Presentation to EPA Region 6 by June 18, 2015 New Innovative Strategy to Reduce Ozone and Fine Particulate Pollution and to Mitigate Constraints to Economic Development in the Baton Rouge Nonattainment Area 1 BRCAC 18JUN15

PRESENTATION OUTLINE  PURPOSE OF THIS PRESENTATION  BATON ROUGE CLEAN AIR COALITION  BATON ROUGE ADVANCE PROGRAM  BATON ROUGE AIR QUALITY o PROGRESS o CHALLENGES  PROPOSED ERC STRATEGY TO MITIGATE OZONE AND FINE PARTICULATE POLLUTION  THE PROPOSED ERC STRATEGY IS NOT UNPRECEDENTED  ERC STRATEGY IS A WIN-WIN-WIN…  QUESTIONS/DISCUSSION BRCAC 18JUN15

3 THE PURPOSE OF THIS PRESENTATION The purpose of this presentation is to inform EPA of an innovative strategy that we feel will allow for relatively quick, easy, and low cost reductions in NOx and fine particulate emissions in the Baton Rouge area (which would facilitate attainment and maintenance of corresponding NAAQS) and which would mitigate a serious constraint to the area’s economic development. BRCAC 18JUN15

4 Who We Are The Baton Rouge Clean Air Coalition (BRCAC) is a coalition of local governments, state environmental agencies, businesses, industries, academic institutions, and civic organizations committed to improving air quality in the greater Baton Rouge area through voluntary actions and reasonable, effective regulatory actions. For over two decades now, BRCAC has worked as a partner with the Louisiana Department of Environmental Quality (LDEQ) to improve air quality in the Baton Rouge area. Along with the LDEQ, we are the proud sponsors of the local Ozone Action Program, which is a voluntary, community-based program designed to reduce ozone-forming emissions caused by vehicles and other sources during the summer months. Our Mission We are a coalition of local governments, businesses, educational institutions, and civic and environmental organizations committed to improving air quality in the Greater Baton Rouge area through voluntary actions. Our Goals Our goals are: (1) to improve air quality through voluntary actions; (2) create public awareness and promote individual responsibility through education; and (3) provide credible measures of air quality improvement efforts. BRCAC 18JUN15

5 Members of Our Coalition Include:  East Baton Rouge, West Baton Rouge, Iberville, Ascension and Livingston Parishes  Baton Rouge Area Chamber of Commerce  Louisiana Department of Environmental Quality  Louisiana Department of Natural Resources  Capital Region Planning Commission  LSU  LSU Center for Energy Studies  Louisiana Association of Business and Industry  Louisiana Mid-Continent Oil and Gas Association  Louisiana Chemical Association  Louisiana Clean Fuels  ExxonMobil  The Dow Chemical Company  Trinity Consultants  Harris, DeVille & Associates  Providence Engineering and Environmental Group BRCAC 18JUN15

6 Baton Rouge Ozone Advance Program 18JUN15 BRCAC The Baton Rouge Clean Air Coalition, Capital Region Planning Commission, and Louisiana Clean Fuels have been approved by EPA to participate in the Advance Program as representatives of the Baton Rouge area.

7 Baton Rouge Air Quality Progress BRCAC 18JUN15 Despite very challenging circumstances, the Baton Rouge area has made remarkable progress in improving its air quality. Voluntary efforts by the Baton Rouge community have played a major role in this progress. These efforts have been chronicled in our December, 2013 and February, 2015 Advance program reports.

8 Baton Rouge Air Quality Progress BRCAC 18JUN15

9 Baton Rouge Air Quality Challenges Baton Rouge area ozone levels are on a downward trend, and the area has achieved attainment with the old 1-hr ozone standard, the hr ozone standard, and the current hr ozone standard. The area’s 2014 ozone design value was 72 ppb. The current ozone design value for 2015 is 70 ppb. However, the area faces some daunting challenges:  It is expected that, in October, EPA will announce a new ozone standard ranging from 65 to 70 ppb. This will undoubtedly result in the Baton Rouge area falling back into nonattainment status for the ozone standard.  Only point sources are currently eligible for generation, banking and/or trading of emission reduction credits (ERCs) under current LDEQ rules. After several decades of aggressively reducing emissions of NOx and VOCs to mitigate ozone levels, Baton Rouge industries have practically exhausted opportunities for voluntary emission reduction projects and ERCs. Banked ERCs have been depleted and, for all practical purposes, are unavailable for new industries or expansions that would require them to meet offset requirements for air permits. The industrial renaissance that the Baton Rouge area was beginning to enjoy has come to a grinding halt. BRCAC 18JUN15

10 PROPOSED ERC STRATEGY TO MITIGATE OZONE AND FINE PARTICULATE POLLUTION  ERC generation and banking for point sources remain unchanged.  Mobile sources (i.e. heavy duty diesel vehicles/equipment) that operate in the 5-parish Baton Rouge nonattainment area become eligible for ERC banking projects.  Projects that reduce emissions from area sources (e.g. truck stop electrification) may be deemed eligible for ERC banking on a case-by-case basis. BRCAC 18JUN15

11 To support LDEQ with the expansion of sources eligible for ERC banking, BRCAC will establish a web-based ERC Information Resources Center that: ERC Information Resources Center 1.organizes and presents current information on Louisiana’s emission reduction credits (ERC) program; 2.facilitates the coordination of those seeking to purchase, generate, and offer projects that will reduce emissions of NOx, VOCs, and small particulates; 3.supports LDEQ air quality permitting efforts for projects being considered in ozone and fine particulate nonattainment areas by providing information on emission reduction credits activity; and 4.Presents tracking information for individual and total air quality benefits brought by ERC projects. BRCAC 18JUN15

12 ERC Information Resources Center Elements of the IRC website  Home page – describes what the IRC is, why it has been put together, what it offers, an events calendar, featured news section, recent blogs, an emissions reductions graphic, etc.  About us – conceived and put together by BRCAC stakeholders; owned and maintained by CRPC.  Offset requirements for permits in nonattainment areas  ERC strategy – background/overview; air quality and economic development benefits  ERC opportunities  Existing ERCs (table) (must accurately reflect DEQ banked ERCs)  ERC projects in progress (table)  Projects with ERC potential seeking funding (table) BRCAC 18JUN15

13 PRELIMINARY PLANNING SCHEDULE FOR DEVELOPMENT OF ERC INFORMATION RESOURCES CENTER TASKSMAYJUNJULAUGSEPOCTNOVDEC APPROVAL OF STRATEGY OBTAIN COST ESTIMATE OF TOTAL IRC DEVELOPMENT DETERMINE FUNDING TEAMS AND METHODS FUND RAISING CONDUCT 5-PARISH DIESEL ENGINES INVENTORY DEVELOP SOW RFP CONTRACTOR PROPOSALS RECEIVED AND REVIEWED AWARD CONTRACT AND BEGIN IRC DEVELOPMENT DEVELOP IRC WEBSITE & DATABASES TEST AND PROVE IRC ROLL OUT IRC BRCAC 18JUN15

14 THE PROPOSED ERC STRATEGY IS NOT UNPRECEDENTED  On July 2, 1999 EPA approved in the state’s SIP LAC 33:III Chapter 6, para. 607B. Eligible sources that may create and bank emission reductions include, but are not limited to, the following permitted and unpermitted source types regardless of the size of the source or the level of emissions: 1.stationary sources, including point sources, fugitive emission sources, and off-shore sources; 2.mobile sources, including on-road and off-road sources and marine vessels; and 3.Area and indirect sources, including non-point sources and agricultural sources.  EPA has a well-establish program for diesel emission reduction projects that generate emission reduction credits for use in SIPs and conformity determinations.*  EPA’s National Clean Diesel Campaign (NCDC) promotes clean air strategies by working with manufacturers, fleet operators, air quality professionals, environmental and community organizations, and state and local officials to reduce diesel emissions.  There are numerous other examples of mobile emission reduction credits being used in SIPs, conformity determinations, and banking for offsets. *EPA Diesel Retrofits: Quantifying and Using Their Emission Benefits in SIPs and Conformity EPA-420-B , February 2014 BRCAC 18JUN15

15 The Proposed ERC Strategy is a Win-Win-Win…..  ERC PROJECTS CAN START REDUCING EMISSIONS AND IMPROVING AIR QUALITY IN A RELATIVELY SHORT PERIOD OF TIME.  WILL REDUCE EMISSIONS FROM IMPORTANT OZONE PRECURSOR SOURCES NOT EASILY REGULATED BY LDEQ (E.G. MOBILE AND AREA SOURCES).  ALLOW FOR CONTINUED ECONOMIC AND TRANSPORTATION DEVELOPMENT (INCREASED AVAILABILITY AND LOWER COSTS FOR ERCs).  FACILITATE OVERALL EMISSIONS REDUCTIONS IN PURSUIT OF ATTAINMENT AND MAINTENANCE OF OZONE AND PM 2.5 NAAQS.  ALLOW SOME MUCH-NEEDED MARGIN FOR CONFORMITY DETERMINATION UNDER AN EXPECTED NEW MORE STRINGENT OZONE STANDARD. BRCAC 18JUN15

16 QUESTIONS/DISCUSSION BRCAC 18JUN15