1. Florida Department of Environmental Protection National Ambient Air Quality Standards being Strengthened --Implications for Northeast Florida-- Larry George Division of Air Resource Management July 16, 2010 2010 Jacksonville Environmental Symposium: Green City Gateway to Florida

2. What are National Ambient Air Quality Standards? Part of federal Clean Air Act since 1970. EPA establishes and periodically revises national ambient air quality standards (NAAQS) for six common air pollutants based on public health-related criteria. Pollutants are ground-level ozone (O 3 ), fine particulate matter (PM 2.5 ), sulfur dioxide (SO 2 ), nitrogen dioxide (NO 2 ), carbon monoxide (CO), and lead (Pb). State/local governments monitor air pollutant levels. If violation of NAAQS is measured, state must develop corrective plan (State Implementation Plan, or SIP) consisting of enforceable emission control measures, and submit plan to EPA for approval. 2

3. What Happens when EPA Revises a NAAQS? Nothing immediate; 2 years (usually) after promulgation of a revised standard, areas that violate the standard are designated “nonattainment” by EPA. Most NAAQS require 3 years of data to determine compliance or non-compliance; so, if standard is revised in 2010, EPA designates nonattainment areas in 2012 based on data for the 3-year period 2009-2011 (the “design value”). SIP “demonstrating attainment” is due 3 years (usually) after nonattainment designation (2015 in above example). For most pollutants, attainment deadline is 5 years after nonattainment designation (2017 in above case). For ozone, attainment deadline is 3, 6, or more years after designation, depending on severity of the area’s design value. 3

4. Status of NAAQS in N.E. Florida – Ozone & PM 2.5 Ozone is pollutant of primary concern for Florida. NAAQS for ozone will be strengthened Aug. 2010 (EPA is proposing 8-hr. standard in range of 60-70 ppb, compared to current 75 ppb). N.E. Florida, and many other areas of the state and country, could find themselves no longer in compliance. (2007-2009 design value for Jacksonville area = 70 ppb) NAAQS for PM 2.5 will be strengthened Oct. 2011 (annual standard in range of 11-13 ug/m 3 and 24-hr. standard of 30 ug/m 3 may be proposed, compared to current 15 and 35 standards, respectively). N.E. Florida may remain attainment. (2007-2009 annual and 24-hr. PM 2.5 design values = 9.0 and 21 ug/m 3, respectively, excluding wildfire impacts. While wildfire smoke is a health concern and included in Air Quality Index, it does not affect NAAQS status.) 4

5. Status of NAAQS in N.E. Florida – SO 2 NAAQS for SO 2 was strengthened in June 2010; EPA replaced annual and 24-hr. standards of 30 and 140 ppb, respectively, with new 1-hr. standard of 75 ppb. Nassau Co. monitor has violation of new SO 2 standard for 2007-2009, likely due to just one or two sources. Air quality status for new SO 2 standard will not be based on monitoring alone; by June 2013, states must demonstrate through refined air quality modeling that strong point sources of SO 2 emissions do not cause or contribute to violations of the standard. Implications of the modeling requirement are unclear at this time but could affect a number of areas beyond those currently showing monitored violations. 5

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7. Areas in red indicate the CBSAs above various ozone standards (between 60-70 ppb proposed, currently 75 ppb) based on 2007-2009 data.

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10. What is EPA Doing to Help Reduce O 3, PM 2.5 & SO 2 ? Clean Air Interstate Rule (CAIR) & proposed Transport Rule will produce substantial NO X and SO 2 emission reductions from power plants throughout the eastern U.S., reducing ambient concentrations of all three pollutants. (In the East, NO X is the primary “precursor” pollutant for ozone, and SO 2 is the primary precursor for PM 2.5 ) National diesel and gasoline fuel standards, and numerous EPA rules for stationary and mobile internal combustion engines will produce significant VOC and NO X emission reductions over time. (VOC is also a precursor for ozone) Proposed “boiler MACT” rule will produce significant SO 2 emission reductions from industrial facilities as a co-benefit of reducing toxic acid gases such as HCl. (This may help solve the Nassau County SO 2 problem) 10

11. Focusing on Ozone Ground-level ozone is formed when emissions of volatile organic compounds (VOC) react with emissions of nitrogen oxides (NO X ) in the presence of strong sunlight. (Should not to be confused with naturally occurring “good” ozone in the stratosphere that blocks UV radiation) NO X is primarily emitted from power plants, motor vehicles, other internal combustion (IC) engines and various industrial combustion sources. VOC is primarily emitted from natural sources (vegetation and soils); man-made sources include motor vehicles, other IC engines, gasoline evaporation, and use of solvents. Emission controls are generally aimed at both NO X and VOC, and at both stationary and mobile sources. 11

12. Timeline of Actions under Revised Ozone Standard Aug. 2010 – EPA finalizes revised standard. Jan. 2011 – States recommend areas to be designated “nonattainment” based on 2008-2010 data (usually core based statistical areas (CBSAs) with one or more violating monitors). Aug. 2011 – EPA makes nonattainment designations. Aug. 2011 – More stringent permitting rules for major VOC and NO x sources take effect (DEP rulemaking now underway). Aug. 2012 – Transportation conformity process begins. Dec. 2013 – SIPs due to EPA (modeling analysis now underway, rule development to begin next year). Dec. 2013, 2016, or later – Attainment deadline, depending on severity of design value. 12

13. If N.E. Florida Becomes Nonattainment for Ozone… EPA regulations (transport rule, mobile source standards, etc.) will be of primary importance in bringing area into attainment. Stricter permitting requirements for new major sources of VOC/NO X emissions will apply until area is redesignated as attainment. (Could slow some types of industrial growth) “Reasonably available control technology” for existing sources of VOC and NO X will apply. (Already in place in Duval County; would be expanded to other counties) Cleaner gasoline will be required during summer. (Already in use in Duval County; would be expanded to other counties) MPO and DOT must demonstrate that transportation plans & transportation improvement programs “conform” to SIP. (Formerly done in Duval County; would apply to all counties) 13

14. Redesignation to Attainment All monitors in the nonattainment area must show attainment over most recent three-year period. State must develop an “air quality maintenance plan,” demonstrating that area will remain in attainment over the next 10 years with continuation of selected control measures and transportation emissions budgets. EPA must approve maintenance plan before redesignating area to attainment. After redesignation, permitting requirements for new major sources revert to prevention of significant deterioration (PSD) program; transportation conformity process continues. 14

15. Myths about Being Nonattainment for Ozone Air pollution is getting worse. Fact: Ozone levels in N.E. Florida have come down a bit over past 20 years, but further improvement may be needed under revised NAAQS. It’s dangerous to go outside and breathe. Fact: High ozone levels occur only a few days per year; the Air Quality Index (AQI) alerts sensitive persons to limit prolonged, moderate exertion outdoors on those days. (The AQI also alerts persons to smoke from wildfires.) Nonattainment will hurt the local economy. Fact: Some industries may have to reduce emissions, but Florida cities have thrived during nonattainment periods in the past; e.g., S.E. Florida, Tampa Bay, and Jacksonville from 1978 through the mid-1990s 15

16. Other NAAQS Issues –NO 2 and CO NAAQS for nitrogen dioxide (NO 2 ) strengthened in Jan. 2010 with adoption of new, 100 ppb 1-hr. standard; Florida has no nonattainment areas based on current urban-scale monitoring network. EPA will designate most of the country “unclassifiable” for NO 2 pending collection of data from new roadside monitors required to begin operation by Jan. 2013; implications of roadside monitoring are unclear at this time, but modeling against new standard is proving tough for some stationary sources. NAAQS for carbon monoxide (CO) will be revised May 2011. EPA may require new roadside monitoring for this pollutant as well. 16

17. Other NAAQS Issues – Lead (Pb) NAAQS for lead (Pb) was strengthened in Oct. 2008 from 1.5 ug/m 3, quarterly avg., to 0.15 ug/m 3, 3-mo. avg. EPA will designate small area of Tampa nonattainment; the problem there should be corrected by a project now underway to rebuild and modernize a secondary lead smelter in the area. EPA is concerned about the air quality impacts of leaded gasoline being used in piston engine aircraft and may propose a phase-out of leaded aviation gas. In the meantime, EPA is requiring placement of new ambient monitors for Pb near high-volume general aviation airports (e.g., Daytona Beach). 17

18. Need Further Information? Information on the NAAQS, including the health effects of ozone, PM 2.5, SO 2 and other criteria pollutants, is available at the EPA website: www.epa.gov/air/criteria.html. For each pollutant, drill down to Regulatory Actions for the latest information. www.epa.gov/air/criteria.html Air quality monitoring data and related information is available at the DEP Division of Air Resource Management website: www.dep.state.fl.us/air.www.dep.state.fl.us/air Feel free to contact me at: larry.george@dep.state.fl.us or 850-921-9555.larry.george@dep.state.fl.us 18