How does the State of Alaska develop and implement air programs

1
How does the State of Alaska develop and
implement air programs?
Part 1

• Presented By
• Alice Edwards and Clint Farr
• Alaska Department of Environmental Conservation
• Improve and Protect Air Quality In AlaskaA
  Workshop for Environmental Staff in Native
  Villages U.S. Environmental Protection Agency,
  The Institute for Tribal Environmental
  Professionals,and The Alaska Inter-Tribal Council
• November 6 - 8, 2007

2
Objectives

• Describe how Alaska DEC implements federal Clean
  Air Act requirements through the State
  Implementation Plan (SIP)
• Clean Air Act
• What is a SIP?
• Alaska SIP
• Health Standards and SIPs
• Public Process
• Current SIP Development

3
Clean Air Act State Implementation Plans
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Clean Air Act

• Federal law that comprehensively addresses air
  quality in the United States
• Original Clean Air Act was passed in 1963.
• Congress passed a much stronger Clean Air Act in
  1970, the same year it created the EPA.
• In 1990, Congress dramatically revised and
  expanded the Clean Air Act
• provided EPA even broader authority to implement
  and enforce regulations reducing air pollutant
  emissions
• placed an increased emphasis on more
  cost-effective approaches to reduce air pollution
• Clean Air Act governs the State Implementation
  Plan (SIP) process

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Air Quality Management Process
Set Air Quality Goals
Health standard

• Implement Control Strategies
• -Title V and other Permits
• Surveillance and
• Enforcement

• Evaluate Air Quality
• Emissions Inventory Data
• Ambient Air Monitoring Data

Review Approve Plan
Assess Problem

• Choose Control Strategies
• Voluntary programs
• Some strategies may be regulatory

• Determine Necessary
• Emissions Reductions
• Modeling

Develop Plan
6
What is a State Implementation Plan?

• Clean Air Act Requirement under Section 110
• States have to develop SIPs that outline how they
  will control air pollution under the Clean Air
  Act
• A SIP is a collection of the regulations,
  programs and policies that a state will use to
  clean up polluted areas
• States must involve the public and industries
  through hearings and opportunities to comment on
  the development of each plan

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What is a State Implementation Plan?

• EPA reviews and takes action on state SIPs
  through the federal register process
• EPA provides another opportunity for public
  comment
• SIPs become federally enforceable when approved
  by EPA.
• If a plan does not meet the necessary Clean Air
  Act requirements, EPA can issue sanctions against
  the state and, if necessary, take over enforcing
  the Clean Air Act in that area.

8
The State Implementation Plan Process
SIP Process and Roles
EPA designates areas attainment/nonattainment
State starts to develop SIP
State drafts SIP and submits to EPA for initial
review
State modifies SIP based on EPA comments
State holds public hearing and comment period
State revises SIP to respond to public comment
State officially adopts and submits SIP to EPA
Regional Office
EPA performs completeness review
EPA publishes proposed notice in Federal Register
EPA holds public comment period
EPA publishes final action responding to public
comment
SIP is now federally enforceable
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Alaska SIP
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Alaska Primacy for Air Quality

• Alaska DEC has been delegated authority by the
  EPA to administer the state air quality control
  program
• Alaskas overall air quality plan is documented
  in the State Air Quality Control Plan
• The air quality control plan, including the State
  Implementation Plan (SIP), is adopted by
  reference into Title 18, Chapter 50 of the Alaska
  Administrative Code
• Alaska DEC is responsible for establishing the
  air quality standards throughout the state and
  ensuring that regulations are enforced statewide
  to maintain air standards

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State Air Quality Control Plan

• Plan for addressing air quality statewide
• Portions of the Air Quality Control Plan make up
  Alaskas SIP and address the federal requirements
  of the Clean Air Act.
• Each time EPA approves an amendment to the
  states control plan, those amendments become a
  part of the federally required and approved SIP.
• Other portions of the control plan are state
  requirements that may be pending approval by EPA
  or cover control measures that are not required
  by EPA.

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Health Standards and SIPs
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National Ambient Air Quality Standards

• Health standards set for 6 air pollutants
• Carbon monoxide
• Nitrogen dioxide
• Sulfur dioxide
• Ozone
• Lead
• Particulate Matter PM10 and PM2.5
• EPA reviews standards on five year cycle

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Health Standards and Deadlines

• When EPA revises a health standard
• Designations of attainment/non-attainment are
  made based on available monitoring data
• Under Clean Air Act, State has 3 years to adopt
  and submit a plan revision addressing the revised
  standard
• Deadlines are set for attaining the standard
• Five years from designation

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Attainment vs. Non-Attainment Areas

• Attainment and non-attainment area designations
  are pollutantspecific
• Areas that meet the health standards are
  designated as attainment areas
• Fall under the general SIP
• Areas that exceed the health standards are
  designated as non-attainment areas
• Must develop control plans to include in the SIP
• Once they attain, move into attainment status
  with maintenance plan
• Areas whose status is not known can also be
  unclassified
• Fall under the general SIP

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EPA PM2.5 Schedule
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Non-attainment Designations

• EPA may initiate a change to an areas
  designation
• CAA 107(d)
• Governor may initiate a change to an areas
  designation
• CAA 107(d)(3)

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Non-attainment Planning Criteria

• State is responsible for the SIP
• Must meet CAA requirements (110 172)
• EPA has to review and approve
• Plan must contain (110 172)
• Monitoring
• Enforceable emission limitations
• Adequate personnel, funding and authority
  (110(a)(2)(E))

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Non-attainment Planning Criteria

• State can work with locals
• Design control strategies
• Who implements
• May certify local lead
• If state relies on local government to implement
• Section 110(a)(2)(E) sets criteria for funding,
  personnel and legal authority
• State is ultimately responsible

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Air Quality Management Process
Set Air Quality Goals
Health standard

• Implement Control Strategies
• -Title V and other Permits
• Surveillance and
• Enforcement

• Evaluate Air Quality
• Emissions Inventory Data
• Ambient Air Monitoring Data

Review Approve Plan
Define Problem

• Choose Control Strategies
• Voluntary programs
• Some strategies may be regulatory

• Determine Necessary
• Emissions Reductions
• Modeling

Develop Plan
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Non-attainment Plans

• Include the following components
• a monitoring program, which tracks whether air
  quality is within the health standards
• emissions inventories, which describe the sources
  and categories of emissions to the air for a
  given pollutant, and how much is emitted by each
  source or source category
• air quality calculations and computer modeling,
  which are used to predict future trends and the
  effects of emissions reduction strategies
• control strategy studies whose goal is finding
  the best way to reduce emissions in order to meet
  air quality standards
• formal adoption of control measures (enforceable
  by EPA, States and citizens) which ensure that we
  will achieve the reductions deemed necessary in
  the planning process
• contingency measures to implement if the plan is
  not working and
• periodic review to evaluate whether those needed
  reductions were achieved in reality, and whether
  they had the predicted result.

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SIP DevelopmentDefine the Problem

• Use monitoring data, emission data, and modeling
  to determine source of problem and how much
  pollution reduction is needed
• Emissions are estimated/calculated for sources in
  the area of interest
• Monitoring data used to help identify the extent
  of the problem and potential sources it is also
  useful in validating models
• EPA has approved models for use in planning for
  various pollutants
• Sometimes difficult to run models under Alaska
  conditions

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SIP DevelopmentEvaluate and Select Control
Measures

• Work with community to develop control options
• Federal, State, and local controls
• Evaluate control options for emission benefits
• Costs for implementation of controls
• Other local considerations logistics,
  seasonality, etc.
• Develop the local ordinances or state rules that
  are needed to implement and enforce the control
• Sometimes the CAA or EPA prescribes certain
  controls
• I/M (Carbon Monoxide)
• Oxygenated Fuels (Carbon Monoxide)

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SIP DevelopmentAttainment/Maintenance
Demonstration

• Once control measures are selected must
  demonstrate that the emission reductions bring
  the area into attainment
• Model impacts with revised/reduced emission
  inventory
• Project impacts into the future to show
  attainment by deadline or continued maintenance

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State Regulations and Rules

• During SIP development either local or state
  controls may be needed
• Legal authority may rest with the state for a
  certain control
• Some controls may best be implemented at a state
  level
• Examples of state regulations
• Vehicle Inspection Maintenance
• Oxygenated Fuels
• Stationary Source Operating Permit Program
• New Source Review Prevention of Significant
  Deterioration Permit Program

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Public Involvement
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Air Quality Management Process
Set Air Quality Goals
Health standard

• Implement Control Strategies
• -Title V and other Permits
• Surveillance and
• Enforcement

• Evaluate Air Quality
• Emissions Inventory Data
• Ambient Air Monitoring Data

Review Approve Plan
Define Problem

• Choose Control Strategies
• Voluntary programs
• Some strategies may be regulatory

• Determine Necessary
• Emissions Reductions
• Modeling

Develop Plan
28
Opportunities for Input and Involvement prior to
SIP

• Community and State assess air quality to
  determine what problems exist
• conduct air monitoring
• determine emission sources
• Community and State discuss ways to improve air
  quality
• Based in part on community input, state
  determines whether to recommend to EPA a
  non-attainment designation

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Opportunities for Input on SIP

• State will work with community to develop plan
• early local opportunities for input
• want to work with affected individuals, agencies
  and communities up front so plan will work
• State SIP and regulation process requires
• Formal public notice
• Public hearing
• Agency must respond to comments
• EPA federal register process provides for
  additional comment opportunity after state
  adoption of the plan

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The State Implementation Plan Process
SIP Process and Roles
Opportunities for Input
Area designated nonattainment by EPA
Provide input on designation status geographic
area size, learn about the SIP process in your
state, gather source data, make initial contact
with your state and Regional Office
State/local agencies start to develop SIP
Meet with state SIP development team, join SIP
stakeholder group, get on mailing list
State drafts SIP and submits to EPA for informal
review
Work with Regional Office to provide input and
tribal perspective
State modifies SIP based on EPA comments
State holds public hearing and comment period
Attend and speak at public hearing, submit
written comment
State revises SIP to respond to public comment
State adopts officially submits SIP to EPA
Regional Office
Work with Regional Office to review and provide
input
EPA performs completeness review (EPA has 6
months)
EPA publishes proposed notice in Federal Register
EPA holds public comment period
Attend and speak at public hearing, submit
written comment
EPA publishes final action responding to public
comment
Work with EPA and state to ensure controls are in
place and working
SIP is now federally enforceable
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Alaska SIP Development
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Current SIP and Future Areas of Work

• SIP revisions currently being worked on
• Fairbanks carbon monoxide maintenance plan
• Regional haze including
• Best Available Retrofit Technology
• Enhanced Smoke Management
• Juneau PM-10 Limited Maintenance Plan
• Future SIP revisions
• Fairbanks PM2.5
• Updates related to revised ozone and PM health
  standards
• Conformity revisions
• Rural Dust concerns