Western Ozone Issues

1. Western Ozone Issues WESTAR Fall Business Meeting Salt Lake City, UT October 30, 2012 Colleen Delaney, Utah Division of Air Quality

2. History of Ozone SIP in Utah • Salt Lake and Davis Counties were nonattainment for the 1-hr ozone standard in the 1980s • Redesignated to attainment in 1997 • All areas in Utah were designated attainment/unclassifiable for the 1997 and 2008 ozone standards • Uintah Basin unclassifiable due to lack of 3 years of regulatory data • 1990s started to see increasing ozone in very remote western sites

3. 1-Hr Ozone Maintenance Area

4. Urban areas that are close to 2008 ozone standard

5. Winter time ozone in area with oil and gas development • Local issue not related to transport • May be a unique western issue related to climate and topography Uintah Basin

6. Ozone Transport Rural areas may exceed an ozone standard in the range of 60-70 ppb. High background ozone also affects urban areas.

7. Large areas of the state have limited ozone data

8. SIP Planning Overview • 110(a)(2)(D) Transport Demonstration for the 2008 ozone standard • Potential new primary ozone standard in 2014 • EPA was close to finalizing a primary standard of 70 ppb (8-hr average) in 2011 • CASAC recently recommended a range of 60-70 ppb for the primary standard, with consideration of even lower values between 50-60 ppb • Potential new secondary ozone standard • EPA was close to finalizing a secondary W126 standard of 13 ppm-hr in 2011 • Designations • Attainment/nonattainment area boundaries would need to be determined • Don’t want to base a SIP on episodes that are significantly influenced by emissions that cannot be controlled • As rural ozone becomes an issue we need a consistent approach for flagging data at CASTNET/other federal sites • State Implementation Plan for nonattainment areas

9. Nonattainment Areas 2008 Ozone Standard

11. Significant Issues from Ozone Transport Conference • Background ozone levels in the west are high. • Transport of ozone or precursors from Asia can have a significant impact, especially during the spring. • Asian impact is increasing • Impact is concentrated in western US • Stratospheric intrusion can have a significant impact, especially at higher altitude sites. • Very high impacts when a front moves through an area • Impact is not limited to that short-term event. Higher ozone occurs across a broad area for several days • Stratospheric intrusion and mixing occur on an on-going basis even without these events • Wildfires have a significant impact on ozone levels. Interannual variability corresponds to variability in fire. • Altitude and topography are important factors in ozone levels. • There is a lot of good research regarding what is contributing to ozone levels in the west, but the monitoring equipment and research centers are not widespread. • Funding for monitoring, research, and regional modeling is decreasing rather than increasing.

12. Significant Issues from Ozone Transport Conference • EPA’s regulatory efforts are focused on the problems in the east • Legal mechanisms to address transport from upwind states • CAIR/CSAPR – focus on power plants in the Midwest • Section 126 petitions • 110(a)(2)(d)SIP guidance • Ideas to address issues in the west are problematic • Exceptional events • Policy is based on the idea that these events are infrequent, but that is not the case for the significant sources (stratospheric intrusion, wildfire, asian transport) • Analysis requirements for demonstrations are unachievable for most events • It is too difficult to quantify the ozone levels “but for” the exceptional event • Nothing gets approved • Regulatory approaches to provide relief in “rural” areas don’t work in the west • Changes to EPA’s rules and guidance to address western issues could cause problems with strategies to reduce ozone in the eastern US • My recommendation - a separate western approach is needed

14. MSA’s are based on county boundaries Low population counties are considered “urban” under some EPA definitions because most of the people live in one small town

15. State Implementation Plan • Mandatory measures required by the CAA • Designed to solve urban ozone problem from 20 years ago • Focus on mobile sources and fuels • Nonattainment NSR – makes no sense in areas affected primarily by transport • Mandatory VOC reductions • Transportation and general conformity • Background levels are high – it may not be possible to show attainment in many areas • Mandatory bump-ups require more urban area controls • If a state can’t demonstrate attainment, then sanctions are applied • This process guarantees failure for many areas in the west

16. Secondary Ozone Standard • EPA proposed a new secondary standard to address impact of ozone on vegetation (W126 measures cumulative impact during the growing season) • Impact of this standard is unclear • Limited monitoring data in rural areas this standard is designed to protect • Effects on western vegetation are not well documented • Desert vegetation has different growth patterns • Altitude effects (large forested areas are at high altitude) • What about fire? • Areas will be designated nonattainment and a SIP is required • Implementation requirements not defined (Utah has no experience doing a SIP for a secondary standard) • Ozone transport into rural areas is a significant issue • How will this affect the large areas of federal land in the west? • General conformity • Western areas may never be able to meet the standard, even after significant emission reductions