1. Western Ozone Issues WESTAR Fall Business Meeting Salt Lake City, UT
October 30, 2012
Colleen Delaney, Utah Division of Air Quality

2. History of Ozone SIP in Utah
Salt Lake and Davis Counties were nonattainment for the 1-hr ozone standard in the 1980s
Redesignated to attainment in 1997
All areas in Utah were designated attainment/unclassifiable for the 1997 and 2008 ozone standards
Uintah Basin unclassifiable due to lack of 3 years of regulatory data
1990s started to see increasing ozone in very remote western sites

3. 1-Hr Ozone Maintenance Area
Typical urban area issues – on-road mobile is a significant portion of the inventory

4. Urban areas that are close to 2008 ozone standard

5. Winter time ozone in area with oil and gas development Uintah Basin
Local issue not related to transport
May be a unique western issue related to climate and topography
Uintah Basin

6. Rural areas may exceed an ozone standard in the range of 60-70 ppb.
Ozone Transport
Rural areas may exceed an ozone standard in the range of ppb.
High background ozone also affects urban areas.
If remote rural sites are close to or are exceeding the standard, then how can an urban area with an additional incremental impact ever achieve the standard

7. Large areas of the state have limited ozone data
We have a good historical record in the urban area and have relied on scattered CASTNET sites for the rest of the state. Utah is currently filling in some of the gaps with portable ozone monitors, but there is no long term data for most of the state.

8. SIP Planning Overview
110(a)(2)(D) Transport Demonstration for the 2008 ozone standard
Potential new primary ozone standard in 2014
EPA was close to finalizing a primary standard of 70 ppb (8-hr average) in 2011
CASAC recently recommended a range of ppb for the primary standard, with consideration of even lower values between ppb
Potential new secondary ozone standard
EPA was close to finalizing a secondary W126 standard of 13 ppm-hr in 2011
Designations
Attainment/nonattainment area boundaries would need to be determined
Don’t want to base a SIP on episodes that are significantly influenced by emissions that cannot be controlled
As rural ozone becomes an issue we need a consistent approach for flagging data at CASTNET/other federal sites
State Implementation Plan for nonattainment areas

9. Nonattainment Areas 2008 Ozone Standard

11. Significant Issues from Ozone Transport Conference
Background ozone levels in the west are high.
Transport of ozone or precursors from Asia can have a significant impact, especially during the spring.
Asian impact is increasing
Impact is concentrated in western US
Stratospheric intrusion can have a significant impact, especially at higher altitude sites.
Very high impacts when a front moves through an area
Impact is not limited to that short-term event. Higher ozone occurs across a broad area for several days
Stratospheric intrusion and mixing occur on an on-going basis even without these events
Wildfires have a significant impact on ozone levels. Interannual variability corresponds to variability in fire.
Altitude and topography are important factors in ozone levels.
There is a lot of good research regarding what is contributing to ozone levels in the west, but the monitoring equipment and research centers are not widespread.
Funding for monitoring, research, and regional modeling is decreasing rather than increasing.

12. Significant Issues from Ozone Transport Conference
EPA’s regulatory efforts are focused on the problems in the east
Legal mechanisms to address transport from upwind states
CAIR/CSAPR – focus on power plants in the Midwest
Section 126 petitions
110(a)(2)(d)SIP guidance
Ideas to address issues in the west are problematic
Exceptional events
Policy is based on the idea that these events are infrequent, but that is not the case for the significant sources (stratospheric intrusion, wildfire, asian transport)
Analysis requirements for demonstrations are unachievable for most events
It is too difficult to quantify the ozone levels “but for” the exceptional event
Nothing gets approved
Regulatory approaches to provide relief in “rural” areas don’t work in the west
Changes to EPA’s rules and guidance to address western issues could cause problems with strategies to reduce ozone in the eastern US
My recommendation - a separate western approach is needed

14. MSA’s are based on county boundaries
Low population counties are considered “urban” under some EPA definitions because most of the people live in one small town
Salt Lake City CSA is almost 20,000 sq. miles, comparable to the combined size of Maryland, New Jersey and Delaware.

15. State Implementation Plan
Mandatory measures required by the CAA
Designed to solve urban ozone problem from 20 years ago
Focus on mobile sources and fuels
Nonattainment NSR – makes no sense in areas affected primarily by transport
Mandatory VOC reductions
Transportation and general conformity
Background levels are high – it may not be possible to show attainment in many areas
Mandatory bump-ups require more urban area controls
If a state can’t demonstrate attainment, then sanctions are applied
This process guarantees failure for many areas in the west

16. Secondary Ozone Standard
EPA proposed a new secondary standard to address impact of ozone on vegetation (W126 measures cumulative impact during the growing season)
Impact of this standard is unclear
Limited monitoring data in rural areas this standard is designed to protect
Effects on western vegetation are not well documented
Desert vegetation has different growth patterns
Altitude effects (large forested areas are at high altitude)
What about fire?
Areas will be designated nonattainment and a SIP is required
Implementation requirements not defined (Utah has no experience doing a SIP for a secondary standard)
Ozone transport into rural areas is a significant issue
How will this affect the large areas of federal land in the west?
General conformity
Western areas may never be able to meet the standard, even after significant emission reductions