Yesterday, U.S. EPA announced its proposed non-attainment designations for counties not meeting the new P.M. 2.5 (fine particle) pollution standard. Ohio was second only to California in total counties designated non-attainment with 28 total counties.
A county's designation as non-attainment makes economic development efforts more difficult and increases competitive pressure on existing businesses. The designations mean regulatory restrictions on economic growth and increased pollution control compliance costs for existing businesses.
How is economic growth impacted? Before a company can build a new factory or expand, if that factory will result in a moderate pollution increase of fine particles it must offset that emission increase. An offset is achieved through pollution reductions from existing businesses already located in that county. The offset requirement, as part of U.S. EPA's New Source Review Program, acts as a strong disincentive to locate in non-attainment counties. The offset requirement only goes away if the county is redesignated attainment.
How does County get out of its non-attainment designation? Through reductions in fine particle pollution to levels that comply with the federal standards. Reductions are achieved through a combination of federal and state pollution programs. The State must develop a pollution control plan (SIP) that shows its strategy for achieving the federal air quality standard by the applicable deadline (2012).
What are the largest sources contributing to fine particle pollution? Transportation, in particular diesel engines and coal-fired power plants. While, fine particle pollution is more localized than ozone, it still has a regional component. Therefore, counties must see state and regional reductions in order to achieve the standard. (Note: the recent letter from State EPA heads to U.S. EPA)
How can Ohio and other states effectively achieve reductions from these sources? While U.S. EPA has adopted tougher standards for diesel engines, the reductions won't come until there is turnover in the fleet. Therefore, the full benefits may not be seen for 25 years. That is why programs like DERG that accelerate diesel reductions are so important. (see yesterday's post on Ohio's diesel grant program).
Furthermore, Ohio and the other state's efforts to meet the fine particle standard are further complicated by the court decision throwing out U.S. EPA's CAIR program. CAIR, as described by U.S. EPA, was the "linchpin" program designed to help states achieve attainment with ozone and fine particle standards. (see post "CAIR Decision Will Have Many Aftershocks")
Implementation of the new standard: Below is U.S. EPA's implementation schedule for both the old (65 ug/m3) and new (35 ug/m3) 24-hour fine particle standards. While Ohio submitted its SIP in July for the old standard it relied heavily upon CAIR. So, even for the old program Ohio's SIP will need significant revisions. It is yet to be seen how states can achieve either standard without regional reductions from coal-fired power plants. Unfortunately, it doesn't appear Congress is going to act quickly to provide relief to the States.
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Milestone
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1997 PM2.5 Primary NAAQS
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2006 PM2.5 Primary NAAQS
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Promulgation of Standard
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July 1997
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Sep. 2006
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Effective Date of Standard
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Sep. 1997
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Dec. 18, 2006
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State Recommendations to EPA
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Feb. 2004
(based on 2001-2003 monitoring data)
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Dec. 18, 2007
(based on 2004-2006 monitoring data)
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Final Designations Signature
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Dec. 2004
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No later than Dec. 18, 2008*
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Effective Date of Designations
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April 2005
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Typically no later than 90 days after publication in the Federal Register
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SIPs Due
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April 2008
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3 years after effective date of designations
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Attainment Date
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April 2010
(based on 2007-2009 monitoring data)
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No later than 5 years after effective date of designations
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Attainment Date with Extension
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Up to April 2015
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No later than 10 years from effective date of designations
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