Protecting Ecosystems: An EPA Perspective on What Critical Loads Can Offer Presentation for WESTAR “Understanding the CL Approach” Workshop By Richard Haeuber, Ph.D. Office of Air and Radiation, EPA November 16, 2005

Current mechanisms under the Clean Air Act to protect ecosystems New emissions reduction programs Ecosystem-related accountability drivers NAS report on air quality management Exploring critical loads Protecting Ecosystems – Where We’ve Been, Where We’re Headed

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 SO 2 emissions goal: Reduce SO 2 emissions from electric generators by 8.5 million tons (50% below 1980 levels) In 2003, SO 2 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 Monitored Reductions in Wet Sulfur Deposition in the Eastern U.S. Average Average 2002 – 2004

Acid Deposition Control Program (Title IV of 1990 CAAA) NO X emissions goal: lower annual NO X emissions from electric power plants to 2 million tons below the forecasted level for 2000 In 2003, NO X 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. Average Average

Title I: Secondary NAAQS Sec. 109 (CAA) “Any national secondary ambient air quality standard…shall specify a level of air quality the attainment and maintenance of which…is 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.” 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.”

Title I: PSD/NO X Increment Rule EPA was sued on NO X Increment Rule Court remanded case to EPA to develop interpretation of Sec.166 that “considers both subsections (c) and (d), and if necessary to take new evidence and modify the regulations.” –Sec. 166 CAA: (c) Such regulations [for new increments, e.g., NOx] shall provide specific numerical measures against which permit applications may be evaluated, a framework for stimulating improved control technology, protection of air quality values, and fulfill the goals and purposes set forth in section 101 and section 160. (d) The regulations…shall provide specific measures at least as effective as the [statutory increments for SO2/PM] to fulfill such goals and purposes, and may contain air quality increments, emission density requirements, or other measures Environmental Defense petitioned court for EPA to take action on earlier remand EPA proposed rule on February 14 seeking comment on alternatives to increment approach (including critical loads). Final rule signed September 30, 2005.

Final NO X Increment Rule & Critical Loads Final rule text: “EPA will work with interested States, tribes, Federal land management agencies and others to identify the components needed to develop and implement cooperative projects to explore the feasibility and usefulness of a critical loads approach.” –Opportunity to evaluate utility of critical loads as tool in policy/program assessment, evaluation, and development

Clean Air Interstate Rule….the Next Big Step Affected Region and Emission Caps Emission Caps* (million tons) 2009/ Annual SO (2010) Annual NO x (2009) Seasonal NO x (2009) *For the affected region. States controlled for fine particles (annual SO 2 and NO x ) States not covered by CAIR States controlled for ozone (ozone season NO x ) States controlled for both fine particles (annual SO 2 and NO x ) and ozone (ozone season NO x )

Above: Acadia National Park on a day with poor visibility Below: Acadia National Park on a day with good visibility Regional Haze Is a Major Concern for Our National Parks

Clean Air Visibility Rule (CAVR) Covers 26 industrial sectors, including the power industry. CAIR determined better than Best Available Retrofit Technology (BART) controls of CAVR in the CAIR region; therefore, States are allowed to use CAIR in lieu of source-specific BART requirements in the CAIR region. Mandatory BART guidance for power plants >750 megawatt (MW) –Guidelines contain presumptive control levels for coal-fired electric generation units > 200 MW (about 50 units in non-CAIR states) –For electric generating units >200 MW at plants 750 MW or less (about 20 units in non-CAIR region) - encourage use of presumptive controls –Guidance only for all other source categories Presumptive control levels: –SO2: 95% control or 0.15 lbs/MMBtu for uncontrolled units. (Recommend States consider upgrades to existing controls if removal rate is 50% or greater. Recommend States consider replacement if removal rate is less than 50%. Recommend oil-fired units have 1% sulfur limit for fuel). –NOx: Current combustion controls on all coal-fired units except cyclones which require SCR, and annual operation of existing SCR and SNCRs.

Projected 2020 Emissions for Power Plants under CAIR/CAMR and CAVR CAVR CAIR + CAMR SO 2 Emissions NO X Emissions

Total Sulfur Deposition CAIR/CAMR/CAVR 2020 Baseline 2001 Base Case 2020 Legend Total S (kg/ha)

CAIR/CAMR/CAVR 2020 Baseline 2001 Base Case 2020 Total Nitrogen Deposition Legend Total N (kg/ha)

Tracking Progress - “Accountability” Drivers Reporting requirements under Clean Air Act Performance Measures - GPRA (Government Performance and Results Act) - PART (Program Assessment Rating Tool) Tracking and Reporting through Program Progress Reports (e.g. Acid Rain and NOx Budget Program Progress Report) EPA State of the Environment Report A new driver: National Academy of Sciences 2004 Report Recommendations on Air Quality Management

NAS Report on Air Quality Management January 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 Clean Air Act Advisory Committee (CAAAC) reviewed report and developed plan to prioritize and focus NAS recommendations –CAAAC developed 38 separate recommendations based on the NAS Report

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 CAAAC Ecosystem-Related Recommendations

5.1 Program review to improve ecosystem protection Examine current policies and programs to develop approaches advancing ecosystem protection from air pollution impacts Evaluate potential alternative approaches for protecting ecosystems from air pollution impacts – critical loads emphasized CAAAC Ecosystem-Related Recommendations

One conceptual model for developing critical loads

Critical Loads Issues – Some Examples What resources do we care about? –Science/policy dialogue on resources, systems, indicators Do we have the right models? –Evaluation and comparison of models, including pilot applications (e.g., steady-state vs. dynamic models) Do we have the data? –Broad set of data needed to drive dynamic models How best to communicate data and results? –Data presentation and aggregation from site-specific to regional/national How do we know if projected loads are protecting ecosystems? –Deposition and environmental monitoring in relation to modeled loads How do we accommodate system change? –Understanding the consequences of disturbance, land use change, climate change, etc.

EPA Projects Exploring CL Issues Compare/evaluate models for characterizing site to regional response to changes in emissions and deposition ( ) Eastern project –100 Adirondack region sites (w/USFS) Western project – LTER Network sites (w/USGS) Develop Maine CL map to complete NE critical loads mapping project – w/ USFS (2006) Convene inter-agency critical loads workshop (2006) Co-organized by EPA, NPS, USFS, USGS Tentatively set for May at University of Virginia Details TBA Develop critical loads pilot projects – follow-on from Final NO 2 Increment Rule Synthesize state of science on indicators and monitoring eco response to air pollution – w/Heinz Center for Science, Economics, and the Environment

To Learn More….. Clean Air Interstate Rule Clean Air Mercury Rule Clean Air Visibility Rule Clean Air Markets Division