Inventory Needs and Legal Requirements Martin Johnson Emission Inventory Workshop Air Resources Board March 13, 2006

Air Resources Board Emission Inventory Workshop Spring Presentation Outline Who Uses the Inventory? How is the Inventory Used? Agency Responsibilities Legal Requirements Reporting Guidelines and Requirements ARB Audit Program

Air Resources Board Emission Inventory Workshop Spring Inventory Users Local air districts ARB and other state agencies USEPA Industry Consultants Academics Environmental Groups Public

Air Resources Board Emission Inventory Workshop Spring Inventory Applications Emission Trend Studies State Implementation Plans (SIPs) Control Measure Development Regional Air Quality Modeling Neighborhood Level Studies (EJ) Cumulative Risk Analyses Public Information Requests

Air Resources Board Emission Inventory Workshop Spring Upcoming Inventory Priorities 8-Hour Ozone SIPs – Districts with Nonattainment Designation Preliminary modeling inventories completed Dec-2005 Completing planning projections now SIPs due to EPA June 2007 PM2.5 SIPs - SC, SJV Preliminary modeling inventories completed Dec-2005 Completing planning projections now A few external adjustments anticipated SIPs due to EPA April 2008 Regional Haze SIPs Western Regional Air Partnership (WRAP) Draft 2018 Milestone Projections completed Nov attainment SIPs due to EPA Dec 2007 Statewide Risk Modeling - all districts Fall 2006 (Tentative)

Air Resources Board Emission Inventory Workshop Spring Agency Responsibilities for Inventory Development Local Air Districts Point sources Some areawide source categories ARB On-road vehicles (EMFAC) Off-road and other mobile (OFFROAD) Some areawide source categories ■ Transition Categories ■ Statewide methodology for Ships for Goods Movement Areawide source categories by agency available at:

Air Resources Board Emission Inventory Workshop Spring Legal Requirements State Health and Safety Code California Clean Air Act AB 2588 “Hot Spots” Act ARB Environmental Justice Policies Federal Clean Air Act Amendments Federal Consolidated Emissions Reporting Rule (CERR) Air Emissions Reporting Requirements (AERR)

Air Resources Board Emission Inventory Workshop Spring State Health and Safety Code ARB has responsibility for development of State Implementation Plans (Section 39602) ARB must inventory all sources of air pollution and use local agency data to fullest extent possible (Section 39607(b)) Districts have power to require facility operators to provide emission inventory data (Section 40701(g))

Air Resources Board Emission Inventory Workshop Spring California Clean Air Act Adopted in 1987 Requires all areas of the State to attain state standards as soon as possible (all feasible measures) Limited to criteria pollutants Authorizes ARB to require districts to impose fees on sources > 250 TPY of any nonattainment pollutant Authorizes ARB to impose fees on consumer product and architectural coating manufacturers that sell a product in California resulting in emissions > 250 TPY of VOC

Air Resources Board Emission Inventory Workshop Spring AB 2588 “Hot Spots” Act Passed in 1987 Limited to toxics pollutants Objective is to reduce toxics risk from individual facilities Includes public notification process Quadrennial reporting schedule Fee schedule adopted to support program Risk-based program (i.e. not emission-based)

Air Resources Board Emission Inventory Workshop Spring ARB Environmental Justice Policies Adopted in 2001 In response to SB 115, EJ must be considered in development, adoption, implementation, and enforcement of environmental laws and regulations ARB must assess, consider, and reduce cumulative emissions, exposures, and health risks

Air Resources Board Emission Inventory Workshop Spring Federal Clean Air Act Amendments Passed in 1990 Limited to criteria pollutants Affects states with nonattainment areas Requires submittal of comprehensive, accurate, and current emission inventories as revisions to SIPs

Air Resources Board Emission Inventory Workshop Spring Federal Consolidated Emissions Reporting Rule CERR adopted in 2002 Limited to criteria pollutants Large point sources must report annually (threshold varies) All other sources must report every three years 2002 inventory submitted June 1, inventory to be submitted June 1, 2007

Air Resources Board Emission Inventory Workshop Spring Air Emissions Reporting Requirements Replaces CERR Rule to be phased in by 2011 Accelerated reporting schedule to EPA e.g data would be due on June 30, 2011 Until 2011, EPA plans on scaling back the requirements under the CERR

Air Resources Board Emission Inventory Workshop Spring Reporting Guidelines and Requirements ARB CEIDARS Reporting Guidelines AB 2588 Reporting Requirements rrent rrent USEPA CERR

Air Resources Board Emission Inventory Workshop Spring ARB CEIDARS Reporting Guidelines Guidelines, not legal requirements Published every year Criteria and toxics pollutants Basis for annual submittals to CEIDARS database

Air Resources Board Emission Inventory Workshop Spring Point Source Criteria Reporting All New or Closed Point Sources Every year Point Sources > 10 TPY Every year Point Sources < 10 TPY Every 3rd year (2005 base year next)

Air Resources Board Emission Inventory Workshop Spring Point Source Toxics Reporting Report high-risk facilities annually Risk 1 in a million; or 10 TPY of any single HAP; or 25 TPY of any combination of HAPS Report AB2588 facilities annually Needed for toxics inventory, HARP, Community Health, CHAPIS, NEI

Air Resources Board Emission Inventory Workshop Spring Criteria for Facility Updates Missing and incorrect data emissions, codes, spatial Change in criteria emissions 5% or 10 TPY change Change in toxics emissions 10% change in process rate Addition or removal of device or process since last year

Air Resources Board Emission Inventory Workshop Spring Area Source Updates Districts requested to update 1/3 of their area sources annually Recognize resource intensive ARB on-line clearinghouse of district methodologies Encourage all districts to submit methodologies to assist others

Air Resources Board Emission Inventory Workshop Spring Reporting Methods Prefer electronic submittals Batch HARP CEIDARS Web Forms QA report tools are available on the web for districts to help correct errors

Air Resources Board Emission Inventory Workshop Spring Merged Criteria and Toxics ARB still in the process of merging criteria and toxics databases Districts requested to submit merged data ARB willing to assist with mergers

Air Resources Board Emission Inventory Workshop Spring Important District Deadlines November 1, 2006 Submit point and area source updates for 2005 inventory year Feb 15 – Apr 30, 2007 QA Review Period for 2005 inventory June 1, 2007 Final 2005 inventory frozen and provided to NEI

Air Resources Board Emission Inventory Workshop Spring District Audit Program ARB staff audit all aspects of district programs Includes AB 2588 and emission inventory Based on CEIDARS reporting guidelines All districts audited Audit frequency function of nonattainment status Results published in report provided to ARB and district upper management

Air Resources Board Emission Inventory Workshop Spring Summary Improved air quality is top public priority SIPs and other control programs need complete and current inventories District and ARB partnership critical Some legal mandates require district cooperation and assistance