (i.e., non-attainment areas). • LAER, or Lowest Achievable Emission Rate, is required on major new or modified sources in non-attainment areas. http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html

SIP Requirements for Ozone Nonattainment Areas Major Source Threshold (TPY) NSR Offset Ratios Courtesy TCEQ

Ozone Increases Downwind from Major Combustion Sources Ozone Increases Further Due to Numerous Urban Sources High Ozone Extends Downward from Urban Areas Rural Background Ozone Level Relatively low Wind Direction Rural Sources Cars Trucks Locomotives Small Engines Vegetation Major Combustion Sources Power Generation Cement Industry Manufacturing Urban Sources Cars Trucks Buses Airports Industries Construction Lawn & Garden Equipment Vegetation Courtesy TCEQ

Transport Image courtesy of the Capital Area Council of Governments

Eagle Ford Shale Play Superlative Comments -“Eagle Ford shale will be another Spindletop for Texas.” -“…and could be the most promising oil play in the nation.” -“…perhaps largest economic boom in our state’s history.” – Texas RR Commission -“… one of the nation’s biggest oil and gas fields over next 20 – 30 years.” -“The 400 mile stretch in south Texas is a major job factory.”

Horizontal Drilling / Hydraulic Fracturing "Ozone Impacts of Natural Gas Development in the Haynesville Shale," Environ. Sci. Technol., November 18, 2010 ENVIRON, et. al. http://pubs.acs.org/doi/abs/10.1021/es1021137 Figure from energyindustryphotos.com

Maximum Regional 8-Hour Ozone Impacts in 2012 Maximum impacts extend outside Northeast Texas into other regions of Texas

Wind directions relative to Bexar County on high ozone days > 70 ppb, 2005-2011 48-hour back trajectories within 250 miles of CAMS 58 Travis Gillespie Blanco Hays Bastrop Kerr Kendall 26% 8% Caldwell 2% Comal Bandera Guadalupe 24% Gonzales 1% Bexar Medina Wilson 2% 25% Dewitt 13% Frio Atascosa Karnes Goliad La Salle Bee Live Oak Wind data analysis: AACOG McMullen Well location data, Legend: http://www.rrc.state.tx.us/eagleford/images/EagleFordShalePlay120211-large.jpg

Eagle Ford Shale Estimates Draft NOx Emissions in tons per day from 24-county Eagle Ford shale play * 2011 estimations for Production not included. Production may create up to 25 additional tons of NOx/day in 2011. 2012 emissions will be higher. For example, midstream sources are estimated at 39.3 tons of VOC and 21.0 tons of NOx in 2012. NOx Emissions in tons per day from Point Sources, 8-County SA-NB MSA

C23 Back Trajectories on Days with 8-Hour Ozone > 75 ppb and the Location of Eagle Ford, 2008-2011 NOAA, Feb. 26, 2010. “Realtime Environmental Applications and Display sYstem (READY)”. Available online: http://www.arl.noaa.gov/ready.html. Accessed 01/12/12.

Questions / Comments Contact Information: Peter Bella Director Natural Resources, AACOG pbella@aacog.com (210) 362-5249

The Alamo Area Council of Governments • AACOG provides direct services & planning supporting communities and local governments in a 12 county area of south central Texas • Services to local governments & citizens (CJ, ART, Aging, etc.) • Planning forum for multi-jurisdictional issues (AQ, Eco Dev., Public Safety, etc.) http://www.aacog.com/

Anthropogenic NOX Emissions by Source Category, San Antonio / New Braunfels MSA, 1996 to 2018 (tons/day) NOX Point Source: 2013 NOX Point Source: 2013 * Does not include estimates from Eagle Ford development

Background • AACOG region: Full compliance with CAA (‘70s) • Significant actions taken in the AACOG region • Early Action Compact + Cement ind. & Power generation • Air Improvement Resources • CoSA’s Mission Verde + CPS Energy’s STEP • Clean Cities (DOE) + Commute Solutions (TxDOT) • Now More Than Ever • Eagle Ford shale (EFS) emissions are not now understood • 2010 & 2011 Design Values: “On The Cusp” pre-EFS • Growth > +885,000 in MSA from 2010-2040* pre-EFS • Doing Nothing ≠ Maintaining Air Quality * Texas Water Development Board

Smart Ideas for the Future • Greater Mobility – Mass Transit • Lone Star Rail • Transit Oriented Development • Greater Urban Densification • Decade of Downtown / Walkable Communities • Energy Efficiency / Renewable Energy • Solar, wind, building code improvements • Building retrofits • Better Emissions Inventories

Ozone Trends, San Antonio Region, 1980-2011

Types of Strategies: LOCAL • Industrial Controls • Energy Efficiency Projects • Mobile Source Controls • Fleet controls • Idling Reduction Programs • Diesel retrofits • Commute Solutions • Outreach • Ozone Awareness Programs Guy Donaldson, Chief, Air Planning Section, EPA Region 6, “State Implementation Plans,” http://blueskyways.org/meetings/webinar/june2.html

Air Quality Planning Flow Chart Is Air Clean? Gather Air Quality Data (Ozone Monitoring) And Track A.Q. Plan Progress Attainment & Maintenance YES NO Is Control Strategy Adequate? Estimate Current Emissions (Build Emissions Inventory) YES NO Develop Rules to Implement Controls Project Future Emissions Develop Base Case Model Develop Emission Control Measures Model Impact of Controls on Air Quality Implement Rules and Program Enforce Rules and Program

Ozone: Violations, NonAttainment & our Air Quality Future