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EPA Changes Ozone Standard; Administrator Proposes New Guiding Principles for Clean Air Act
13 March 2008
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| Counties in violation of former 0.08 ppm standard (top) and counties in violation of new 0.075 ppm standard, based on recent data (bottom). EPA will not designate nonattainment areas for the new standard based on those data, but on newer data. Click to enlarge. |
The US Environmental Protection Agency (EPA) has established a new primary 8-hour standard for ozone of 0.075 parts per million (ppm), and a new secondary standard set at a form and level identical to the new primary standard. The previous primary and secondary standards were identical 8-hour standards, set at 0.08 ppm. Because ozone is measured out to three decimal places, the standard effectively became 0.084 ppm; therefore, areas with ozone levels as high as 0.084 ppm were considered to have met the 0.08 ppm standard, due to rounding.
The new standard is at the higher end of options proposed by EPA staff scientists in a paper submitted last year (earlier post), and falls above the standard recommended by scientific and medical groups, including the Clean Air Scientific Advisory Committee (CASAC) which assists the Administrator of the EPA.
In the staff document, EPA staff recommended that consideration be given to setting the primary standard within the range of somewhat below 0.080 ppm to 0.600 ppm, “reflecting our judgment that a standard set within this range could provide an appropriate degree of public health protection and would result in important improvements in protecting the health of sensitive groups.”
Standard levels within this range that were considered in staff analyses of air quality, exposure, and risk include 0.074, 0.070, and 0.064 ppm, representative of levels within the upper, middle, and lower parts of this range, respectively.
...A standard set in the lower part of the range would place relatively more weight on the evidence from the controlled human exposure studies showing lung function decrements and respiratory symptoms in some healthy adults at 0.060 ppm O3, as well as evidence from epidemiological studies showing an array of respiratory morbidity effects occurring at levels below the current standard. It would place relatively less weight on the uncertainties associated with the exposure and risk estimates, and reflect the greater importance, from a policy perspective, of the public health implications of exposures at the 0.060 ppm benchmark level.
—Final Staff Paper, July 2007
Staff also had recommended earlier a different secondary standard to protect against ozone damage to public welfare, including damage to plants, concluding that even when the current primary standard is attained, significant environmental effects continue to occur.
The Clean Air Scientific Advisory Committee (CASAC) to the Administrator had unanimously made a stronger recommendation, stating that “the current primary ozone NAAQS be revised and that the level that should be considered for the revised standard be from 0.060 to 0.070 ppm.”
Medical and public health organization supporting a 0.060 ppm primary standard included: American Academy of Pediatrics; American Association of Cardiovascular and Pulmonary Rehabilitation; American College of Chest Physicians; American College of Preventive Medicine; American College of Occupational and Environmental Medicine; American Heart Association; American Lung Association; American Medical Association; American Nurses Association; American Public Health Association; American Thoracic Society; Asthma and Allergy Foundation of America; National Association for Medical Direction of Respiratory Care; National Association of City and County Health Officials; Physicians for Social Responsibility; and Trust for America’s Health.
In announcing the new ozone standard, Administrator Stephen Johnson also said that he will be sending Congress four principles to guide legislative changes to the Clean Air Act.
The four principles outlined by the Administrator recommend that the Clean Air Act and the National Ambient Air Quality Standards (NAAQS):
Must protect the public health and improve the overall well-being of our citizens;
Should allow decision-makers to consider benefits, costs, risk tradeoffs, and feasibility in making decisions about how to clean the air;
Should provide greater accountability and effective enforcement to ensure not only paper requirements but also air quality requirements are met, especially in areas with the furthest to go in meeting our standards; and
Should allow the schedule for addressing NAAQS standards to be driven by the available science and the prioritization of health and environmental concerns, taking into account the multi-pollutant nature of air pollution.
EPA estimates that the final standards will yield health benefits valued between $2 billion and $19 billion. Those benefits include preventing cases of bronchitis, aggravated asthma, hospital and emergency room visits, nonfatal heart attacks and premature death, among others. EPA’s Regulatory Impact analysis shows that benefits are likely greater than the cost of implementing the standards. Cost estimates range from $7.6 billion to $8.5 billion.
The new ozone rule and the proposed guiding principles for the Clean Air Act triggered a strong negative reaction from the American Lung Association, among others.
We wish we could be happier about this decision, but we cannot. The standard announced today, although an improvement, falls far short of the requirements of the Clean Air Act. We are unable to celebrate half measures when the risks are so evident, when the science and the scientists are so united about what is needed and when the missed opportunity means that thousands will suffer more and die sooner than they should. Furthermore, we reject the suggestions made by the Administrator to weaken and undermine the Clean Air Act itself. Coming from the head of the Environmental Protection Agency, such suggestions are truly outrageous.
According to the nation’s landmark air pollution law, the Clean Air Act, the EPA must set our air quality standards at levels that protect the health of the public, including children, older people, and people who suffer from chronic lung diseases. The EPA’s own expert scientific advisors unanimously recommended a stronger standard that would provide much more protection—advice the Agency ignored. Sixteen major medical societies and public health organizations—including the American Lung Association—repeatedly urged the EPA to follow the overwhelming evidence for a truly protective standard. Our recommendations also went unheeded.
Instead of following the law, the Administrator has proposed, incredibly enough, dismantling the core principles that are embodied in the Clean Air Act—legal requirements that have enabled us to reduce deadly forms of air pollution. The Administrator offers to play “pick your poison” with public health, allowing the state and local governments to determine which pollutants to ignore and which to clean up. The Clean Air Act recognized these pollutants as the national priority because they were the most widespread and dangerous. The Act assigned the EPA Administrator the responsibility to set standards to protect the health of all of the public from these pollutants, not just some people, and required the states and local governments to reduce the burden of all these pollutants, not just some of them. History has shown that when communities pick and chose who gets protected, those left behind, exposed to the worst, are usually the weak, the young, the old and those who face life-threatening disease. The Administrator cannot promote such discrimination.
...Despite arguments from polluters, thirty years of evidence shows that protecting public health has not harmed the economy—nor is it likely to do so in the future. We would encourage the Administrator to read his own website to see the EPA chart documenting that we’ve been able to cut emissions by half while the economy soared.
Given the real dangers to the most vulnerable members of each of our families, EPA’s decisions today represent a compromise the public can ill afford. The Agency moved closer to the need but not only failed to follow the law, the Agency is now supporting fundamentally weakening the Clean Air Act itself.
—Bernadette Toomey, President and Chief Executive Officer, American Lung Association
Resources
Final Staff Paper, Updated July 2007, EPA report No. EPA-452/R-07-007a
March 13, 2008 in Emissions, Policy | Permalink | Comments (20) | TrackBack (0)
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Comments
I understand it varies widely by location, but I'm very curious about the source for the ozone in the air. What percent is:
* autos & pickups
* multi-axle trucks
* rail
* port & water vessel
* electric power plant
* other things I didn't think of... :)
My thinking is: if renewable electricity generation continues to grow, how does that change things? Does the lower standard provide another financial incentive to move toward cleaner energy in and of itself? What can states to do help move those counties in the right direction? What if the ozone is coming from across the state border?
Posted by: stomv | Mar 13, 2008 8:47:04 AM
If you ask a medical doctor, any airborne pollutant that can cause or aggravate any respiratory ailment must be reduced or eliminated at virtually any cost.
However, as with almost everything, these efforts are subject to the law of rapidly diminishing returns once ambient pollutant concentrations reach extremely low levels. Meanwhile, complaints about picking and choosing which compounds to do something about miss a critical issue: overall indoor air quality - at home, at work or inside (new) vehicles - is usually many times worse than outdoor air quality.
Moreover, efforts to reduce pollutant concentrations ad infinitum have historically led to an upward spiral in fuel consumption. For example, gasoline-powered cars have to wastefully run stoichiometrically rather than lean in part load purely to satisfy the operating parameters of three-way catalysts for NOx reduction.
Lean NOx traps now exist but they are expensive and highly susceptible to reduced life expectancy related to sulfur poisoning and purges. EPA Tier 2 limits US gasoline to 30ppm on average, twice the level permitted for ULSD and therefore, too high to apply LNT technology broadly. Fortunately, there are other - less effective - approaches to improving the fuel economy of gasoline engines but they are also all quite expensive.
http://www.epa.gov/tier2/frm/fr-t2reg.pdf
Ground-level ozone is created naturally by sunlight in the summer months. The human species has evolved to cope with naturally occurring levels, but ozone also converts harmless NO from various combustion processes (especially, vehicle engines) into noxious NO2. This summer smog can easily accumulate to dangerous levels in locations prone to inversion layers, e.g. the LA basin and the SF Bay Area.
Present efforts to further reduce NOx emissions, e.g. the ZEV mandate, directly or indirectly lead to even greater dependence on OPEC oil and even more global warming. Car makers can only meet ZEV quotas and still turn a profit if they increase the number of highly profitable but gas-guzzling trucks and SUVs they sell. An increasing number of people would argue that this is moving us 180 degrees in the wrong direction, that our environmental priority should be to reduce the consumption of fuels - especially fossil fuels.
Already, many members of the general public have - rightly or wrongly - decided that energy dependence is linked to islamist terrorism and to military action intended to fight it. Likewise, many have - rightly or wrongly - decided that global warming is not only real but a serious multifaceted threat to Western civilization as we know it.
Both phenomena have already increased the general level of anxiety in the population just as surely as the fear of nuclear armageddon did during the Cold War. Even mild anxiety can be a problem if it's chronic, leading to psychosomatic effects like occasional insomnia, reduced appetite, reduced libido, even weakened immune response or gastric malfunctions in susceptible individuals.
Policies, innovations and corporate actions that effectively address energy supply and demand are the best way to address these new sources of anxiety. For example, growing energy crops like miscanthus or algae in California's Central Valley would boost the local economies of Sacramento, Fresno and Bakersfield, making them more attractive places to live and work. This would ease population pressures on LA and the Bay Area and the associated mobility nightmares, real estate bubbles etc.
It would also increase the value of the proposed high speed rail system. While its primary intent is to avoid the expansion of highways and runways, it would also help keep local NOx emissions in check, reducing the need to enact stricter emissions regs per vehicle. As in mathematics, sometimes the easiest way to solve a problem is to complexify it.
Mental health is no less important than its respiratory counterpart. Perhaps the good doctors would benefit from taking a broader, more interdisciplinary view of general population health rather than focusing narrowly on the implementation of the Clean Air Act.
Posted by: Rafael Seidl | Mar 13, 2008 10:00:58 AM
The lower map includes the San Joaquin valley in the center of California, where all the fruit and nut trees grow. You would think that they would have clean air there, but they get most of the Bay area smog and a lot from Fresno, the nearby city. Dilution is not a solution to pollution. It goes everywhere and ends up against the foothills from the prevailing winds. The same is true of San Bernardino in the southern part of the state. They get L.A. and Orange County smog.
Posted by: sjc | Mar 13, 2008 11:14:18 AM
Rafael: One of your more interesting posts. It will require some time to digest.
Posted by: Neil | Mar 13, 2008 12:52:38 PM
@ Rafael -
I agree with you.
One comment on your post...
You're correct that NO (the main form of NOx from combustion processes) reacts with ozone (O3) to form NO2 (and molecular oxygen - O2). However, as you can see, this is actually an ozone DESTRUCTION process. The NOx photolytic cycle produces only a tiny steady-state amount of O3 (depending on the NO:NO2 ratio of the NOx emissions), no matter how high ambient NOx levels get.
The problem as far as ambient ozone accumulation is concern is hydrocarbon emissions (and to some extent CO emissions). Products from the oxidation of HC in the atmosphere (peroxy radicals) compete with O3 to oxidize NO to NO2 and thus allow O3 to accumulate in the atmosphere. This process also tends to convert most of the ambient NO to NO2 which, as you pointed out, is the harmful form of NOx. HC/VOC emissions are a problem on multiple fronts.
If anything, EPA needs to refocus on HC emissions and leave NOx emissions alone for now, in my opinion.
Posted by: Carl | Mar 13, 2008 1:53:36 PM
In other words, internal combustion produces smog that is unhealthy for people. This I knew as a child growing up in Southern California. My hope was that some day the air would be clean again.
Posted by: sjc | Mar 13, 2008 2:51:19 PM
Couple comments in addition to those of Rafael and Carl.
NO is toxic at ppm levels, OSHA limit is 25 ppmv (but at ppt levels it is necessary for signaling in the body). NO2 is even more toxic, limit is 5 ppmv.
You need both NOx (NO + NO2) and volatile organic compounds (VOC) to make ozone. CO works also. Lot of NOx, little VOC -> ozone destruction and nitrate deposition. Lot of VOC, little NOx -> peroxide and organic aerosol formation (the "smoke" in the Great Smoky Mountains). Lot of NOx, lot of VOC -> lots of ozone, lots of organic aerosol (PM), lots of PANs (peroxyacyl nitrates, the stuff that makes your eyes water). Whether adding NOx makes ("NOx limited regime") or destroys ("VOC limited regime") ozone depends on the amount of VOC you have. Essentially all urban and suburban regions in the US are VOC limited (though adding NOx creates ozone downwind, also acid and nutrient deposition). That's why they tell you to fill up in the evening or early in the AM -- those fugitive emissions are basically instant ozone and PM (in the really nasty nano and ultrafine fractions, no less) during the day. You cannot address ozone by addressing only NOx.
Also, there's no "harmless" level of ozone known, though at some point it becomes less relevant than other known issues, like PM. EPA scientists prefer 60 ppbv, whether or not that's feasible is one thing, but it is important to know that levels of ozone below the current 80 ppb limit are still toxic.
For example, gasoline-powered cars have to wastefully run stoichiometrically rather than lean in part load purely to satisfy the operating parameters of three-way catalysts for NOx reduction.
This is true, but I think it's backwards. Current catalytic converter technology developed out of gasoline ICEs running stoichiometrically. Decades of foot dragging on desulfurizing diesel constrains gasoline technology as well. But IIRC both diesel and gasoline are scheduled to go down to 10 ppm sulfur.
Also, this is no doubt true:
Moreover, efforts to reduce pollutant concentrations ad infinitum have historically led to an upward spiral in fuel consumption.
But I'd say that's a smaller contribution to increases in fuel consumption than increases in vehicle size and power.
Posted by: dt | Mar 13, 2008 3:16:03 PM
There is only so much you can do per engine generation - if you increase pressure on NOx, you have to give up on MPG and CO2.
I guess the choice is political.
Europe has gone for MPG while the US has gone for NOx.
Posted by: mahonj | Mar 13, 2008 3:29:30 PM
@ Carl, dt -
thx for explaining the finer points of smog chemistry. I was simply trying to point out that the issue isn't just ozone but something a lot more complex that you shouldn't try to nail down with just one number.
@ Mahonj -
to be fair, most of Europe is at more Northerly latitudes, none of its major cities are subject to frequent inversion layers and its city dwellers take long vacations just when smog would be at its worst. Europe also doesn't have enough domestic oil to satisfy ~40% of demand. The circumstances are different and so are the priorities for regulators.
Fortunately, they are converging. The EU has been setting ever-tighter emissions and air quality standards since 1992 and the US just recently raised CAFE and updated the EPA drive cycle (though ironically, not for CAFE purposes). California is also trying to wrest control of energy policy from Washington, DC by way of declaring CO2 as an airborne pollutant - mostly because President Bush has been so ornery on the subject.
Posted by: Rafael Seidl | Mar 13, 2008 5:11:21 PM
@dt -
Excellent summary of a complex atmospheric process!
One more caveat - because of the ozone destruction properties of NOx, ambient ozone levels have the potential to actually rise in VOC-limited areas (i.e., most urban/suburban locations) if ambient NOx levels are decreased relatively more than ambient levels of VOC/CO, based on the weekend ozone effect studies conducted by USDOE/NREL.
This is something I hope the regulators will consider when drafting future emissions regulation.
Posted by: Carl | Mar 14, 2008 5:53:35 AM
This proposal is the third or fourth toughened standard of what is acceptable for the level of O3. And it is quite apparent that the lawsuit firebrands aim for a fourth, fifth or sixth toughening of the standard. Even as their is a certain level after which only the true-believers think there is any benefit. The Law officially says there is no lower limit to toxicity and it was purposely written to enhance these unending sinecures.
We had the initial safety limits promulgated by various organizations prior to the levied standards when the EPA was initially chartered, and then the tougher standards promulgated in the late 1980s. Now only 65 counties occasionally fail to meet standards, most momentarily. If you removed the technical momentary exceptions, only a handful of locations would fail; principally the LA basin, the Houston area, and metro NYC.
Why do I expect that we have now far exceeded the level of reasonability and only the Rachel-Carsonite theologians will debate demands for more.
I don't hesitate to say bureaucracies are virtually immortal, and cynics are forever. Work expands to fit the time available.
If we clean the environment, why justify your existence by... moving the goalposts. EPA bureaucrats avoid a RIF; cynical Big Law can earn huge sums continuing to sue; and Green organizations continue to justify their existence.
Forgotten in all this, is the moneys that might have been directed at much more significant and real pollution abating measures.
Posted by: Stan Peterson | Mar 14, 2008 11:42:56 AM
There was a recent report complaining about increased NOx from corn growing. Somehow not one of Iowa's 99 counties exceeded EPA limits. Some scientists choke on gnats while swallowing camels.
Posted by: tom deplume | Mar 14, 2008 1:32:50 PM
CO2 an airborne pollutant fulfills only the political needs of those knowingly exaggerating fact for political gain. A naturally occurring trace gas at .038 percent atmosphere fails to meet any standard of pollutant definition - unless you claim allergy or inability to accept carbon of any kind. Therefore the level of anxiety is largely due to strident exaggeration for the entirely misguided purpose of behavior modification.
Posted by: coolbreeze | Mar 14, 2008 5:49:39 PM
CO2 is a pollutant. It is not suppose to be there in high concentrations. Go into a room filled with CO2 and tell me if you think it is a pollutant. You might find it hard to breath.
Posted by: sjc | Mar 14, 2008 7:50:12 PM
Let's try for honesty here - perhaps you subscribe to a different physiology - but here on Earth, CO2 is infused in every can of soda, beer, sparkling water and wine sold(the order of billions of liters annually). If it were a pollutant, the WHO (World Health Org) should immediately halt the distribution of these beverages. They seem not to be inclined to do so.
BTW, three one hundredths of ONE percent hardly seems to be a "high concentration."
Posted by: coolbreeze | Mar 14, 2008 11:09:25 PM
High concentration is a relative term. If the world's climate is in balance at 400 ppm and we have 500 and heading towards 600, then those are high and getting higher. What happens at the ground level? Are the ppm higher on city streets? I bet they are. The atmosphere may be as thin as an onion skin on earth, but it is a big planet. How many trillions of tons does it take to go from 400 ppm to 500 ppm? Well we did that in a fairly short time in geologic terms.
That carbon that sequestered by nature over millions of years in the form of coal and oil was a response to the planet having too much CO2 in the air. Now we bring it up and burn it and put it back into the air in a very short time. What we are seeing is a vastly accelerated event and the consequences are too severe to ignore. The rate of change is apparent and accelerating. The CO2 on the ground might not kill you, but the severe climate change in hurricanes, tornadoes, droughts and other severe climate change just might. If that does not get you, then economic collapse gets another shot at you.
Posted by: sjc | Mar 15, 2008 8:08:49 AM
The last three sentences above reveal an altogether unhappy, mongering agenda. Has your movement for clean air and alternative energy on Earth taken on the mantle of homicidal threat? God have pity on your poor, misguided soul!
Posted by: coolbreeze | Mar 15, 2008 10:50:44 AM
What ever...if you want to live with those beliefs then that is your choice, but do not expect everyone else to ignore reality. Some people try to head off problems before they become large and insurmountable. This is called planning. That us usually a preferred route to denial.
Climate change is one of those things that people in denial can never be blamed for. They will say it was not their fault, the information was inconclusive, they were just being rational. (when they were actually rationalizing) Rationalizing is doing something irrational and then trying to make it seem rational. Like burning huge amount of finite fossil fuels and pretending that there are no consequences for it.
They can also not be blamed, because they will say it was China, India or any and all other countries that are to blame. Either way, the damage is already done and blame is not going to solve the problem. This is WHY you head off such a large and serious problem before it becomes big and it is too late. The downside damage is too severe to take the chance.
Thank God our lives are not run by people like you. You would get us all in a big mess and then say "hey, it was not my fault".
Posted by: sjc | Mar 16, 2008 9:03:45 AM
The point being made by rationalists (approaching problems rationally, not hysterically)is illustrated by the children's fairy tale "The Boy Who Cried Wolf." If you shout loud and excessively that you see a wolf in your village, and it turns out you have fabricated the claim - people cease to believe you. When a real, significant threat approaches you have lost the ears of your neighbors and then you alone will have to confront the danger.
Claiming CO2 to be a "pollutant" is the irrational, excessive fear mongering of a little boy crying wolf. Keep it up and you will stand alone wondering why no one bothers to listen to your next outcry. And, using veiled threats toward those you disagree with indicates troubled aggression further tipping you toward fundamentalist extremes. Lighten up young man! It's not all about YOU.
Posted by: coolbreeze | Mar 16, 2008 10:52:50 AM
Quoth Tom Deplume:
There was a recent report complaining about increased NOx from corn growing. Somehow not one of Iowa's 99 counties exceeded EPA limits.Different gases. The nitrate applied to corn generates N2O, not NO or NO2. N2O isn't a smog precursor, it's a long-lived greenhouse gas.
Posted by: Engineer-Poet | Mar 16, 2008 11:00:19 AM
