Paper on Pollution From Highways, Threatening Public Health

8/7/2019 Paper on Pollution From Highways, Threatening Public Health

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Background

Transportation conformity is intended to ensure that actual emissions from motor vehiclesstay within the pollution limits established by states to meet health based air quality standards.

Conformity was strengthened in the 1990 Clean Air Act amendments so that transportationplans would no longer routinely undermine progress towards healthful air quality as they hadrepeatedly since the 1970 Clean Air Act.

In the past few years, transportation conformity has begun to operate fully with the adoptionof the motor vehicle emissions budgets (MVEBs) as part of the attainment StateImplementation Plans (SIPs). This has spurred support for cleaner vehicles, fuels, andmaintenance, and strategies to curb traffic and pollution growth with better travel choices. Ithas resulted in better coordination among transportation and air quality agencies.

In 1997, in response to compelling evidence that the adopted 1-hour ozone health standardwas not adequately protecting public health, EPA adopted a more stringent 8-hour ozoneNational Ambient Air Quality Standard (NAAQS). EPAs authority to adopt this newstandard was challenged all the way to the Supreme Court by industry where the standard wasupheld. After long delay, in 2002, EPA settled a lawsuit with environmental groups toestablish a firm timetable for implementing the new standard, agreeing to designate new 8-hour ozone non-attainment areas by April 2004, with the expectation that most areas wouldsubmit to EPA new 8-hour SIPs with motor vehicle emission budgets by April 2007.

EPAs Proposed Conformity Rule For Transition to 8-Hour Ozone Standard

EPA published for public comment on October 22, 2003 a proposed conformity rule togovern the transition from the 1-hour to the 8-hour ozone standard. In this document EPAmade clear its intention to revoke the 1-hour ozone standard one year following finaldesignation of new 8-hour ozone areas, in April 2005 and negate adopted motor vehicleemissions budgets for 1-hour SIPs that are a foundation of the transportation conformityprocess. As a result, this proposal would disable conformity for many years in our nationsmost polluted areas like Philadelphia, Baltimore, New York, and Chicago, effectivelyremoving most pollution controls from highway construction and transportation planning formany years. This would allow large increases in motor vehicle emissions, as documented bythis study for a sample of major metropolitan areas.

EPA proposes to instead allow metro areas to demonstrate conformity using any of severalalternative tests. This puts states in a position where they are forced to balance the protectionof public health against a desire to increase highway construction, rather than findingsolutions that protect human health and improve mobility. Among the conformity tests thatEPA proposes to substitute is a 2002 baseline test using motor vehicle emissions from 2002as the level not to be exceeded. Application of this test in place of the adopted 1-hour motor

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vehicle emission budgets would allow motor vehicle emissions to increase after April 2005 to2002 levels until new MVEBs are adopted for the 8-hr NAAQS.

These new 8-hour budgets will not become available until 2007 at the earliest, and it is likelythat 8-hour attainment SIPs will not actually be submitted and approved for several years after

that for most of the areas that are examined in this report, which will likely be designatedserious or severe under the 8-hr NAAQS. Under EPAs proposal, areas could approve newtransportation plans so long as transportation emissions levels are less than 2002 levels. Since2002 levels are well above the MVEBs established in the 1-hour SIP to achieve attainment,this could trigger approval of many pollution-inducing highway projects without any trulyeffective air pollution controls.

Analysis of Emission Increases Allowable Under EPAs Proposed Conformity Rule

To evaluate how EPAs proposed conformity rule might affect future emissions, we examinedavailable data for several specific metropolitan areas.

Table 1 shows estimated mobile source emissions for 2002 and for the attainment yearor other SIP deadline year for selected areas.

Table 2 shows the total allowable emissions in the SIP for different ozone-relatedpollutants for selected areas.

Table 3 shows the number of violations of the ozone standard in 2002 by state,suggesting the likely effect of allowing motor vehicle pollution to rise back to 2002emission levels in coming years.

Table 4 shows the share of total ozone-related emissions that are expected to be due tomobile sources in coming years, even with cleaner fuels and motor vehicles.

Older vs. Newer Emission Estimates

This examination of emission changes over time is dependent on the use of a variety of datasources. In January 2002, EPA released new mobile source emission estimation computersoftware, called Mobile 6, which supercedes the older software, Mobile 5. Our examination ofdata seeks to identify which emission estimation tool was used for each number cited.

In Chicago, an initial estimate of the 2002 baseline data (using Mobile 6) shows that VOCand NOX would be allowed to increase to 44% and 56% respectively above the level of theemissions budgets currently approved in the 1-hour SIP budgets for Chicagos attainmentdate of 2007, as shown in Figure 1. A similar analysis in metropolitan Washington, DCshows the EPA rule would allow a 29% and 24% increase in VOC and NOx. In other cities,using Mobile 5 data, a comparison of past emissions budgets for 2002 vs. 2005 and 2007

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attainment budgets shows that under the proposed rule emissions would be allowed toincrease by up to 20% over the attainment budgets allowed in the 1-hour SIPs.

However, it is well accepted that Mobile 6 more correctly reflects the true emissionscompared with Mobile 5 computer model. An EPA analysis shows that Mobile 5 significantly

underestimated NOx and VOC emissions compared to Mobile 6 especially in years prior to2007, with the Mobile 5 emission underestimation problem becoming more acute the fartherback in time one looks. This is illustrated in Figures 1 and 2, which are drawn from theMobile 6 On-Road Motor Vehicle Emissions Model 5-Day Training Course, September 10, 2001,available at http://www.epa.gov/otaq/m6.htm#m6train. Thus, our preliminary analysissuggests that the data for Chicago and Washington, DC, using Mobile 6 presents a moreaccurate measure of the likely increase in mobile source emissions that would be allowableunder the 2002 baseline test vs. the adopted 2005 or 2007 SIP motor vehicle emission budgettest. Unfortunately, 2002 baseline estimates using Mobile 6 are not readily available yet forsome metropolitan areas.

Our preliminary evaluation strongly suggests that it would be prudent for EPA and the statesto carefully review the latest emission estimates using Mobile 6 so that the implications of theproposed EPA rule for all non-attainment areas can be understood before this rule isfinalized.

Motor Vehicles: A Pollution Problem

Motor vehicle emissions represent a quarter to a half of the source of ozone precursoremissions in most US cities that are in non-attainment of the 1-hour standard, as Table 4shows. An increase in motor vehicle emissions means that total emissions in an air shed will

exceed the level needed for attainment. The serious and severe ozone non-attainment areasexamined in this study will not attain the 1-hour national ambient air quality standard if allthe emissions reductions assumed in the attainment demonstrations are not achieved. Thisassertion is based on modeling analyses that demonstrate that SIPs will not attain the ozoneNAAQS without further reductions and EPAs SIP approvals, based on weight of theevidence analyses, that demonstrate only marginal attainment with some highly questionableassumptions. For example, EPAs proposed rule, if adopted, would allow motor vehicleemissions of nitrogen oxides to increase by 56% in metropolitan Chicago, where theseemissions represent 5% of the total attainment year inventory. This could result in a 28%increase in total airshed nitrogen oxide emissions in 2007. Such an emission increase wouldcause serious damage to public health and to the ability of state and local officials to develop

new 8-hour ozone attainment strategies.

Effects of Going Back to Year 2000 Pollution Levels on Number of Dirty Air Days

Looking at 2002 ozone data in Table Three, we can get an approximation of what future airquality is likely to be as long as motor vehicle emissions are allowed to remain at 2002 levels.For example, in the District of Columbia there were 9 exceedences of the 1-hour standard

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http://www.epa.gov/otaq/m6.htmhttp://www.epa.gov/otaq/m6.htm


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and 44 exceedences of the 8-hour standard in 2002. This provides a rough idea of what ozonelevels are likely to be in years after 2005 if motor vehicle emissions are allowed to rise to 2002levels instead of being reduced to the levels required for 2005 in the 1-hour SIP.

These significant increases in allowable motor vehicle emissions for future years almost

certainly guarantee that if EPAs proposed rule is adopted these areas: will not attain the 1-hr NAAQS, will experience more severe and more frequent violations of the 1-hour and 8-hour

NAAQS after April 2005 than they would otherwise, and will experience significantly delayed progress toward attainment of the 8-hr NAAQS.

These outcomes would violate the conformity requirements of the Clean Air Act, section176(c)(1)(B).

Effects of EPAs Proposal on Public Health

In the past decade, the science linking emissions from the transportation sector to publichealth has confirmed, time and again, the powerful link between health and the environment.The increased emissions that would result from this proposed EPA rule could cause greatharm to those already suffering from health problems related to poor air quality

The facts on the harmful effects of ozone are clear. Asthmatics and others with lung diseasesare sickened by exposure to elevated ozone levels. When ozone levels are high, more peoplesuffer asthma attacks, more children are transported to emergency rooms, and moreasthmatics are hospitalized. When ozone levels go down, as was shown in the study ofAtlanta during the summer Olympics of 1996, fewer people suffer asthma attacks, and fewerasthmatic children wind up in emergency rooms and hospitals.1 A recent study has

documented that ozone sickens asthmatic children at levels well below the new eight hourstandard of 80 parts per billion.2 Ozone impairs lung development in healthy children aswell.3 Several studies have documented poorer lung development in children from high ozoneareas compared to those from low ozone areas.4,5

1 Friedman MS, Powell KE, Hutwagner L, Graham LM, Teague WG. Impact of changes in transportation and

commuting behaviors during the 1996 Summer Olympic Games in Atlanta on air quality and childhood asthma.

JAMA 2001; 285(7):897-905.

2 Gent JF, Triche EW, Holford TR, Belanger K, Bracken MB, Beckett WS et al. Association of low-level ozone

and fine particles with respiratory symptoms in children with asthma. JAMA 2003; 290(14):1859-1867.

3

McConnell R, Berhane K, Gilliland F, London SJ, Islam T, Gauderman WJ et al. Asthma in exercisingchildren exposed to ozone: a cohort study. Lancet 2002; 359(9304):386-391.

4 Frischer T, Studnicka M, Gartner C, Tauber E, Horak F, Veiter A et al. Lung function growth and ambient

ozone: a three-year population study in school children

Am J Respir Crit Care Med 1999; 160(2):390-396.

5 Gauderman WJ, Gilliland GF, Vora H, Avol E, Stram D, McConnell R et al. Association between air pollution

and lung function growth in southern California children: results from a second cohort

Am J Respir Crit Care Med 2002; 166(1):76-84.

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Conclusion

It is essential that EPA keep in place the motor vehicle emission budgets in approved ozone

SIPs and control strategies for motor vehicles under the 1-hour national ambient air qualitystandards until the one hour standards are attained and until new attainment SIPs with motorvehicle emissions budgets have been approved for the eight-hour standard. Otherwise, EPAwill authorize backsliding towards dirtier air in Americas most polluted metropolitan areas,with lengthy delay in attainment of healthful air quality.

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Table 1: Estimated mobile source emissions for 2002 and for the Attainment Year or Other SIP Deadlin

Area 2002

MVEB

VOCtons/

2005

MVEB

VOC

day

tons/

day

2007

MVEB

VOC

tons/day

VOC:

Percent

Change

02vs05

VOC:

Percent

Change

02vs07

2002

MVEB

NOx

tons/day

2005

MVEB

NOx

tons/day

2007

MVEB

NOx

tons/day

NOx:

%Change

02vs05

NOx:

%Change

02vs07

C

in

(N

Atlanta1,2 364.5 318.24 15% Boston (Eastern,

MA) 128 87 47% 301 226 33%

Baltimore 54 45.6 18% 112.6 96.9 16%

Chicago2

183 127.42 44% 438 280.4 56%

Houston 99.21 79.51 25% 260.85 156.6 67%

Los Angeles

South Coast Air

Basin3,4 273.1 80.73 61% 526.8 277.8 238%

Milwaukee 43.5 32.2 35% 103.5 71.4 45%

New York,6 179.1 162.6 11% 265.9 221 20%

Philadelphia 69.52 61.76 13% 93.13 86.42 8%

San Joaquin

Valley3

98.8 78.9 25% 210.7 179.7 17%

San Francisco

Bay Area3,5

214.10 164.00 31% 330.80 270.30 22%

Washington

DC/MD/VA2

125.20 97.40 29% 290.30 234.70 24% 1

The attainment date for Atlanta is 2004. The column labeled 2005 MVEB actually shows 2004 MVEB and the NOX perce

2Budgets are based on Mobile 6 data (unless otherwise specified, all other areas show Mobile 5 data)

3California budgets are based on EMFAC, EMFAC2000 for San Francisco, EMFAC2002 for San Joaquin Valley and South

4The attainment date for South Coast is 2010. The column labeled 2007 MVEB actually shows 2010 MVEB and the perce2002. Data from website of SCAQMD 12/22/03.5San Francisco's attainment date is 2006. The column labeled 2005 MVEB actually shows 2006 MVEB and the percent ch

6New York 2007 emission values are emission inventories that do not demonstrate attainment. The 2007 VOC reductio

than the 2007 SIP control strategies emissions. further reductions are needed. The 2007 NOx reduction target is 208

tpd 2007 emission inventory. Added control strategies mostly from non-mobile sources have been identified by NY DEC


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Table 1 Continued

Area Notes/Sources

Atlanta 11/17/03 ROP SIP

Boston (Eastern,

MA)

Attainment SIP, PersonalCommunication MA DEP

Baltimore Attainment SIP. PersonalCommunication EPA R3

Chicago Personal Communication Illinois2002 data is an initial baselineestimate. 2007 is approvedattainment budget

Houston Post 1999 ROP and AttainmentDemo SIP 10/26/01ROP Budgets

Los Angeles South

Coast Air Basin

South Coast Air QualityManagement District2003 Air Quality Management Plan

Milwaukee 66FRN 56931 11/13/20012002 ROP Budget 2007ROP/Attainment Budget

New York 67FR5170 2/4/02 Attainment SIP

Philadelphia 66FR54143 10/26/01Post 1996-ROP plan

San Joaquin Valley San Joaquin Valley draft ROP plan

San Francisco Bay

Area

Attainment SIP

Washington

DC/MD/VA

12/12/03 Draft SIP Demonstrating

Rate of Progress for 2002 and 2005


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Table 2

Total Allowable Emissions in the SIP for Different Ozone-Related Pollutants for Selected Areas

Area Total Allowable

VOC for

attainmentTons/Day

Total Allowable

NOX for

attainmentTons/Day

Source/Notes

Baltimore 230.74 352.42 Personal Communication MDE,Attainment SIP

Chicago 700 564 12/11 Personal Communication IL EPA,Attainment SIP

Houston 573 305.4 Attainment Demonstration SIP 12/2000

Los Angeles South

Coast Air Basin

659.37 764.182003 Air Quality Management Plan.

Numbers do not come from anAttainment SIP

Milwaukee 182.4 249.8 Personal Communication WI DNR,Attainment SIP

New York 708 308 NY DEC Air Resources personalcommunication 1222/03

Philadelphia 425 310 Attainment SIP Feb 200 Rev.

San Francisco 445 525 Attainment SIP October 2001

Washington DC/MD/VA 325.4 487.3 Attainment Demonstration SIP 12/2000

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Table 3 from PIRG Analysis of 2002 air quality violations athttp://www.uspirg.org/reports/dangerintheair2003/dangerintheair2003.pdf

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Table 3 Continued


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Table 4Information from Regions about Composition of Inventory

April 17, 2002

Area O3 Class. Year Type of

SIP

Pollutnt %

Point

%

On

road

%

Non

road

%

Area

Greater CT serious 1999 ROP NOx 27 43 - -

2002 ROP NOx 24 39 - -

2005 ROP NOx 23 35 - -

CT portion of NY-

NJ-Long Island

severe 17

2007 ROP NOx 25 31 - -

Boston (E. Mass) serious 1999 ROP NOx 19 45 - -

Springfield, MA serious 1999 ROP NOx 12 63 - -

marginal 1993 attain NOx 33 58 onroad +

transit

- -Hancock Countyand Waldo County,

ME

2006 maint NOx 33 57 on

road +

transit

- -

moderate 1999 draft

attain

NOx 20 74 - -Portland, ME

2012 draft

attain

NOx 25 67 - -

NH portion of

Boston area

serious 1999 ROP NOx 2 76 - -

Portsmouth-Dover-

Rochester, NH


Providence (all of

RI)


serious 2005 attain VOC 5 28 20 46Washington DC -

MD - VANOx 20 39 25 14

severe 2005 ROP VOC 20 22 17 42Baltimore, MD

NOx 43 30 22 4

severe 2005 attain VOC 31 16 16 37Philadelphia, PA

NOx 47 28 13 12

Atlanta serious 2004 attain VOC 12 total mobile: 62 27

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SIP

Pollutnt %

Point

%

On

road

%

Non

road

%

Area

NOx 21 total mobile:

73

7

1996 VOC 31 32 area + nonroad:

37

NOx 65 26 9

2010 VOC 38 19 43

Cincinnati

NOx 73 16 12

2005 VOC 10 31 59Columbus

NOx 8 33 59

2006 VOC 17 38 32 12Indianapolis

NOx 24 37 21 18

Chicago 2007 VOC 19 45 area + nonroad:

36

(NOx figures are statewide:) NOx 36 61 4

severe 2007 attain VOC 21 19 15 45Milwaukee, WI

(includes NOx ctrls

on lg indust

sources, I/M, Tier

II/Low sulfur,

various rules for sm.indust. sources)

NOx 39 30 18 13

2007 maint VOC 32 15 10 44Sheyboygan, WI

(same ctrls as

Milwaukee)

maint

NOx 68 15 11 5

VOC 21 24 area + nonroad

55

Detroit, MI (does

not include NLEV,

Tier II/Low sulfur)

maint 2005 1994

maint

planNOx 58 25 17

1996

base

case

invtry

VOC

(67%

biogen)

8 8 7 10Houston

NOx 54 24 21 1

Dallas/Fort Worth 1996b

ase

case

VOC

(24%

biogen)

23 28 21 4

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SIP

Pollutnt %

Point

%

On

road

%

Non

road

%

Area

NOx 13 50 33 4

1996base

case

VOC (77%biogen)

13 4 3 3Beaumont

NOx 78 12 9 1

expected 8

hour area

1996

base

case

VOC (42%

biogen)

20 22 15 1San Antonio

NOx 27 49 23 1

expected 8

hour area

1996

base

case

VOC (66%

biogen)

1 11 10 12Austin

NOx 15 45 36 4

Kansas City

R8's % total more

than 100

1999

base

line

NOx 38 42 25 23

St. Louis

R8's %s total more

than 100

1995/1

996

base

case

NOx 49 32 17 32

1993 VOC 16 40

NOx 37 41

2006 VOC 21 34

NOx 40 38

2013 VOC 23 30

Denver

NOx 41 39

1996 VOC 8 44

NOx 16 47

2005 VOC 10 38

NOx 19 43

2015 VOC 10 38

NOx 18 45

Salt Lake/Davis

County

2020 VOC 10 38

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SIP

Pollutnt %

Point

%

On

road

%

Non

road

%

Area

NOx 16 44

1996 CO 1 85 12 2

2000 CO 2 80 16 3

2010 CO 2 77 17 4

Las Vegas N/A

2020 CO 1 79 17 3

1998 PM10 1 35


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Figure 1

Figure 2

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Paper on Pollution From Highways, Threatening Public Health