How will current regulations be revised to improve air quality randy wood october 21 2003
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How will Current Regulations be Revised to Improve Air Quality? Randy Wood October 21, 2003. Texas Commission on Environmental Quality. December 2000 Revision. On December 6, 2000 the TCEQ adopted a 1-hour ozone SIP revision for the 8-county area

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How will current regulations be revised to improve air quality randy wood october 21 2003

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

Texas Commission on Environmental Quality

December 2000 revision
December 2000 Revision Quality?

  • 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

Houston galveston emissions tons per day
Houston/Galveston Emissions Quality?(tons per day)

1052 tons

(2007 Future Case)


289 tons

Control strategies adopted
Control Strategies Adopted Quality?

  • 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

Control strategies cont
Control Strategies cont. Quality?

  • 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

Control strategies cont1
Control Strategies cont. Quality?

  • Lawn and Garden Equipment Use Restrictions

    • 6 a.m. – noon ban during ozone season


    • various controls for some bakeries, printers and chemical batch processes.

  • Vehicle Idling Restriction

Control strategies cont2
Control Strategies cont. Quality?

  • Inspection and Maintenance

  • Cleaner Diesel Fuel

  • Construction Equipment Operation Restrictions

  • Accelerated Purchase requirement for federal Tier 2/3 equipment

Control strategies cont3
Control Strategies cont. Quality?

  • 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.

Lawsuit Quality?

  • 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

September 2001 revision
September 2001 Revision Quality?

  • 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

December 2002 revision
December 2002 Revision Quality?

  • 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

March 2003 proposal
March 2003 Proposal Quality?

  • 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

What is the goal
What is the Goal? Quality?

  • Submit approvable SIPs to EPA to prevent federal intervention

  • Submit a 1-hr/8-hr SIP to EPA in Oct. 2004

Why don t we have the answers today
Why Don’t We Have the Answers Today? Quality?

  • The photochemical modeling process has not been completed

  • CAA requires photochemical grid modeling

The modeling process
The Modeling Process Quality?

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



  • Chemical Model

  • Chemistry changes during day and night

  • 33 chemical groups, more than 80 reactions

  • Complex System of differential equations

Emissions inventory
Emissions Inventory Quality?

  • 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

Modeling goals
Modeling Goals Quality?

  • Purpose of model is to compare effectiveness of various control strategies

  • Determine what controls are most effective

The modeling process2
The Modeling Process Quality?

  • Process is not static

  • Stakeholder input necessary

  • The typical SIP development process takes 3 years

  • EPA requires periodic update of SIPs

Why don t we have the answers today1
Why Don’t We Have the Answers Today? Quality?

  • 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

Texas air quality study 2000
Texas Air Quality Study 2000 Quality?

  • 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

Complete the modeling
Complete the Modeling Quality?

  • 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?

What are we going to do to achieve the goal
What Are We Going to Do to Achieve the Goal? Quality?

  • Complete development of photochemical model w/ control strategies

  • Develop control strategies/rules to achieve the necessary emission reductions

    • Not all control strategies are rules

Rule development
Rule Development Quality?

  • Dependant on photochemical modeling results

  • Requires extensive research

    • Searching inventories for sources

    • Investigating accuracy of inventories

    • Evaluating new technologies

    • Calling vendors

Rule development1
Rule Development Quality?

  • Research literature and other states’ requirements

  • Stakeholder input (with advisory group restrictions), public comment period and policy decisions necessary

Control strategy obstacles
Control Strategy Obstacles Quality?

  • 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

Control strategies obstacles
Control Strategies Obstacles Quality?

  • 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

Efforts to overcome obstacles
Efforts to Overcome Obstacles Quality?

  • 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