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Correspondence


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Clean Air Planning Meeting Summary

May 22-23, 1996

Introduction

The Office of Air and Radiation recently invited representatives from STAPPA and ALAPCO, ECOS and
EPA's Office of Enforcement and Compliance Assurance to meet and jointly develop national air
program priorities, in preparation for implementation of EPA's air program in FY 1997 and development
of the agency's FY 1998 air program budget. The May 22-23, 1996 joint planning meeting included
discussions of critical policy issues and associated resource concerns. EPA committed to follow-up
meetings to further refine the priorities and recommendations discussed and to work with ECOS and
STAPPA and ALAPCO representatives each year to develop national air program priorities and funding
recommendations. The May meeting was preceded by an intensive three-week preparatory effort
involving EPA program staff and STAPPA and ALAPCO committee chairs, who comprised six issues
specific workgroups.


The program priorities that we agreed to focus on included ozone/particulate matter and air toxics. While
these are not our only critical programs to reduce overall risk from air pollution, we agreed that these
were essential priorities for investment because they present high risks both to public health and
ecosystems. (The need for focused discussion on Clean Air Act programs meant that important
programs which also provide substantial risk reduction, (climate change, indoor air, and radiation) were
not specifically discussed in these sessions. Continued investment will be necessary in these areas as
well.)


Public Health and Environmental Risks Posed by Air Pollution

Annually, more than 50 million Americans - one in five - are exposed to air that fails to meet the current
health-based National Ambient Air Quality Standards (NAAQS) established by EPA. The promulgation
of a new standard for fine particulate matter and a revised standard for ozone will undoubtedly reveal that
exposure to unhealthful air quality is even more widespread. The following are the most critical air quality
risks to the public and related regulatory concerns that must be addressed by federal state and local
regulators through the national air program.


Particulate Matter/Regional Haze: A number of recent studies have concluded that significant
mortality and morbidity effects occur at levels well below the current PM10 NAAQS. One such study
estimates that over 50,000 people die prematurely each year from cardiopulmonary causes linked to PM
air pollution, with lives shortened by an average of one to two years in the most polluted cities. Further
these studies show that fine particulate --in the range of PM2.5 -- contributes significantly to the most
serious health effects. The findings from these studies indicate that the current PM10 standard may not
be sufficient to protect people from the adverse health consequences of particulate matter, and a new
standard to address fine particles may be proposed.. In addition to the tremendous health threat posed
by PM, this pollutant also contributes to regional haze, which is responsible for environmental
degradation in


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many parts of the country, particularly pristine areas e.g., national parks, wilderness areas, and must be
controlled.


Hazardous Air Pollutants: Toxic air pollutants regulated under the Clean Air Act cause cancer and
other health problems, such as reproductive disorders, birth defects and damage to the nervous system.
Based on currently available data, it appears that people living in heavily populated urban areas are at
greatest risk from exposure to toxins. The national air program has focused on developing
technology-based standards and controls to ensure exposure by citizens of the United States.


Ozone: Ground-level ozone continues to be a difficult and pervasive air pollutant, causing lung damage
and impaired breathing for approximately 50 million people living in urban areas. Recent health data
also suggest that health effects are occurring below the level of exposure allowed under the current
ozone standard, so this standard may need to be improved to protect public health. Ozone is also
responsible for $1-2 billion in lost crop yield across the United States annually and damage to forest
ecosystems in California and the eastern United States.


Critical National Air Program Priorities for FY 1998

The EPA, ECOS and STAPPA and ALAPCO representatives identified four key air program priorities
that must be the focus of additional emphasis in FY 1998: national air program infrastructure;
development of federal measures; technical information, tools and training; and public education and
outreach.


National Air Program Infrastructure

With implementation of new NAAQS for PM, a revised NAAQS for ozone and a new program for
regional haze, there will be significant implications for both existing nonattainment areas and the many
areas currently designated as attainment that may become nonattainment areas. As a result , there will
be a need for new attainment strategies to meet the new standards, while ensuring that our progress to
date is not compromised. Among the efforts that will be necessary are regional initiatives where
transport plays a role in nonattainment, (e.g., Ozone Transport Assessment group and the Grand Canyon
Visibility Transport Commission), integrated strategies, (e.g., Clean Air Power Initiative), streamlined
approaches (e.g.Title V operating permits) and adequate enforcement and compliance assurance
capabilities to optimize both the effectiveness of our resources and the overall environmental results.


Given the health risks associated with toxic air pollution, EPA should develop a national integrated air
toxics strategy. As part of that strategy, EPA needs to
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continue work on issuing and providing implementation assistance for national MACT standards, ensure
the timely issuance of all remaining MACT standards, and complete strategies for control of mobile and
other urban air toxics, as well as pollutants affecting the Great Waters and studies of mercury and utility
air toxic emissions.


The national air monitoring infrastructure will require substantial upgrading, particularly for new PMfine
NAAQS, to identify nonattainment areas, as well as for information on air toxics in urban areas and
ozone in rural areas. Early estimates of costs for equipment to monitor the new PMfine standards
indicate that tens of millions of dollars will be necessary. Data gathering and assessment will also be
needed for air toxics nationwide. Monitoring and assessment activities under the acid rain program also
remain essential to determine the impacts of program initiatives and the need for further action.


Technical Information, Tools and Training

The collection of accurate air quality data, the modeled assessment of the effects of control programs
and the technical capabilities of federal, regional, state and local air quality professionals are
fundamental components of the national air program and must be improved if were are to achieve our
goals. Such improvement will require additional resources.


Development of Federal Air Pollution Measures

To protect the public health from the most insidious air pollutants, federal standards for hazardous air
pollutants must be promulgated on time. This will involve completing 21 two- to- four year MACT
standards (affecting 6,000


major and 40,000 area sources) and 30 seven year MACT standards (affecting 6,000 major sources),
and working on 10-year MACT standards for 87 additional source categories (affecting 6-12,000 major
and 70,000 area sources). As these standards are issued, both EPA and states will need to ensure that
they are fully implemented and the emission reductions from the standards are documented.


For numerous mobile, stationary and area sources of criteria pollutants that can be regulated only at the
federal level or most effectively regulated by a national approach (e.g., on- and off-road engines,
including heavy-duty diesels, the national low emission vehicle program, consumer products and
architectural and industrial maintenance coatings), the expeditious adoption of the most effective federal
control measures achievable will be essential to efforts to realize the emission reductions necessary to
attain the NAAQS.


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Public Education and Outreach Activities

The overall success of the air program will, to a large degree, depend on the level of support provided by
political decision makers, the regulated community and the general public. To generate such support, a
comprehensive and sophisticated public education and outreach strategy will be imperative to build
understanding of the problems underlying federal regulations and programs and acceptance of the
measures that must be implemented.


Targeting Further Efficiencies in the National Air Program

EPA, ECOS and STAPPA and ALAPCO are looking at additional ways to increase program
efficiencies. Areas for scrutiny include streamlining the State Implementation Plan (SIP) process and the
permit process, streamlining and focusing enforcement and inspections, better coordination of
compliance and enforcement efforts, better EPA/State integration of education and outreach efforts,
creative approaches to the development of MACT standards, and elimination of unneeded monitoring to
free resources for other monitoring priorities.


Conclusion

Over the past five years, we have made significant progress in reducing air pollution. Notwithstanding
this progress, as a nation we have not yet realized the Clean Air Act's goal of providing all citizens with
clean, healthful air.


The goal of the National Environmental Performance Partnership System (NEPPS) is to foster improved
stewardship of public health and the environment by directing scarce resources to solving priority
problems and by working collaboratively to take advantage of the relative strengths of both EPA and the
States. One of the critical features of NEPPS is joint planning and priority setting. EPA's meeting with
STAPPA, ALAPCO and ECOS representatives marks a first step toward jointly defining a national air
program strategy. We will continue to seek ways to utilize our collective resources more effectively.
However, efficiencies alone will not be sufficient to meet these new high priority challenges.



For further information, contact: flowers.debra@epa.gov
This Information Last Modified On: 09/18/2008 03:58 PM