Chapter 3: Air pollution control laws and regulations, Air pollution control philosophies

3.1 Us Air pollution laws and regulations Most air pollution control engineers works with permits and also the major facilities These permits are authorized by local, state, or federal authorities, normally, expressed as: The emissions of pollutant X from the main stack factory Y shall not exceed Z pound per hours

Federal regulations direct the states to require a permit for each facility that has the potential to emit 100 tons/ Yr or 25 ton/ Yr of Hazardous

3.2 Air pollution control philosophies The main wish is to have a completely un-polluted environment at no cost to any one The logic is to have appropriately clean environment with appropriate cost distributed among industry car owners and other sources of pollutants

3.3 The four philosophies The regulations often based on mixture of philosophies such as 1- Emission standards 2- Air quality standards 3- Emission taxes 4- Cost- benefit standards

3.3.1 The emission standard philosophy The maximum emissions of different classes will keep the pollution emission rate at lowest possibility and each class is required to limit emissions to this maxima So if this philosophy is followed we will have the cleanest possible air The cleanest possible air philosophy

Best technology type The alkali acts in England followed the Leblanc process for manufacturing an alkali soda ash Na 2 CO 3, HCL as byproduct was emitted of the smokestack of the plant Legislations led to "Alkali inspectors" who their duty was to regularly inspect all alkali plants and to find the best technique for minimizing the emission Then enforcing the other plants to adopt the best technology

The best technology is still widely used specially in cases where determining the emission rate in pound per hours would be difficult i.e- large gasoline storage tanks open burning of garbage and agricultural wastes Emission standards is applied to regulate the emission of pollutants from the chimneys of industrial plants i-e Visible emissions from the chimney of coal- burning furnaces are indicative of re-emissions of air particles regulations limiting these visible emissions are of a form of emission standard

Fuel sulfur content and gasoline olefin content and oxygen content minima are of emission standard Because S → SO 2 Olefins →photochemical smog Increasing O 2 implies Decreasing CO emission All these kinds of emission standards have the same general idea: There is some degree of emission control that it is practical to impose upon all members of a well- defined class of emitters and that degree of control is required of all members of that class

This philosophy was the basis of most of the air pollution activities in the industrial world from In U.S air pollution law two sections are "pure" emission standards New source performance standard "NSPS" NESHAP

3.3.11: Advantages and disadvantages of emissions standard The cost effectiveness of the emission standard philosophy is bad. i.e. if the same emission standard were applied for a specific class of emitters, for both remote location and in those in industrial densely populated areas, then for a stringent standard, the remote plants will make large expenditure to produce a small reduction in damage to receivers and hence a small benefit.

The simplicity of the emission standard philosophy is excellent, the entire set of regulations consist s of the permitted emission rates and the description of the test method to be used to determine whether the emission standards are being met The enforceability of the emission standard philosophy is excellent, once the standards are set and tests methods defined, one knows whom to monitor and for what.

The flexibility of this philosophy is poor, if a plant orders pollution control equipment, and the equipment fails to meet the manufacturers predicted performance criteria ( and hence the emission standards) it may take years to replace it. Q. how should the air pollution control authorities deal with this plant. Under this philosophy, they can ……..

The evolutionary ability of this philosophy is fair, if a new technology makes it possible to set a lower standard, it can be implemented for all sources built after a certain date.

The Air Quality Standard Philosophy -Emission standard philosophy is a ”cleanest possible air” -The Air Quality Standard Philosophy is a “zero-damage” -What is the relation between threshold values and the philosophy of The Air Quality Standard Philosophy?

*The idea of threshold values that which no air pollution damage would occur *The air quality standard philosophy is based on the assumption that the true situation for most major air pollutant is the threshold value situation.

The U.S air pollution community is trying to do precisely that, by carrying out the basic air quality standard philosophy of the Clean Air Act To apply this philosophy must study the " available dose-response data and determine the threshold values National ambient air quality standards (NAAQS) –which are maximum allowable level of contamination & EPA established such standards for six major pollutants The process of setting these standards calls for issuing documents called "Air Quality Criteria " for which reason the pollutants on this list are called " Criteria pollutants"

The states are now attempting to manage air quality to ensure that those standards will not be exceeded, ever, any where To procedure is illustrated in flowchart in fig.(3.2) This process was initiated in the United States in April 1971 In 2000, 25 years after the original deadlines, many of the standards have not been met in the regions with the most difficult problem. For the most part we failed to meet the standards because we underestimate the total emissions, overestimate the efficacy of control measures, and used optimistic models to predict future air quality

The states and the EPA are now on their third or fourth time around the loop shown in fig(3.2) trying to bring the ambient air pollutant concentration down to the NAAQS. These simulation apply for each of the six pollutants for which we have NAAQS and in each Air Quality Control Region(AQCR) in each states, the process continues until such time as the air becomes as clean as the standards require

The advantages and disadvantages of the air quality standards philosophy This philosophy cost effectiveness is good but not excellent* *Require some control expenditures for which the damage reduction benefits are small No one has found away to write a simple set of regulation based on this philosophy *EPA's efforts to write a simple set of regulation *The reason of this complexity is that we are attempting to control the concentration of pollutants in the ambient air

The enforcement difficulty of this philosophy results from the save cause as its complexity The flexibility of the air quality standard philosophy is far (why?) Because of the multiple way by which air quality standards can be met The evolutionary ability of the air quality standards philosophy is fair. As new data appear The most difficulty which led to court action in the United States,concerns nondegradation or nondeterioration

Emission Tax Philosophy -The two philosophies discussed next are not in use to any significant extent any where in the world, but rather are ideas that have had theoretical discussion in academic journals. -They represent future alternatives.

Laws based on an emission tax philosophy would tax each emitter of major pollutants according to its emission rate; – e.g. X cents per pound of pollutant Y for all emitters. This tax rate would be set so that most major polluters would find it more economical to install pollution control equipment than pay the taxes. Emission Tax Philosophy

Emission taxes have also been proposed in combination with air quality standard philosophy : in this combination, emission taxes would act as an added incentive to reduce emissions to lower levels than those required to meet air quality standards. Air Quality Standard and Emission taxes would work in parallel. Emission Tax Philosophy

Emission Tax is a member of a larger class philosophies called economic incentives. The other members of this class are: - Tax rebates - Low-interest-rate loans from the government for the installation of air pollution control equipment. - Direct public subsides for pollution control. Emission Tax Philosophy

The emission tax philosophy assumes that the environment has natural removal mechanisms for pollutants (with CFCs as possible exception) and at any particular contaminant level the environment has a finite, renewable absorptive or dispersive capability.

Emission Tax Philosophy If we take that view and apply the pure form of emission taxes, then we accomplish two desirable results: First: The degree of pollution control by individual firm becomes an internal economic decision. There will be competition between firms to reduce the emission for lower tax. Second: Minimize the misallocation of pollution control

Emission Tax Philosophy Making the decisions whether or not to control the pollution and what the degree of control should be is a matter of the internal economics of major emitters would probably result in a better overall cost effectiveness than is possible with uniform emission standards. Industry has complained about their difficulties with changing standards ( shooting at a moving target)

4- Cost-Benefit Philosophy The cost benefit approach assumes that either there are no thresholds or, if there are, they are low enough that we cannot afford to have air that clean. Then we must accept some amount of air pollution damage to someone, somewhere.

This philosophy suggests that we attempt to decide in as rational a manner as possible, – how much damage we should accept and – how much we should be willing to spend to reduce damages to this level.

The idea is illustrated in Figure below :

The ambient air concentration can be reduced by air pollution control expenditures. The control cost goes up steeply as the ambient air concentration becomes small. The sum of the two costs has a Minimum value,when the slopes of the two cost curves are equal and opposite

The minimum occurs when the slopes of the two costs curves are equal and opposite Or in mathematical expression d( pollution control costs + pollution damage costs) =0 d (ambient air pollution concentrations)

The figure is great simplification, it shows one control cost curve One damage cost curve And one atmospheric concentration In reality there is: a damage curve for each individual exposed to air pollution Control curve for each emitter And concentration dimension for each pollutant at each location

The simple application shown in the figure 3.3 and equation 3.3 does not consider the question : “” Whose costs? Whose benefits? ‘’

This approach is frequently criticized by those who say: “ You can’t reduce X to monetary term”, Where X may be human health, human life, or the quality of a clear sky, or air pollution damage to the cathedrals of Europe. Etc…

Comparison of the four philosophies

Palestinian Environmental law No. 7 (1999) الفصل الثاني : البيئة الهوائية مادة ( 19) أ ‌. تحدد الوزارة بالتعاون مع الجهات المختصة المقاييس المتعلقة بضبط نسب ملوثات الهواء التي قد تسبب الأذى والضرر للصحة العامة أو الرفاه الاجتماعي أو البيئة. ب ‌. على كل منشأة تقام في فلسطين أن تلتزم بهذه المقاييس، وعلى المنشآت القائمة تعديل أوضاعها بما يتفق وهذه المقاييس خلال فترة زمنية لا تزيد عن ثلاث سنوات. The Ministry, in cooperation with the specialized agencies, shall specify standards to regulate the percentage of pollutants in the air which may cause harm or damage to public health, social welfare and the environment; Each facility, which will be established in Palestine, shall abide to these standards; every existing facility shall make necessary changes in a manner that makes it conform to these standards within a period, which does not exceed three years. 42

Palestinian Environmental law No. 7 (1999) الفصل الثاني : البيئة الهوائية مادة ( 20) على صاحب المنشأة توفير سبل الحماية اللازمة للعاملين والمجاورين للمنشأة تنفيذا لشروط السلامة والصحة المهنية ضد أي تسرب أو انبعاث لأي ملوثات داخل مكان العمل أو خارجه. Every facility owner shall provide all means to ensure the necessary protection for workers and the neighbors of the facility, in compliance with the conditions of occupational safety and health, against any leak or emission of pollutants in or out the working place. 43

Palestinian Environmental law No. 7 (1999) الفصل الثاني : البيئة الهوائية مادة ( 21) يحظر التدخين في وسائل النقل والأماكن العامة المغلقة. It is forbidden to smoke in transportation means and closed public areas. 44

Palestinian Environmental law No. 7 (1999) الفصل الثاني : البيئة الهوائية مادة ( 22) لا يجوز استخدام آلات أو محركات أو مركبات ينتج عنها عادم يخالف المقاييس المحددة بموجب أحكام هذا القانون.. It shall be prohibited to utilize machines, engines or vehicles that generate exhaust that does not comply with the standards specified in accordance with the provisions of this law. 45

Palestinian Environmental law No. 7 (1999) الفصل الثاني البيئة الهوائية مادة ( 23) يحظر إلقاء أو معالجة أو حرق القمامة والمخلفات الصلبة إلا في الأماكن المخصصة لذلك، وفقاً للشروط المحددة من قبل الوزارة بما يكفل حماية البيئة. 46

Palestinian Environmental law No. 7 (1999) الفصل الثاني البيئة الهوائية مادة ( 24) تعمل الوزارة على الحد من استنزاف طبقة الأوزون وفقا لما نصت عليه المعاهدات الدولية التي تلتزم بها فلسطين وذلك باتخاذ الإجراءات المناسبة فيما يتعلق باستيراد أو إنتاج أو استعمال أية مواد كيماوية تسبب ضررا لذلك. 47