Implementation of 2015 Ozone Standard

Transcription

1 1 Implementation of 2015 Ozone Standard Rob Sliwinski Director, Bureau of Air Quality Planning May 20, 2015

2 2 New York s Recommendations Current levels inadequate to protect public and welfare Primary NAAQS: Support CASAC recommendation to revise to a level below 70 ppb Secondary NAAQS: Separate W126 seasonal cumulative index at 7 to 15 ppm-hrs (CASAC recommendation, but account for entire growing season). More monitoring would be needed for W126. Revision needed to avoid double-counting a single highozone event EPA proposal to ignore 8-hour blocks (12am-6am) is inappropriate Potential large difference e.g., 4 ppb at Whiteface, 2 ppb at Rochester Recommended approach that would monitor at all times but avoid using data twice

3 3 New York s Recommendations Two different monitoring seasons within NYC area. Disparity needs correcting. NY and NJ (March October) CT (April October) Design Value Monitor Need to address transport in a timely manner Need implementation guidance in a timely manner

4 4 Existing New York Ozone Programs VOC and NOx RACT on all major sources 25 tpy in NYC 50/100 tpy in rest of State Nonattainment NSR OTC NOx Budget/NOx SIP Call/CAIR/CSAPR OTC Architectural Coatings OTC Consumer Products Portable Fuel Containers Motor Vehicle I&M, inc. HDDVs CA LEV Personal Watercraft ( Jet-skis )

5 ( prelim. data) 5

6 6 Connecticut Contains New York City Area Design Value Monitor Connecticut 8-Hour Ozone Design Values for 2014 (Preliminary) Area Monitoring Station County 2014 DV (ppb) New York - N. New Jersey - Long Island, NY-NJ-CT Greenwich Fairfield 82 Danbury Fairfield 78 Stratford Fairfield 84 Westport* Fairfield 85 Middletown Middlesex 81 New Haven New Haven 76 Madison (combined) New Haven 81 *Design value monitor for NY-N.NJ-CT nonattainment area

7 7 Ozone Classification Percent above standard Area Classification NAAQS set at 70 ppb NAAQS set at 65 ppb Marginal 71 to to 75 Moderate 81 to to 87 Serious 93 to to 98 Severe to to 103 Severe to to 152 Extreme >163 >152

8 8 Implementation of 2015 Ozone NAAQS Designations States recommend by October 1, 2016 EPA Designations effective December 2017 Based on monitored data (2017 data?) State Implementation Plans (SIPs) Infrastructure SIP due October 2018 Includes transport portion which relies on modeled impacts to downwind areas. Attainment SIP due 3 years from designation (Dec. 2020) Attainment dates vary based on severity of problem: Marginal 2020, Moderate 2023, Serious 2026

9 9 Designation Classification is Critical for Effective Planning Subpart 2 contains specific requirements to assure that progress is made towards attaining ozone NAAQS Minimal requirements for marginal areas [ 182(a)] Graduated emission reduction programs starting with moderate areas [ 182(b)-(e)] Reasonable Further Progress reductions (3% per annum)

10 Designation Classification is Critical for Effective Planning Previous Attempts by New York to Expedite Planning Designated Marginal nonattainment for 2008 NAAQS Bump-up letters for NYC Area to moderate classification June 20, 2012: Based on modeling demonstrating severity of problem, and being within 5% of moderate classification threshold [ 181(a)(4)]. Also, requested voluntary reclassification [ 181(b)(3)] Re-request March 16, 2015: DC Circuit Court decision on attainment date, and ozone levels in moderate range 10

11 Designation Classification is Critical for Effective Planning NYC Area Failed to Attain by Marginal Deadline Incorrect designations delayed effective program development Attainment Deadline July 20, 2015 ( ) Up to 6 months (January 20, 2016) to be reclassified [ 181(b)(2)] New Attainment Plans due 18 months (?) (July 2017) Moderate attainment date July 20, 2018 ( ) Challenge to develop and implement meaningful plan to attain by moderate deadline 11

12 Addressing Transport is Critical for Effective Planning EPA has issued transport rules in past. NOx SIP Call (1998) for one-hour NAAQS CAIR (2005) & CSAPR (2011) for 1997 NAAQS Inability to address transport for the 2008 NAAQS has delayed implementation of effective program EPA has probably settled on a legal remedy (SCOTUS) to address transport Jan. 22, 2015 Good Neighbor EPA memo provided updated modeling/impacts for 2008 NAAQS EPA identified upwind states contributions to downwind areas nonattainment CSAPR update (w/ new modeling) to be proposed this year? 12

13 13 Addressing Transport is Critical for Effective Planning Good Neighbor SIP due 3 years after NAAQS adoption [ 110(a)(2)(D)] October 2018 States identify and control to address significant contribution to nonattainment and interference with maintenance, or; Timing is critical Attainment plans due 3 years from designation. (2 years after Good Neighbor SIPs) December 2020 Other mechanisms for addressing transport 126 petition EPA to directly regulate 176A expand OTR

14 14 Thank You Robert G. Sliwinski Director, Air Quality Planning NYSDEC 625 Broadway, Albany, NY (518) Connect with us: Facebook: Twitter: twitter.com/nysdec Flickr: