Protecting Ecosystems from S and N Emissions EPAs Perspective

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Protecting Ecosystems from S and N Emissions
EPAs Perspective

• Presentation for Riverside Critical Loads
  Workshop
• By
• Richard Haeuber and Vicki Sandiford
• Office of Air and Radiation, EPA
• February 16, 2005

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Protecting Ecosystems Where Weve Been, Where
Were Headed

• Current mechanisms under the Clean Air Act to
  protect ecosystems
• PSD/NOX increment rule proposal
• National Ambient Air Quality Standards welfare
  effects
• Acid Rain Program
• Potential future emissions reduction programs
• Clean Air Interstate Rule
• Clear Skies Act
• Ecosystem-related accountability drivers
• NAS report on air quality management an
  opportunity for creative thinking

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PSD/NOX Increment Rule

• 1988 EPA was sued on NOX Increment Rule
• 1990 Court remanded case to EPA to develop an
  interpretation of sec. 166 that considers both
  subsections (c) and (d), and if necessary to take
  new evidence and modify the regulations.
• 2003 Environmental Defense petitioned court for
  EPA to take action on earlier remand
• Settlement to issue proposal Sept. 30, 2004
• ED and EPA agreed to delay to Feb. 14, 2005 to
  allow EPA time to consider alternatives to
  increment approach (including critical loads).

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Secondary NAAQS

• Sec. 109 (CAA) Any national secondary ambient
  air quality standardshall specify a level of air
  quality the attainment and maintenance of
  whichis requisite to protect the public welfare
  from any known or anticipated adverse effects
  associated with the presence of such air
  pollutant in the ambient air.

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NAAQS Definition of Welfare

• Sec. 302(h)
• All language referring to effects on welfare
  includes but is not limited to, effects on soils,
  water, wildlife, weather, visibility, and
  climate,, whether caused by transformation,
  conversion, or combination with other air
  pollutants.

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Current PM NAAQS Review

• 01/31/05 -PM 2nd Draft Staff Paper stated
• Though these current activities hold promise for
  using CLs approach in environmental
  assessmentsinsufficient data are available at
  this time to quantify the contribution of ambient
  PM to total reactive nitrogen or acidic
  deposition
• www.epa.gov/ttn/NAAQS

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Review Process for NAAQS
EPA Staff Paper interprets scientific data and
identifies factors to consider in setting
standards including staff recommendations for
standards
Scientific studies on health and environmental
effects
EPA Criteria Document extensive assessment of
scientific studies
Scientific peer review of published studies
Reviews by CASAC and the public
Reviews by CASAC and the public
Public hearings and comments on proposals
Proposed decision on standards
Final decision on standards
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Acid Rain Damages Lakes, Streams, and Forests

• Acid deposition occurs when emissions of SO2 and
  NOx react in the atmosphere to create acidic
  gases and particles which reach the Earth in wet
  and dry forms.
• The greatest sulfur and nitrogen deposition
  occurs in areas of the Midwest and northeastern
  United States which are downwind of the highest
  SO2 and NOx emission areas.
• Impacts occur in both the eastern U.S. and
  mountainous areas of the West.
• Effects of acid deposition include
• Acidification of lakes and streams, making them
  unable to support fish and other aquatic life
• Damage to forests through acidification of soil,
  depletion of soil nutrients, and direct injury to
  sensitive tree leaves and needles

Wet Sulfate Deposition (2000-2002) and
Acid-Sensitive Surface Waters

• Despite substantial emissions reductions over the
  last 20 years, high levels of sulfur and nitrogen
  deposition still enter acid-sensitive lakes and
  streams, leading to high levels of acidity.

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Nitrogen Deposition in the High Elevation West

• Under current emissions rates, nitrogen
  saturation is expected to get worse
• Nitrogen deposition is a significant problem in
  many western areas, including the Colorado Front
  Range, the San Gabriel Mountains,the Klamath
  Mountains, and the San Bernadino Mountains
• This is leading to high nitrogen levels in
  streams in several areas and changing the
  ecological structure of some alpine lakes and
  tundras
• Nitrogen saturation contributes to greater forest
  and grassland susceptibility to fire

Points on map represent only those forested areas
surveyed for these purposes
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Impacts to Coastal Ecosystems
Estuaries with Highly Eutrophic Conditions
Note Conditions are not necessarily related in
whole to human-related eutrophication to various
degrees natural causes and other human
disturbances may also play a role. For instance,
some estuaries in Maine are typified by natural
occurrences of toxic algae, which drift in from
the open ocean. Once in the estuary, however,
these blooms may be sustained by human nutrient
inputs.

• 44 estuaries along all of the nations coasts are
  highly eutrophic
• Estuaries in the Mid-Atlantic and Gulf of Mexico
  are particularly sensitive
• An additional 40 estuaries (not shown) have
  moderate levels of eutrophic conditions

Source NOAA, National Estuarine Eutrophication
Assessment 1999
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Acid Deposition Control Program (Title IV of 1990
CAAA)

• Overall program goal Reduce ecological effects
  of acid rain and protect public health,
  visibility through large-scale regional
  reductions
• SO2 emissions goal Reduce SO2 emissions from
  electric generators by 8.5 million tons (50
  below 1980 levels)
• In 2003, SO2 emissions from all power generation
  were 10.6 million tons, 5.1 million tons (32)
  below 1990 levels
• Eastern states have experienced significant
  decreases in sulfate deposition -- almost 30
  percent -- since the Acid Rain Program took
  effect in 1995.

Monitored Reductions in Wet Sulfur Deposition in
the Eastern U.S.
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Acid Deposition Control Program (Title IV of 1990
CAAA)

• NOX emissions goal lower annual NOX emissions
  from electric power plants to 2 million tons
  below the forecasted level for 2000
• In 2003, NOX emissions from all power generation
  were 4.2 million tons, 2.5 million tons (or 37 )
  below 1990 levels
• Eastern states have experienced some decreases in
  nitrogen deposition
• Nitrogen deposition has not significantly
  decreased since the Acid Rain Program took effect
  in 1995

Monitored Reductions in Wet Nitrogen Deposition
in the Eastern U.S.
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Acid Rain Program Results Surface Water Response
to Emissions Reductions
Regional Trends in Lakes and Streams Acidity,
1990-2000
TIME/LTM (Surface Water Monitoring)

• Regional declines in surface water sulfate can be
  directly linked to declines in emissions and
  deposition of sulfur
• In three regions monitored, one-quarter to
  one-third of lakes and streams previously
  affected by acid rain are no longer acidic

• Regional Acid Neutralizing Capacity (ANC), a key
  indicator of recovery, did not change
  significantly in New England or in Blue Ridge
  streams
• Surface water nitrate concentrations are largely
  unchanged except in Adirondacks and Northern
  Appalachian Plateau

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CAIR The Next Big Step

• Reducing interstate transport is critical to
  solving the problems of ozone, fine particles,
  and regional haze
• Emissions have declined under the Acid Rain
  Program and the environment is beginning to
  improve, but full environmental recovery from
  acid deposition will not happen without
  additional emission reductions
• Clean Air Interstate Rule (CAIR), which is
  focused mainly on the electric power industry,
  would use cap and trade programs to further
  reduce emissions of SO2 and NOx in the eastern
  U.S.

Columns indicate projected nationwide emissions
for the December 2003 CAIR proposal Yellow bars
indicate level of caps for the CAIR region only
(eastern U.S.)
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Projected Sulfur Deposition Improvements in 2010
and 2015 under CAIR
Projected Sulfur Deposition Changes with CAIR
compared to the Base Case in 2010
Projected Sulfur Deposition Changes with CAIR
compared to the Base Case in 2015

• Estimates for 2015 show even more reductions in
  the 60 range in the east.

• By 2010, CAIR would significantly reduce sulfur
  deposition in some areas by over 60 beyond
  levels expected without the implementation of the
  rule

Note this modeling represents the CAIR proposal,
not the final regulation
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Projected Nitrogen Deposition Improvements in
2010 and 2015 under CAIR
Projected Nitrogen Deposition Changes with CAIR
compared to the Base Case in 2010
Projected Nitrogen Deposition Changes with CAIR
compared to the Base Case in 2015

• Estimates for 2015 show even more reductions in
  the eastern U.S., with reductions reaching as
  much as 31 in some areas of Florida.

• By 2010, CAIR would significantly reduce nitrogen
  deposition by up to 21 beyond levels expected
  without the implementation of the rule.

Note this modeling represents the CAIR proposal,
not the final regulation
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The Clear Skies Act 2003 SO2 and NOX Emissions
Caps and Timing for the Electric Power Sector
2004 The NOx SIP call (summertime NOx cap in 19
Eastern States D.C.)
2004
2008 Clear Skies NOx Phase I (2.1 million ton
annual cap assigned to two Zones with trading
programs)
2008
2010 Clear Skies SO2 Phase I (4.5 million ton
annual cap with a national trading program)
2012
2018 Clear Skies NOx Phase II (1.7 million ton
annual cap assigned to two Zones with trading
programs)
2016
2018 Clear Skies SO2 Phase II (3.0 million ton
annual cap with a national trading program)
2020
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Sulfur Deposition Improvements in 2020 under
Clear Skies Act 2003
Projected Changes in Sulfur Deposition with the
Base Case in 2020 Compared to 2001

• The top map demonstrates the effect of existing
  programs (Base Case) in comparison to current
  deposition levels.
• The bottom map demonstrates the effects of Clear
  Skies in combination with the Base Case in
  comparison to current deposition levels.
• Clear Skies, in combination with the Base Case,
  would reduce sulfur deposition up to 60 from
  current levels throughout much of the Eastern U.S.

Projected Changes in Sulfur Deposition with Clear
Skies and the Base Case in 2020 Compared to 2001
Note Alaska and Hawaii are not included in the
model domain
Source 2003 EPA Analysis of the Clear Skies Act.
Projections based on latest data available at
time of analysis.

• Sulfur deposition in the West is generally low,
  so the large percentage increases correspond to
  relatively small changes in actual deposition
  (less than 1 kg/ha). These increases come from
  expected increases in emissions primarily from
  sources not affected by Clear Skies (e.g., metals
  processing, petroleum refining, chemical and
  fertilizer manufacturing). A few power plants are
  expected to increase emissions slightly under
  existing programs.

Note Alaska and Hawaii are not included in the
model domain
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Nitrogen Deposition Improvements in 2020 under
Clear Skies Act 2003

• The top map demonstrates the effect of existing
  programs (Base Case) in comparison to current
  deposition levels.
• The bottom map demonstrates the effect of Clear
  Skies in combination with the Base Case in
  comparison to current deposition levels.
• Clear Skies and the Base Case together would
  reduce nitrogen deposition across much of the
  country up to 35, with larger reductions of up
  to 50 across most of the East and large areas of
  the West.

Projected Changes in Nitrogen Deposition with the
Base Case in 2020 Compared to 2001
Projected Changes in Nitrogen Deposition with
Clear Skies and the Base Case in 2020 Compared to
2001
Note Alaska and Hawaii are not included in the
model domain
Source 2003 EPA Analysis of the Clear Skies Act.
Projections based on latest data available at
time of analysis.

• The projected large reductions in nitrogen
  deposition on the West coast are due to existing
  programs not yet fully implemented, such as the
  Tier II and Diesel Rules.
• In the West, Clear Skies would prevent further
  deterioration of air quality, including
  visibility.
• Clear Skies would allow growth to occur in the
  West without increasing NOx emissions.

Note Alaska and Hawaii are not included in the
model domain
Note The increases in nitrogen deposition in
Louisiana and Washington state occur under both
the Base Case and Clear Skies and are the result
of increases in emissions from manufacturing and
refining sources.
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Tracking Progress - Accountability Drivers

• Reporting requirements under Clean Air Act --
  NAPAP Report to Congress
• Performance Measures
• - GPRA (Government Performance and Results Act)
• - PART (Program Assessment Rating Tool)
• Self-imposed reporting requirements (e.g., Acid
  Rain Program Progress Report, NOx Budget Program
  Progress Report, etc.)
• EPA State of the Environment Report
• A new driver National Academy of Sciences 2004
  Report Recommendations on Air Quality Management

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NAS Report on Air Quality Management

• January 2004 -- NAS Committee on Air Quality
  Management in United States releases report
• Comprehensive assessment of effectiveness of US
  air quality management system
• Core conclusions
• Over past 30 years, Clean Air Act has
  substantially reduced pollution emissions
• Despite progress, Committee identified scientific
  and technical limitations that will hinder future
  progress
• Report intended as blueprint to address
  limitations, enhance air quality management, and
  chart path toward more productive and efficient
  system
• Viewed as opportunity for EPA and to step
  outside the box to achieve better environmental
  results

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NAS Report on Air Quality Management

• NAS made 5 core recommendations to be implemented
  through specific actions
• Strengthen scientific and technical capacity to
  assess risk and track progress
• Expand national and multi-state control
  strategies
• Transform the SIP process into dynamic and
  collaborative multi-pollutant air quality
  management plan
• Develop integrated program for criteria pollutant
  and hazardous air pollutants
• Enhance protection of ecosystems and public
  welfare through better monitoring and tracking of
  ecosystem effects and improving the science to
  support secondary or alternative standards

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Steps to Implement NAS Recommendations-- Clean
Air Act Advisory Committee Review

• NAS Committee recommended that EPA convene
  implementation task force
• Clean Air Act Advisory Committee (CAAAC) reviewed
  report and developed plan to prioritize and focus
  NAS recommendations
• CAAAC review structure
• Air Quality Management Work Group
• Science and Technology Work Group
• Policy and Planning Work Group
• CAAAC developed 38 separate recommendations based
  on the NAS Report

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Input to Developing CAAAC Recommendations
Ecosystem Focus Group

• Ad hoc Ecosystem Focus Group formed to provide
  input to recommendations of Science and
  Technology workgroup
• Prioritized efforts to advance ecosystem
  protection and improve understanding of
  air-ecosystem impacts near term, given current
  state of science and assessment tools
• Ecosystem Focus Group members
• Paul Stacey, Connecticut Department of
  Environmental Protection (co-lead)
• Rona Birnbaum, EPA/OAR (co-lead)
• John Aber, University of New Hampshire
• Jill Baron, Colorado State University/USGS
• Charlie Driscoll, Syracuse University
• Jim Galloway, University of Virginia
• Bill Hogsett from EPA/ORD, NHEERL in Corvallis
• David Karnosky, Michigan Tech
• Hans Paerl, University of North Carolina

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CAAAC Ecosystem-Related Recommendations

• 1.5 Framework for accountability
• Develop benchmarks/measures to assess ecological
  impacts of air pollution and improve ability to
  track/evaluate progress
• Improve tracking/assessing ecosystem effects of
  multiple pollutants
• Conduct/facilitate integrated assessments
  research to develop/implement measurements to
  detect ecosystem response
• Facilitate/pursue collaboration on integrated
  assessments
• Examine possibility of using critical loads
  thresholds

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CAAAC Ecosystem-Related Recommendations

• 5.1 Program review to improve ecosystem
  protection
• Examine current alternative policies and
  programs to develop approaches advancing
  ecosystem protection from air pollution impacts
• Policy/program assessment features
• Policy mandates, objectives, goals, definitions
  of ecosystem protection, historic/legal
  interpretation
• Characteristics of air pollutant regulated, and
  potential magnitudes of impact
• Existing measures for reporting program progress
  and ecosystem impacts
• Desirable modifications to existing tracking
  efforts to support application to different
  regulatory programs
• Current future opportunities/impediments to
  expanding the use of ecological science in the
  policy context
• Policy innovations or revisions that would help
  translate ecosystem science into effective
  ecosystem protection policies