A Regional Response to New Air Monitoring Requirements Michael Koerber Lake Michigan Air Directors Consortium October 3, 2011

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

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

New Monitoring Requirements Pollutant Type Requirement Timeframe Carbon Monoxide Near-roadway 1 monitor at near-roadway NO2 site Jan 2015 (CBSAs > 2.5 M) Jan 2017 (CBSAs > 1 M) Nitrogen Dioxide 1 monitor in CBSA > 0.5 M Jan 2013 2nd monitor in CBSA > 2.5 M (or AADT > 250K) Community-wide 1 monitor in CBSA > 1 M Susceptible/vulnerable populations 40 additional sites nationwide Sulfur Dioxide Source/pop.-oriented 3 monitors in CBSAs with PEI > 1 M 2 monitors in CBSAs with PEI > 100K 1 monitor in CBSAs with PEI > 5K Ozone Rural areas, smaller cities 3 rural sites per state TBD (proposed) 1 monitor in MSAs between 50K and 350K Particulate Matter Lead Source-oriented 1 monitor near all point sources > 0.5 TPY Dec 2011 Airport special study Urban NCORE sites

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

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.”

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.

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

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)

NO2 Proposal: Phased approach with 1 NR site in Current Network Required Network PAMS Other Pop/NR/EJ Illinois 1 6 1/2/? Indiana 4 (+1 ind.) 1/1/? Michigan 5 1/3/? Minnesota Ohio 3 3/7/? Wisconsin 2 Subtotal 23 8/17/? Tribes TOTAL 25 Proposal: Phased approach with 1 NR site in 2-3 cities. Maintain/reduce network – satisfies population and EJ(?) requirements.

CO Current Network Required Network NCORE Other Near-Road Illinois 1 8 Indiana 5 (+1 ind.) Michigan 2 Minnesota Ohio 3 13 Wisconsin Subtotal 9 31 Tribes TOTAL Proposal: Scale back existing network - move monitors to near-roadway sites, as needed.

SO2 Proposal: No new sites (and scale back Current Network Required Network NCORE Other NAAQS Illinois 1 13 4 Indiana 7 (+17 ind.) 5 Michigan 2 Minnesota 6 Ohio 3 29 9 Wisconsin Subtotal 59 28 Tribes TOTAL 60 Proposal: No new sites (and scale back existing network) – NAAQS implementation based primarily on modeling

PM10 Proposal: Scale back existing network Current Network Required Network NCORE Other NAAQS Illinois 1 4 Indiana 15 (+5 ind.) ? Michigan 2 3 Minnesota 5 Ohio 33 Wisconsin Subtotal 9 64 Tribes TOTAL 66 Proposal: Scale back existing network

PM2.5 and O3 Question: Can we/should we cut PM2.5 and O3 now, in =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?

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

Next Steps Recent EPA actions encouraging Still need help…. 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