How will Current Regulations be Revised to Improve Air Quality? Randy Wood October 21, 2003

1. How will Current Regulations be Revised to Improve Air Quality?Randy WoodOctober 21, 2003 Texas Commission on Environmental Quality

2. December 2000 Revision • On December 6, 2000 the TCEQ adopted a 1-hour ozone SIP revision for the 8-county area • Total reduction of NOx emissions of more than 750 tons per day were necessary to demonstrate attainment in the area • Houston has until 2007 to attain the 1-hour ozone standard

3. Houston/Galveston Emissions(tons per day) 1052 tons (2007 Future Case) Attainment 289 tons

4. Control Strategies Adopted • 90% reduction in point source NOx • Required an overall 90% reduction in power plant, refineries, and chemical plants - including grandfathered sources • Emissions banking and trading • Provides flexibility in meeting the 90% requirement

5. Control Strategies cont. • Speed limit reduction • Reduced all speed limits 60 mph and higher to 55 mph • Airport GSE • Agreements reached to get equivalent reductions at area airports • California Large Spark Off-Highway Equipment

6. Control Strategies cont. • Lawn and Garden Equipment Use Restrictions • 6 a.m. – noon ban during ozone season • VOC RACT • various controls for some bakeries, printers and chemical batch processes. • Vehicle Idling Restriction

7. Control Strategies cont. • Inspection and Maintenance • Cleaner Diesel Fuel • Construction Equipment Operation Restrictions • Accelerated Purchase requirement for federal Tier 2/3 equipment

8. Control Strategies cont. • Transportation Control Measures • Signal timing, bicycle/pedestrian projects, HOV lanes, etc. • Voluntary Projects • Various voluntary projects such as bus fare promotions, alternative fuel programs, an ozone action days.

9. Lawsuit • January 2001: BCCA-AG sues the TCEQ over the 90% requirement • Results of TXAQS 2000 gives a directional indication that HRVOCs contribute to ozone formation in the HGA area

10. September 2001 Revision • Incorporated revisions to the cleaner diesel fuel rules, point source NOx rules, and emissions banking and trading program • The December 2000 and September 2001 revisions were approved by EPA October 15, 2001

11. December 2002 Revision • TCEQ adopted HRVOC rules in exchange for 80% NOx reduction (as opposed to 90%) requirements as a result of settlement w/ BCCA-AG • Rules were for four source categories: • Flares, vents, cooling towers, and fugitives

12. March 2003 Proposal • HRVOC rules are reopened for technical clean-up • Scheduled for adoption October 22 • Rules correct inconsistencies and replace ambiguous language that may otherwise result in unduly burdensome requirements for which compliance dates are imminent

13. What is the Goal? • Submit approvable SIPs to EPA to prevent federal intervention • Submit a 1-hr/8-hr SIP to EPA in Oct. 2004

14. Why Don’t We Have the Answers Today? • The photochemical modeling process has not been completed • CAA requires photochemical grid modeling

15. The Modeling Process Three Models Combined • Meteorological Model • Temperature and sunlight affect reaction rates and mixing layer height • Emissions Model • Emissions from cars, planes, construction equipment, factories, power plants Photochemical Model • Chemical Model • Chemistry changes during day and night • 33 chemical groups, more than 80 reactions • Complex System of differential equations

16. The Modeling Process

17. Emissions Inventory • Where no data exists, we must build estimates • Uncertainty regarding the VOC emissions inventory • Incorporating real world air monitoring data in the current emissions inventory

18. Modeling Goals • Purpose of model is to compare effectiveness of various control strategies • Determine what controls are most effective

19. The Modeling Process • Process is not static • Stakeholder input necessary • The typical SIP development process takes 3 years • EPA requires periodic update of SIPs

20. Why Don’t We Have the Answers Today? • The modeling must be defendable • The process can be completed quickly, but the results won’t be defendable • Important to replicate what is really happening in the atmosphere

21. Texas Air Quality Study 2000 • VOCs from industry are primarily responsible for high ozone in Houston. • VOC emissions are substantially under-reported by industry. • VOC concentrations in Houston are very different from other cities • Ozone is produced faster and yields more in Houston than in other cities

22. Complete the Modeling • TexAQS did not answer all questions • Should VOCs or NOx be controlled to reach attainment? • What combination of NOx and VOC reductions will attain the standard? • How much VOCs are actually being emitted from industry (80+ plants) in Houston? • Which VOCs are the most effective to control?

23. What Are We Going to Do to Achieve the Goal? • Complete development of photochemical model w/ control strategies • Develop control strategies/rules to achieve the necessary emission reductions • Not all control strategies are rules

24. Rule Development • Dependant on photochemical modeling results • Requires extensive research • Searching inventories for sources • Investigating accuracy of inventories • Evaluating new technologies • Calling vendors

25. Rule Development • Research literature and other states’ requirements • Stakeholder input (with advisory group restrictions), public comment period and policy decisions necessary

26. Control Strategy Obstacles • Federal Pre-empted from regulating source • Ex: Locomotives, ocean going vessels, diesel engines • Texas Legislature removed TCEQ’s regulatory authority • Ex: Fuels, Speed Limit, Construction Equipment Related Rules

27. Control Strategies Obstacles • Available technology and verification/certification of technology • There are a limited number of EPA verified or CARB certified technologies • EPA’s verification process is costly and timely

28. Efforts to Overcome Obstacles • TCET funded to test technologies for verification purposes • TCEQ has urged EPA to expedite its verification process • TCEQ in partnership w/ CARB and NY have pressured EPA to improve verification process and implement cleaner engine/fuel standards