1. Front Range Ozone Update to the Colorado Directors of Environmental Health Mike Silverstein April 17, 2008

4. Year 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 # of days 2 3 2 0 9 3 2 7 22 0 3 9 Days Greater than 84 ppb at Denver Metro Sites Year 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 # of days 6 13 16 23 8 1 10 13 24 10 4 2 4 6 # of days now includes all Front Range sites

6. How Does Colorado Compare to Other Areas? Area2006 8-hr 1 st Max (ppb) # of days >85 ppb Los Angeles Metro13536 Houston11810 Atlanta Metro10811 St. Louis Metro9710 Kansas City Metro992 Denver Metro (RFN)945 Las Vegas944 Phoenix944 Salt Lake City902

7. The Early Action Compact for Ozone Numerous agencies signed on to the Compact in 2002 –Supported the planning efforts to comply with the federal ozone standard by 2007 Though the plan fell just short of the ultimate goal – 1 part per billion, –Numerous controls were implemented and emissions reduced More than 180 tons/day of VOCs More than 60 tons/day of NOx –Public health was likely improved The Compact terminated with EPAs formal designation of nonattainment on 11/20/2007 - Marginal A new plan is now required

8. Governor Ritters Directive Propose measures to reduce ozone further in the 2008 summer ozone season Submit a proposed plan to the AQCC by September 2008 to assure compliance with the federal standard Set a goal of reducing or eliminating ozone levels above 80 ppb Consider the addition of elements that would further reduce ozone levels in anticipation of a lower federal standard

9. Planning Goals Meet 1997 Ozone Standard (effectively 0.084 ppm) by 2010 –per Federal requirements Reduce or eliminate ozone values above 0.080 ppm –per Governor Ritters directive Begin laying the groundwork to prepare a plan to meet the new Ozone Standard (0.075 ppm) –per Governor Ritters directive

10. VOC Emissions – 2010 (4% reduction since 2006)

11. NOx Emissions – 2010 (8% reduction since 2006)

12. Some Nonattainment Implications Regions image Transportation conformity –Coordination between the transportation planning agencies – NFRMPO, UFR, DRCOG, CDOT – 30 years General conformity –Projects involving federal approvals have to undergo more extensive review and justification Long-term planning: 20 - 30 years –NFR, APCD, RAQC, Counties, Cities, Towns

13. Some Nonattainment Implications Siting of new industrial sources –New and modified major sources subject to more stringent New Source Review permitting requirements Lowest achievable emission rate Emission offsets –Smaller sources: APEN reporting thresholds reduced –1 tpy for VOC and NOx sources Permitting/RACT requirements more stringent –2 tpy VOC sources –5 tpy NOx sources

14. Process and Timeline for Developing an Attainment Plan Agency discussions and stakeholder meetings began Fall 2007 Technical work is underway Control measure options are under development –Measures will likely be proposed to go beyond 84 ppb Modeling and control strategy development will occur throughout 2008 A plan will be drafted and proposed to the AQCC by September 2008

15. Stakeholder Process for Developing and Attainment Plan All stakeholders invited to participate in a collaborative and open process –Government, environmental, nonprofit and other interest groups, business and industry, and citizens Stakeholder Workgroups: –Oil and Gas (VOCs) –Stationary Sources (VOCs) –Modeling and Technical Analyses –NOx –Mobile Sources/Fuels –Transportation Outcome-based process –Stakeholders work together to set goals and ensure they are met

16. Elements to be Addressed in the New Plan Complex technical analyses Control measures to meet the Governors directives – a suite of control options are under development –Stationary/oil & gas controls –Area/mobile/fuels controls –Contingency measures Setting of emission budgets for transportation conformity Demonstration of attainment by 2010

17. Next Steps April 2006/2010 base case modeling June 2010 sensitivity modeling AprilInitial strategy analyses complete May-AugustRAQC considers modeling and strategy analyses JuneMeet with NFRMPO June-August RAQC/APCD draft regulations September RAQC/NFR/APCD proposes draft plan/regulations to AQCC Oct.-Dec.AQCC prehearing process December AQCC hearing and SIP/regulation adoption January-May Legislative review July 1, 2009Deadline to submit plan to EPA

18. EPA Review of the Ozone Standard EPA is promulgating a new, more stringent 8-hour ozone standard –0.075 ppm or 75 ppb March 2009: States submit recommendations (2006- 2008 data) March 2010: EPA makes designations (2006-2008 & 2007-2009 data) March 2013: SIPs due to EPA 2015-2030: Attainment required (dependent on severity of the problem) Note: Potential litigation could delay this timeline

19. Days Above.075 ppm (Denver/North Front Range Area)

20. New standard: 3-yr avg. of 4 th max 8-hour < 0.075 ppm Counties violating: Larimer, Weld, Boulder, Jefferson, Arapahoe, Douglas