Update: National Ambient Air Quality Standards

Association of California Airports

September 15, 2010

Phil DeVita

Overview

Typical Air Quality Regulations

Revised NAAQS

EPA Lead Proposal

Moving Forward

Air Quality Regulations

Federal Clean Air Act Amendments (CAA) National Environmental Policy Act (NEPA)

State California Environmental Quality Act (CEQA) Air Resource Board (ARB)

Local Local Air Pollution Districts (35)

Definitions

National Ambient Air Quality Standards (NAAQS) – developed by EPA to protect public health (Primary Standards) and welfare (Secondary)

Criteria pollutants (NOx, SO2, PM10, PM2.5, CO, Ozone, Lead)

Non-attainment Area designated by EPA as not meeting the NAAQS

Attainment Area designated by EPA which meets the NAAQS

Maintenance Previously designated non-attainment subsequently redesignated to attainment

State Implementation Plan Each state is required to draft a state implementation plan (SIP) to further improve the air quality in

nonattainment areas and to maintain the air quality in attainment and maintenance areas. The plan outlines the measures that the state will take in order to improve air quality

De-minimus Levels Impacts above de-minimus levels are considered significant. Levels are set based on attainment status. Keep

impacts below these levels.

General Conformity Only apply in non-attainment and maintenance areas. If net emissions below de-minimus levels, and not regionally significant, no further action. Otherwise; Conformity determination conducted using dispersion modeling for NAAQS compliance.

Tightening Ozone

EPA proposes tightening the 8-hour Standard effective 8/31/2010 (delayed until October 2010) Reduce the standard from 75 ppb to 60-70 ppb CA Standard 70 ppb

Result of New Standard More non-attainment areas Require Agencies to develop a SIP for attainment Precursors such as VOC and NOx will be targeted More projects subject to EPA Conformity Potential for Agencies to require more reductions at airports

Reclassification of existing non-attainment areas severity Increase pressure for emission reductions Lower conformity thresholds

Existing Ozone Non-Attainment Regions

Source: EPA

Proposed Ozone Non-Attainment Regions

Source: EPA

1-Hour Sulfur Dioxide

New SO2 standard Effective 6/2/2010

Keep the 3-hour secondary and revoke the 24-hour and annual primary standard

New 1-hour standard of (196 ug/m3) more restrictive than CA standard of 655 ug/m3

New monitors proposed along with modeling for compliance

Designations by June 2012

1-Hour NO2 Standard

A new short-term standard 100 ppb (188 ug/m3) in addition to annual standard

More restrictive than CA (current 1-hour NO2 is at 339 ug/m3)

Significant for airports since located near highways and aviation emissions are higher for NO2

Many airports could be located in 1-hour NA, thereby subjecting to General Conformity for NO2

Attainment designations by Jan 2012, conformity reviews by 2013.

New Monitors proposed near major roadways or other large stationary sources of NO2

Particulates

EPA currently reviewing, update due in 2011

Draft Policy Assessment based on the Integrated Science Assessment recommends stricter PM2.5 standards

Annual Standard 10-13 ug/m3 (15 ug/m3) CA at 12 ug/m3

24-hour Standard 25-35 ug/m3 (35 ug/m3)

No Ultrafine Particulate standards (i.e. diameter < 0.1 um)

Lead

EPA Lowered Standard in January 2009 From 1.5 ug/m3 to 0.15 ug/m3.

Trend in lead emissions down from the 1980s (91%)

Lead is still in General Aviation Gas (AvGas) Concern near airports with high piston engine activity Low income/minority populations near airports

EPA conducted a follow up study at Santa Monica Airport. Air and Soil emissions. Not a risk assessment. Previous monitoring results below standard but up to 9 times

above background New results also below standard especially near the runway

Lead near Airports

EPA requires states to locate lead monitors in areas with sources that emit over 1 ton/yr

Four new lead monitoring programs at airports: Van Nuys, Phoenix, Teterboro, Centennial

Lead: What is Next

EPA ANPR for Endangerment Finding ANPR is the earliest step in the process

In response to Friends of the Earth petition

EPA agrees to conduct further health and environmental impact studies to understand lead impacts Unknown whether lead emissions from Piston engines contribute to

endangerment

Endangerment Finding Requires EPA to issue a lead emission standard (i.e. new lead

standard for AVGAS EPA would consult with FAA to insure safety and compliance Many issues remain such as drop in, safety, availability

Industry concern about how EPA is evaluating emissions near airports: Old fuel usage and LTO, modeling techniques

Moving Forward

Airports should track NAAQS changes and attainment designations for their location

Know the SIP process for your region including: Obtain SIP emission inventory Understand the budgets

Contact DEP agency to learn existing monitoring locations and proposed sites near the airport

Have a good understanding of emission inventory at your airport (i.e. modeling)

ACRP Project “Quantifying and Monitoring Lead Emissions from Leaded Aviation Gasoline”

Thank You for your time…For more information, please contact:

Phil DeVita, CCM

pdevita@hmmh.com

www.hmmh.com