SIP Challenges in Houston-Galveston-Brazoria. Chief Engineer s Office, Air Quality Division

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1 SIP Challenges in 2008 Houston-Galveston-Brazoria Chief Engineer s Office, Air Quality Division Susana M. Hildebrand, Air Quality P.E., Division Director HGB SIP Challenges in 2008 February 12, 2008 Page 1 February 12, 2008

2 SIP Challenges in 2008 Air Quality Status Ozone Standard Revision 185 Fees Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 2

3 Air Quality Status Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 3

4 Ozone Monitoring - Statewide Statewide there are 77 regulatory ozone monitors In reviewing the latest 4 th highest, 3-year average (2005, 2006, 2007) eight-hour ozone concentration: 61 monitors had lower values 8 monitors had the same value and at only 5 monitors was the value higher Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 4

5 Ozone Monitoring HGB Houston-Galveston-Brazoria (HGB) area has 25 federal reference monitors for ozone 24 monitors had lower design values 1 monitor had the same design value 0 monitors had higher design values 8 additional monitors in attainment Design value dropped from 103 to 96 ppb Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 5

6 HGB Area Submitted to EPA on June 15, 2007: Eight-Hour Ozone SIP Moderate (June 15, 2010, attainment date) Includes rule revisions and local emissions reductions but does not demonstrate attainment of the standard Reasonable Further Progress SIP Governor s request for reclassification from moderate to severe Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 6

7 HGB Reclassification EPA Proposal published in the Federal Register (December 31, 2007) to: Voluntarily reclassify the HGB ozone nonattainment area from a moderate to a severe area Attainment date: June 15, 2019 Comments for revised SIP: Dec. 15, 2008 April 15, 2010 TCEQ submitted comments to EPA (January 30, 2008) that: Support the reclassification and attainment by June 15, 2019 Provide justification for an April 2010 HGB SIP submittal date Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 7

8 Photochemical Modeling 2005 episode Including final base case, baseline, future baseline and future controls Estimated completion: August episode Estimated completion: March 2009 TexAQS II intensive period episodes (2006) meteorological and emissions modeling files will be included Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 8

9 What s Next? Establish a stakeholder group Meetings scheduled: March 25-6:30 p.m. March 26 9:30 a.m. Houston City Hall Annex Council Chamber, (900 Bagby Street) Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 9

10 Control Strategy Development and Rule Proposal Timeline Internal research and analysis of potential control strategies: August 2007 January 2008 Control strategy development: February 2008 March 2009 Rule proposal development: April 2009 August 2009 Internal Research Control Strategy Development Rule August January February March April August Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 10

11 SIP Development SIP Narrative Proposal development: April 2009 August 2009 SIP Proposal Agenda: October 2009 SIP Adoption Agenda: March 2010 Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 11

12 Ozone Standard Revision Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 12

13 Ozone NAAQS Current Ozone NAAQS: Eight-Hour Ozone: 0.08 ppm Proposed Changes to Ozone NAAQS: Eight-Hour Ozone: Range from ppm to ppm Also seeking comments on levels down to ppm and up to the current level of 0.08 ppm To be finalized March 2008 Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 13

14 New Rounding Conventions Note that the old eight-hour ozone standard is reported to two decimal places ppm 0.08 ppm ATTAINMENT ppm 0.09 ppm NONATTAINMENT The new standard: reported to three decimal places so rounding is no longer necessary: ppm ATTAINMENT ppm NONATTAINMENT Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 14

15 Counties Monitoring Over Current Ozone Standard of 0.08 ppm Region County Hr Ozone DV (ppb) BPA DFW DFW DFW DFW DFW DFW HGB HGB HGB SAN TLM JEFFERSON COLLIN DALLAS DENTON JOHNSON PARKER TARRANT BRAZORIA HARRIS MONTGOMERY BEXAR GREGG *Design Values based on average of 2004 to 2006 data. To exceed the current standard the design value must be greater than or equal to 85 ppb. Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 15

16 Counties Monitoring Over Proposed Revised Ozone Standard of ppm Region County Hr Ozone DV (ppb) AUS BPA DFW DFW DFW DFW ELP HGB TLM TLM TRAVIS ORANGE ELLIS HOOD HUNT ROCKWALL EL PASO GALVESTON HARRISON SMITH *Design Values based on average of 2004 to 2006 data. To exceed the new standard at 75 ppb the design value must be greater than or equal to 76 ppb. Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 16

17 Counties Monitoring Over Proposed Revised Ozone Standard of ppm Region County Hr Ozone DV (ppb) CC DFW VIC NUECES KAUFMAN VICTORIA *Design Values based on average of 2004 to 2006 data. To exceed the new standard at 70 ppb the design value must be greater than or equal to 71 ppb. Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 17

18 Ozone Standard Revision Conclusion At 0.08 ppm (Current Standard): 12 counties have design values that exceed At ppm: 10 additional counties have design values that would exceed At ppm: 3 additional counties have design values that would exceed Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 18

19 Eight-hour Ozone Proposal TCEQ commented: Studies supporting the lowering of the standard were not robust enough Any tightening of the standard must be clearly warranted and irrefutable based upon thorough scientific health data The current State Implementation Plan process must be thoroughly reconsidered and revised to have any hope in meeting a new standard in a timely manner Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 19

20 185 Fees Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 20

21 CAA Section 185 Fee Provision Applies to severe and extreme ozone nonattainment areas that fail to attain by their attainment date Requires major stationary sources of VOC (and NOx) to pay a fee to the State Fees for each calendar year after attainment date until area reaches attainment (e.g. for severe-15, sources subject to fee in 2006) Fee for failing to attain is $5,000* per ton of VOC, in excess of 80% of baseline amount, emitted by source in calendar year Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 21

22 How is Baseline Computed? Administrator may provide guidance as the lower of: Actual emissions for the source Emissions allowed under the permit or under the SIP in the attainment year, if no permit has been issued Guidance may authorize baseline amount to be the lower of averaged actuals or allowables over a period of more than one year Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 22

23 185 Fees: Conceptual Options Identified Option 1: emissions-based Option 2: fee-based Option 3: emissions and fee-based Option 4: fee-based program Option 5: let states base program on any combination of options 1-4 Option 6: give states the option of implementing CAA section 185 fee program Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 23

24 Contact Information Susana M. Hildebrand, P.E. Phone: Air Quality Division HGB SIP Challenges in 2008 February 12, 2008 Page 24

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