Ask the Scholar
Document scope · 1 page
Scholar
Ask about this object, its catalog metadata, its source description, or the page inventory.
For page-specific OCR and visual context, open one of the page chats.
Scholar Source Context
Document identity
localId
323152500
label
Clean Air Act Announcement 6/8/89 [OA 6264] [5]
core
doc
dtoType
document
citationUrl
pageCount
1
Source metadata
id
323152500
contentType
document
title
Clean Air Act Announcement 6/8/89 [OA 6264] [5]
citationUrl
identifierLocal
13672-004
collections
Records of the White House Office of Speechwriting (George H. W. Bush Administration)
Speech Backup Chronological Files
imageCount
1
hasImages
yes
source
import
hasTranscription
no
Source extras
naId
323152500
levelOfDescription
fileUnit
recordType
description
ocrSource
nara-archive
Single page context
seq
1
pageIndex
0
type
document
mediaId
d1ba4815a9fee5b3
ocrText
Originally Processed With FOIA(s):
FOIA Number:
S
S
FOIA
MARKER
This is not a textual record. This is used as an
administrative marker by the George Bush Presidential
Library Staff.
Record Group/Collection:
George H.W. Bush Presidential Records
Collection/Office of Origin:
Speechwriting, White House Office of
Series:
Speech File Backup Files
Subseries:
Chron File, 1989-1993
OA/ID Number:
13672
Folder ID Number:
13672-004
Folder Title:
Clean Air Act Announcement 6/8/89 [OA 6264] [5]
Stack:
Row:
Section:
Shelf:
Position:
G
26
19
1
6
Withdrawal/Redaction Sheet
(George Bush Library)
Document No.
Subject/Title of Document
Date
Restriction
Class.
and Type
01a. Report
"Toxic Air Pollution Control." (12 pp.)
05/12/89
P-8
Collection:
Record Group:
Bush Presidential Records
Office:
Speechwriting, White House Office of
Series:
Speech File, Backup
Open on Expiration of PRA
Subseries:
(Document Follows)
WHORM Cat.:
By SN (NLGB) on 4/5/2005
File Location:
Clean Air Act Announcement 6/8/89 [5]
Date Closed:
9/30/2004
OA/ID Number:
06264
FOIA/SYS Case #:
Re-review Case #:
2004-2265-S
P-2/P-5 Review Case #:
MR Case #:
Appeal Case #:
MR Disposition:
Appeal Disposition:
Disposition Date:
Disposition Date:
RESTRICTION CODES
Presidential Records Act - [44 U.S.C. 2204(a)]
Freedom of Information Act - [5 U.S.C. 552(b)]
P-1 National Security Classified Information [(a)(1) of the PRA]
(b)(1) National security classified information [(b)(1) of the FOIA]
P-2 Relating to the appointment to Federal office [(a)(2) of the PRA]
(b)(2) Release would disclose internal personnel rules and practices of an
P-3 Release would violate a Federal statute [(a)(3) of the PRA]
agency [(b)(2) of the FOIA]
P-4 Release would disclose trade secrets or confidential commercial or
(b)(3) Release would violate a Federal statute [(b)(3) of the FOIA]
financial information I(a)(4) of the PRA]
(b)(4) Release would disclose trade secrets or confidential or financial
P-5 Release would disclose confidential advise between the President
information [(b)(4) of the FOIA]
and his advisors, or between such advisors [a)(5) of the PRA]
(b)(6) Release would constitute a clearly unwarranted invasion of
P-6 Release would constitute a clearly unwarranted invasion of
personal privacy [(b)(6) of the FOIA]
personal privacy [(a)(6) of the PRA]
(b)(7) Release would disclose information compiled for law enforcement
purposes [(b)(7) of the FOIA]
C. Closed in accordance with restrictions contained in donor's deed of
(b)(8) Release would disclose information concerning the regulation of
gift.
financial institutions [(b)(8) of the FOIA]
(b)(9) Release would disclose geological or geophysical information
May 12, 1989
Toxic Air Pollution Control
Background
Since 1974, EPA has been required to set health-based emission
standards for hazardous air pollutants. Section 112 of the
Clean Air Act requires EPA to protect public health and the
environment "with an ample margin of safety" to ensure
protection of the most vulnerable class of individuals (e.g.,
elderly, children) or species.
Estimates submitted to EPA show that 2.7 billion pounds of toxic
chemicals are emitted annually. Approximately 280 toxic
compounds were identified that are emitted in quantities that
pose some risks. About 45 are carcinogens and are estimated to
cause between 1500 and 3000 additional cancer deaths per year,
of which 25 percent are caused by large stationary sources, 25
percent by small area wide sources and 50 percent by mobile
sources. Non-cancer effects have not been quantified but would
include reproductive and birth defects and neurotoxicity. High
quality data exists for only 60-80 chemicals which would most
likely be the basis for an initial regulatory program under
revised legislation.
A majority of the number of identified carcinogens is emitted by
about 30 industrial categories, including steel mills (coke
ovens), rubber, pulp and paper, chromium electroplating,
electric utility cooling towers, and solvent users.
Illustrative lists of chemicals, emitting sources, and their
cancer incidences are Attachments A - C. However, almost 75
percent of the total pounds of toxic pollution emitted are
volatile organic compounds (VOCs) which are principally emitted
from automobiles and smaller area sources such as gasoline
stations and dry cleaners.
The desirability of an international convention to control VOC
emissions is currently under consideration in the Economic
Commission for Europe, in which the U.S. is an active
participant. An Administration policy on air toxics would
provide a sound basis for a U.S. position on VOC controls in any
future negotiations.
Current Legislative Status
Two proposed bills to control stationary sources have been
introduced by this Congress. H.R. 4 (Dingell) reintroduces a
bill drafted by EPA last year. It did not represent the Reagan
Administration position. S. 816 (Baucus) is far more stringent
than the regulatory scheme in H.R. 4. But both bills are
conceptually based on regulating a specific list of chemicals
with regulatory priority based on toxicity, volume and the
number of chemicals emitted by an industrial category. Both
2
bills also require the regulation of specific industrial
categories through deployment of technology-based standards,
requiring maximum controls subject to economic and technical
feasibility. Future follow-up actions would be required if the
technologies prescribed do not reduce risk sufficiently within
the allowed time frames. Exceptions to (or less stringent)
regulations can be promulgated or permitted on an individual
basis if the industrial sources can demonstrate negligible risk.
Additional details of the above elements are in Attachment D and
a comparison of the House and Senate bills is Attachment E.
The Current Program Will Not Work
The current law is unwieldy, fraught with contradictions, and
provides such little regulatory discretion that it is impossible
to administer. The statutory requirement to "protect the public
health with an ample margin of safety" is inherently unworkable
for carcinogens. There simply is no identifiable threshold at
which carcinogens pose no health risk. Yet a zero emission
requirement is tantamount to shutting down many of the largest
and most vital U.S. industries.
As a result, over the past 15 years since enactment of Section
112 of the Act, EPA has promulgated only seven regulations
controlling toxic air pollutants. Further, attempts by EPA to
balance risk reductions with economic and even technical
feasibility were undermined by a recent (1987) D.C. Appeals
Court decision. The Court ruled that a safe level must be met
without regard to costs or technical feasibility of the controls
required. Meeting the test would obviously shut down or
severely disrupt many industries. Under current law, plants
must comply within 90 days of promulgation and can receive a
oné-time extension for only two years if it is technically (as
opposed to economically) infeasible to comply.
Maximizing regulatory control under other Clean Air Act sections
and other applicable statutes instead of regulation under
Section 112 is also not viable -- even though a significant
percentage of the problem (VOC's) is being addressed under other
statutory authorities. Many toxic pollutants and sources would
remain uncontrolled, since not all toxic pollutants can be
addressed by other authorities. Second, EPA has already been
subject to suits by NRDC to push forward under Section 112.
Ultimately, without an active EPA program, the courts will only
substitute their regulatory policies for that of the Executive
Branch. Last, but not least, EPA would be in the impossible
situation of justifying why it chose not to pursue controls over
identified carcinogens.
In summary, the zero tolerance level mandated under current law
is suboptimal and if continued would be extremely costly,
politically difficult and would threaten the shut-down of many
plants in several industries from court mandates.
3
Reductions of health risk occurring under other current programs
and proposed legislation
There are several control measures already in existence and
several others which could be accelerated, strengthened or
initiated under current laws that would greatly reduce the
health threat from toxic pollutants. Furthermore, much of the
VOC emission problem will be addressed as part of the ozone non-
attainment program at least in those areas that are in non-
attainment. Nearly 50 percent of VOC emissions occur in non-
attainment areas which will be subject to additional controls
through the Administration's proposed legislation.
of particular importance is the control of mobile sources, which
will, alone, reduce 700 cancer deaths per year by 1995.
(1) Control of diesel particulates - EPA estimates that
particulate emissions from diesel engines are
responsible for 520 cancers per year. By 1995, these
standards already in place will reduce air toxics risks
from diesel bus and truck emissions by 185 cancers per
year and by roughly 400 cancers per year by 2005.
(2) Control of hydrocarbon emissions - EPA estimates that
emissions from gasoline-fueled vehicles are responsible
for 700 deaths per year. By 1995, the replacement of
older (1970 or earlier) cars in the fleet with new cars
meeting the current tailpipe standards will reduce air
toxics risks by 214 cancers per year. In addition,
options to require oxygenated fuels and a neat fuels
program to address non-attainment problems could yield a
further reduction of 75 cancers per year.
Attachment F shows that toxic emissions from major stationary
sources rank in the third tier of overall risks facing Americans
today. Emissions from cars and trucks pose a far greater risk,
and implementation of those programs will result in the greatest
risk reduction.
Another group of control measures that can be implemented (in
addition to options presented below) are those controllable
under other current authorities, e.g., RCRA controls for
hazardous waste treatment, storage, and disposal facilities.
EPA estimates that its current rulemaking to limit air toxic
emissions from these hazardous waste facilities would reduce the
risks by 120 cancer deaths per year.
A listing of other EPA authorities, and the reduced health
threat associated with their implementation, is Attachment G.
4
LEGISLATIVE REFORM PROPOSALS:
The remaining health risk that cannot be addressed under current
laws or proposed legislation to control ozone is concentrated in
large, stationary sources and a large number of small "area-
wide" emitters. In developing new legislation to address these
sources, there are five principal objectives that have guided
the development of options.
Legislative Principles
1. To achieve reductions in toxic pollutants as soon as
possible. As a nation we have reduced pollutants posing far
less risk to a far greater extent. The early reduction of these
significant risks should be a top priority.
2. To provide sufficient flexibility that risk reduction can be
balanced against economic and technical feasibility consider-
ations. Flexibility should also be maintained to ensure that
neither over- or under-control is the ultimate result of the
regulatory strategy adopted.
3. To set in place a comprehensive long-term strategy that
could lead to additional reductions in risks as new pollutant
compounds are identified, or technical and economic
feasibilities are improved sufficiently to reduce existing risk
further.
4. Encourage industries to make reductions on their own by
crediting early non-mandated reductions against total reductions
subsequently required in Federal regulation.
Program Reform Options
Adherence to the above principles presents a general framework
for legislation. The short-term and long-term control
objectives can be met by having two phases -- an initial phase
that will lead to early but not complete reductions in risk and
a second phase to deal with the admittedly far more difficult
"residual risk" that could not be captured in the initial round
of reductions.
Phase I
For the major industrial dischargers of toxic air pollution,
early reduction and flexibility in control strategies can be
achieved through one of three basic regulatory strategies.
5
Alternative 1: Shift the basis for regulation from solely
health-based to an "unreasonable risk" standard. Factors to be
considered in establishing the unreasonable risk level for
industrial sources would include risks (e.g., aggregate health
effects), costs and availability of substitutes. The
unreasonable risk test would explicitly balance the benefits of
regulation against the cost of regulation and free the Agency
from the rigidity of a zero risk test under current law that has
precluded regulation.
Furthermore, the standard could be coupled with a commitment to
address a specific list of the industrial sources posing the
greatest risk within, for example, the next three or five years
and by implementing regulatory activities under other
authorities as described on page 3.
Advantages of Alternative 1
Attachment H shows that, among stationary sources, the
major risk is posed by one industry (electroplating) the
control of which by itself would reduce 50 percent of all
annual cancer deaths resulting from stationary sources.
The standards established in Federal regulation would
target controls at the most significant health effects and
avoid "control for control's sake." With a finite amount
of financial resources available for this problem it is
essential that capital be directed where benefits will be
achieved.
It would minimize unnecessary economic dislocations and
allow EPA to balance higher risk against higher costs of
control.
Disadvantages to Alternative 1
This approach has many of the same inherent defects of the
current program -- it requires extensive and detailed
health and engineering data before decisions can be made.
Further, by combining the base technology and residual
risk decision, litigation over the admittedly imprecise
"choice" will be extensive.
Experience with the balancing of costs and benefits under
other EPA statutes (e.g., Toxic Substance Control Act) has
proven that an unreasonable risk basis is slow and
cumbersome.
Without some strategy for the residual risk the
legislation would be criticized as not protective of
public health.
The mobile source and RCRA controls included in this
alternative can be done under any option.
6
Alternative 2: Implement a modified version of the the Maximum
Available Control Technology (MACT) program provided currently
in H.R. 4. Implement Federal regulations through a State permit
program modeled after the Clean Water Act program to control
toxic water pollutants.
Under this regulatory program, EPA would list about 125
industrial categories for control on schedules requiring
controls by dates 5 to 12 years after promulgation. Another 125
would be discretionary for regulation and have compliance dates
of 10-12 years from enactment.
For newly constructed sources, MACT would be defined as best
achievable technology considering costs and technical
feasibility. For existing sources, MACT would be defined as the
maximum achievable "in common practice" by the "better
performing sources," i.e., the "average of the best
technologies." In either instance single national regulations
would establish the specific performance standards for all
sources within the regulated category.
Specifically, this option would require sources to use maximum
available control technology economically achievable on source
categories established by EPA, except:
Exempt sources or categories presenting negligible risk.
Exempt sources from controls where they have achieved 90
percent emission reduction for VOC's or 95 percent for
particulates.
Area sources may use "generally available" control
technology.
Exempt utility boilers from control until EPA performs a
study and reports to Congress.
Sources emitting less than 10 tons per year of one
chemical or 25 tons of a mixture are not included (except
when area sources are listed).
Then each State (or EPA if a State does not accept delegation)
will issue permits to individual sources. Based on negotiations
with the source the States will set actual technology require-
ments needed to meet the Federal emission limits. Technologies
may not be the same as referenced in the EPA regulation, but the
emission limits would be met. This allows plants to meet
Federal limits in the most cost-effective way, based on the
unique production, site location, economic and environmental
capabilities of the permittee.
7
Advantages of Alternative 2
Information on each community's exposure is now, by law,
available in local public libraries. The availability of
this information is increasing pressure on State and local
governments to reduce community exposure to air toxics.
Many of these governments lack resources and expertise to
effectively regulate major industrial sources. The
standards for industry as a whole should be Federal
standards which take into account economic feasibility in
defining our expectations of industry.
The performance requirements under MACT would be patterned
very closely after the existing Best Available Control
Technology (BACT) program currently in place for
controlling non-toxic air pollutants. It is, therefore,
familiar to the regulated community.
Establishes a regulatory framework that provides
significant discretion to EPA and yet is consistent with
the national Federal regulatory structure already in the
Clean Air Act.
Is the most likely to obtain Congressional and state
support since it is consistent with H.R. 4.
Disadvantages to Alternative 2
No early reduction can be achieved prior to the completion
of the lengthy (5 to 10 years) and arduous task of
promulgating the nearly 125 separate control regulations.
It violates one of the principal legislative objectives --
to obtain early reductions.
Rigid technology-based standards have the highest
likelihood of over-control, especially if combined with a
by EPA.
percentage reduction requirement in Phase II as proposed
Federal regulation can not address the large number and
wide variety of small diffuse sources.
8
Alternative 3: Alternative II but, get early risk reductions
through the State permit program before MACT is issued.
Under the toxic water pollution control program, prior to
issuance of Federal regulations, permits were issued by States
(or EPA if not delegated) in accordance with "best engineering"
judgment. Since the Federal technology-based regulations for
toxic pollutants took over a decade after passage of the Act in
1972 to develop), the vast majority of plants operated under
these "BEJ" permits. They required, as a general rule, the
"best of the average" technologies readily available and
achieved roughly 75 percent reductions in emissions. When
Federal guidelines were finally promulgated State-issued permits
for each plant are then adjusted to accommodate the new limits.
Advantages of Alternative 3
The "BEJ" permit system can be implemented rapidly and can
achieve significant (75 percent) reductions in toxic
emissions before the lengthy, arduous, federal MACT
litigation. regulatory scheme is promulgated and fought through
The permit system is already well established in other
State environmental programs, (Water and Hazardous Waste)
discharger, and should be easily adapted to air emissions.
Industries are familiar with the permitting process and
the chemistry of the pollutants being controlled.
From the start it places the policing power at the State
level where it belongs and places in EPA its proper
standard setting and oversight responsibility. However,
the vast majority of the work would be done by the states
and by the industries themselves which would be required
to have rigorous monitoring programs and provide emission
data to the State on a quarterly basis.
Can also deal with small diffuse "area-wide" sources in
the same manner as in the Clean Water Act -- through the
use of area-wide or general permits. These sources are
so varied and diffuse that they will not likely be covered
by Federal regulations
Disadvantages of Alternative 3
The water permit program had considerable difficulty in
getting started, with large backlogs in the mid-1980's.
Industry will be very concerned about a repeat of this
process.
Due to its earlier inception, will increase State costs in
the short run. States will demand additional Federal
grant support or will refuse delegation, requiring
additional EPA permit staff instead. This is only for the
near term reductions, since after MACT regulations are
issued, a permit program is envisioned.
9
Phase II
With the majority of risk reduced by Phase I controls the issue
now shifts to the longer run control of emissions where the
"residual risk" is still unacceptable. By definition, the costs
of control to address the residual risk will increase
dramatically and the technology will be far more sophisticated
to install and operate. EPA estimates, however, that only a
small percentage of major sources will have residual risks of
concern. Therefore, the legislative framework that EPA must use
to establish additional controls is as important as the level of
control. Without flexibility, EPA runs the greatest risk of
over-controlling sources.
Alternative 1. Evaluate the residual risk after controls are
implemented and make legislative recommendations at that time.
Advantages of Alternative 1
Experience in other control programs has shown that well-
operated technologies will often exceed the engineering
estimates of performance and that industries often build
in extra reduction capacity to ensure against violations.
Therefore, actual remaining risk may well be less than the
models predict.
Because EPA uses a very conservative risk model in
estimating health effects of toxic air pollutants,
establishing rigid deadlines or minimum further reductions
to deal with residual risk now will most likely lead to
over-controls. Given the cost of further controls,
decisions should be based to the greatest extent possible
on actual risk levels, not models.
Postponing mandatory action also allows sufficient time
for needed research and development efforts by industry to
develop techniques. new control methods or lower emitting production
Disadvantages of Alternative 1
Precludes EPA from acting on residual risks even where
subsequent analysis demonstrates a need or subsequent
controls become available.
Provides no incentive for industry to develop new or
innovative control technologies.
10
Alternative 2: Require an average of 90 percent reductions of
current emissions for pollutants that the Administration
determines would continue to present a serious or widespread
risk of adverse effects to health.
Determinations of the need for further reductions would be made
based on post-MACT compliance. A five-year deadline for
implementation of additional controls would be set. The strict
90 percent rule in H.R. 4 would be tempered by EPA's proposal to
allow extensions of the deadlines for implementation if
"reasonable further progress" is demonstrated. The definition
of further progress would include appropriate private investment
in controls and research and development leading to new
controls.
Advantages to Alternative 2
Would have the greatest chance of obtaining Congressional
support since it follows the model established in H.R. 4.
The 90 percent reduction in 5 years in H.R. 4 was
arbitrarily selected and should be tempered by allowing
more time for needed controls to be put in place.
Ensures that residual health risks are addressed
nationally in a moderate, cost-effective way.
Disadvantages of Alternative 2
Leads to the greatest likelihood of either under- or over-
control for the sake of regulatory convenience.
Any percentage requirement is arbitrary and can't reflect
the purpose of the legislation, which is to achieve
health-based goals.
The baseline data from which reductions take place is
seriously flawed including incomplete data from some
industries and no information from nearly 20 percent of
the sources.
Places a tremendous burden on industry to demonstrate that
arbitrarily set reductions are wrong or that risks are
negligible. Further, waivers and exemptions will be
litigated extensively, especially if the Federal EPA
administers the program.
11
Alternative 3: Establish a risk threshold of between 10-4 and
10-6 (i.e., between one cancer death in 10,000 and one cancer
death in a million individuals at risk). This concept would
require emission reductions beyond MACT to whatever extent was
needed to achieve the tolerable risk level. This may be more or
less than the 90 percent requirement of Alternative 2. A range
of 10-4 to 10-6 is selected because it is often used as a
benchmark in other risk-based decisions in EPA, FDA and OSHA.
EPA has recently extended the range to 10-7 (one in 10 million)
for some Superfund and RCRA decisions but the 10-4 to 10-6 range
remains the most common.
It is assumed that either MACT or the risk range threshold would
apply whichever is the more stringent. This concept is
consistent with other EPA technology-based regulatory programs.
If the risk-based threshold could be achieved through the
employment of less than MACT, plants nevertheless would be
required to put MACT in place subject to the normal costs and
technical feasibility tests. Therefore the health-based
standard applies only to the residual risk and not the overall
level of risk posed by the discharge.
Advantages of Alternative 3
Requires only as much additional reduction as needed to
meet the health-based objectives. On the other hand, this
may require more than the 90 percent reduction in
Alternative 2. It prevents over-controls in the much more
expensive second phase and yet ensures that the health
objectives are met.
It can tailor deadlines for compliance to remaining risk
levels allowing the Nation's finite resources to be
concentrated on the most serious risk remaining and
leaving lesser residual risks to be dealt with later.
Could incorporate the same flexibility for deadline
extension system as in Alternative 2, based on a
demonstration of reasonable further progress.
Disadvantages to Alternative 3
Unlike Option 1, which is based on actual risk, places
entirely too much weight on risk assessment methodologies
and entirely too much power in the hands of modelers.
Could just as easily require greater reduction than the
admittedly arbitrary 90 percent required in Option 2 and
therefore result in higher costs for some plants.
A range of 10-4 to 10-6 will likely end up at 10-5, which
could be technically infeasible. Interim additional
measures need to be added to this option.
12
Costs of Controls
Total industry costs and economic effects can not be estimated
with any accuracy. Such estimates would require knowledge of
which industries would be regulated, and which control options
would be available for each industry. The costs of different
control options would then be evaluated against the economic and
financial viability of the industry before one is selected and
promulgated.
Phase I
In the clear absence of that knowledge several estimates have
been generated with significant estimating error. These range
from $0.7 to $2.6 billion per year. It is generally agreed that
$2 billion per year estimate is a reasonable point estimate for
the Phase I program. Furthermore, the water pollution control
program, which regulated the same industries and pollutants, and
after which the toxic air control program is modeled, is costing
$1.5 - $2.0 billion per year in 1988 dollars.
There will likely be no difference in costs between Alternative
2 and 3, since the issue is one of timing. A BEJ permit process
will achieve much of the reductions sooner whereas Alternative 2
would postpone costs until Federal regulations are in place.
Except for the time-cost of money, total costs can be assumed to
be equal.
Alternative 1 would be less expensive because a reasonable risk
strategy would certainly require no greater than MACT technology
and may avoid regulating several industries entirely.
Phase II
There are even fewer estimates for Phase II, which would be far
more difficult to predict. CMA estimates range from $1 billion
per year to as high as $14 billion per year. An "order of
magnitude" estimate of an additonal $2.0 billion per year over
Phase I controls would represent restrictive health-based
standard for a small percentage of those sources regulated under
Phase I. The principal industrial emitter subject to Phase II
controls would be coke ovens.
A summary of the costs and benefits of these options follow.
13
Costs of Controls
Base Program
Annual Cost
Benefits
Legislative Options
($ 1989)
(Cancer Deaths Avoided)
Base Program
-
700-1200
Phase I
All Options
$0.7 to 2.6B
what we
700-1500
will control
Phase II
Dowd 1/
$1.4 billion
100-300
EPA
$0.5 billion
0-50
CMA 1/
$1-14 billion
100-300
1/ Assumes that risk reduction to 10-6 (one in a million).
14
Decisions
Phase I
LI
Alternative 1. National standards of unreasonable risk.
Ll Alternative 2. National standards of Maximum
Available Control Technology (MACT). .
L]
Alternative 3. Early reductions through permits, then
MACT,
Phase II
L/
Alternative 1. Seek phase II legislation after
evaluation of implemented controls.
L/
Alternative 2. 90 percent rec tion from uncontrolled
level where risk is serious.
L/
Alternative 3. Reduce to risk range threshold.
Attachment
1987 Air Toxics Inventory
Top 25 Toxic Pollutants By Pounds Emitted Per Year
M Lbs./Yr
Percent
Cumulative
Pollutant
Emitted
of Total
Percent
*
1.
Toluene
236
9.8%
9.8%
2.
Ammonia
233
9.7%
19.6%
3.
Acetone
186
7.8%
27.3%
4.
Methanol
183
7.6%
35.0%
5.
Carbon Disulfide
137
5.7%
40.7%
6.
Trichloroethane
131
5.5%
46.1%
7.
Methyl Ethyl Ketone
125
5.2%
51.4%
* 8. Xylene
120
5.0%
56.4%
** 9. Dichloromethane
112
4.7%
61.0%
10. Chlorine
103
4.3%
65.3%
11.
Aluminum Oxide
73
3.0%
68.4%
12.
Ethylene
54
2.3%
70.6%
13. Hydrochloric Acid
50
2.1%
72.7%
14.
Freon 113
49
2.0%
74.8%
*
15. Trichloroethylene
47
2.0%
76.7%
16.
Propylene
37
1.5%
78.3%
17.
Glycol Ethers
32
1.3%
79.6%
18. Tetrachloroethylene
28
1.2%
80.8%
19. M-Butyl Alcohol
27
1.1%
81.9%
20. Methyl Isobutyl Keto
25
1.0%
82.9%
** 21. Benzene
25
1.0%
84.0%
22.
Styrene
25
1.0%
85.0%
** 23. Chloroform
24
1.0%
86.0%
24.
Chloromethane
21
0.9%
86.9%
25.
Carbonyl Sulfide
20
0.8%
87.7%
n
Denotes known neurotoxin.
:
Denotes known carcinogen.
WISHAPS STUDY: PRELIMINARY APPROXIMATION OF ANNUAL INCIDENCE
AND MAXIMUM LIFETIEN RISK
Preliminary Estimate
Pollutants Maving
of Maximum Individual
Preliminary Estimate
Some Evidence of
Individual Lifetime
of Annual
Carcinoganicity
Riskes
Incidence**
Acrylamide
9.4x10-5
0.01
Acrylonitrile
3.8x10-3
0.42
Allylchloride
2.3x10-6
<0.01
Arsenic
6.5x10-3
4.70
Benzene
8.0x10-3
32.30
Benzylchloride
3.0x20-5
<0.01
Beryllium
1.0x10-4
1.20
2.3 Butadiene
9.7x10-6
0.01
Cadrium
9.5x10-4
16.30
Carbon Tetrachloride
5.8x10-4
24.00
Chloroform
3.0x10-3
0.27
Chronium
1.6x10-1
330.0
Coke oven Exissions
2.0x10-2
8.60
Diethanolazine
2.0x10-7
<0.01
Dioctyl phthalate
9.8x10-6
<0.01
Ipichlorehydrin
1.9x10-6
<0.01
Ethyl acrylate
4.7x10-5
<0.01
Ethylene dibrozide
1.6x10-4
26.70
Ethylene dichloride
2.9x10-4
44.00
Ethylene oxide
6.8x20-3
47.80
Forzaldehyde
6.1x10-4
2.60
Methyl chloride
2.2x10-5
<0.01
Methylene chloride
9.0x10-6
2.0
4,4 Methylane dianiline
1.5x10-3
0.02
Nickel
1.6x10-3
80.00
Nitrobenzene
1.2x10-6
<0.01
Nitrosonorpheline
6.0x10-9
<0.01
Pentachlorophenol
1.7x10-5
0.12
Perchloroethylene
4.6x10-4
2.90
PCBs
3.0x10-4
0.21
Propylene dichloride
2.1x10-6
<0.01
Propylene oxide
3.0x10-2
0.97
Styrene
3.3x10-5
<0.01
Terephthalic acid
1.5x10-5
<0.01
Trichloresthylens
2.0x10-4
9.70
Vinyl chloride
3.8x20-3
11.70
Vinylidens chloride
4.2x10-3
0.04
Total
634.7
.
The weight of evidence of earcinogenicity for the corpounds listed
varies greatly, from very limited to very substantial. Further, the
extent of evaluation and health review performed varies considerably
among coxpounds. Novever, for the purposes of this report, a
human carcinogens) has been assumed.
conservative scenarie (1.e., that all corpounds exazined could be
.. Because of the uncertainties in the data used to make these estimates,
they should be regarded as rough approximations of total incidence and
BAXIBUT lifetime individual risk. Estizates of incidence for individual
compounds are such less certain. These incidence and Baxizum risk
estimates have Deen performed to provide a rough idea of the possible
priority-setting and to provide policy guidance.
tetal Bagnitude of the air toxies problem, and will be used only for
Risk estizates assume that all species of chrozium and nickel are
carcinogenic, although only certain species have evidence of
species. carcinogenicity. Current data do not allow differentiation among
Attachment C
Regulatory Activities To Be Undertaken
in the Short Term Under a Modified Section 112
Baseline Cancer
Polluntant/Source Category
Incidence
Benzene
Coke By-Products
3
13-Butadiene
S-B Rubber
10
Chloroform
Pulp and Paper
2
Chromium
Chrome Elecuroplating
120
Cooling Towers
55
Coke Oven Emissions
Coke Ovens
7
Ethvlene Oxide
Sterilization
4
Methvlene Chloride
Solvent Use
4
Perchlorethviene
Dry Cleaning
3
Solvent Use
5
Trichloroethviene
Solvent Use
6
Multi-Pollutant Source Category (HON)
Sources of 13-Butadiene, Carbon Tetrachloride
21
Chioroform, Ethylene Dichloride, Ethylene Oxide,
Methylene chioride, Perchloroethylene, and
Trichloroethylene
Withdrawal/Redaction Sheet
(George Bush Library)
Document No.
Subject/Title of Document
Date
Restriction
Class.
and Type
01b. Report
Attachment D, re: "Elements." (1 pp.)
n.d.
PO
Collection:
Record Group:
Bush Presidential Records
Office:
Speechwriting, White House Office of
Open on Expiration of PRA
Series:
Speech File, Backup
(Document Follows)
Subseries:
By SN (NLGB) on 4/5/2005
WHORM Cat.:
File Location:
Clean Air Act Announcement 6/8/89 [5]
Date Closed:
9/30/2004
OA/ID Number:
06264
FOIA/SYS Case #:
Re-review Case #:
2004-2265-S
P-2/P-5 Review Case #:
MR Case #:
Appeal Case #:
MR Disposition:
Appeal Disposition:
Disposition Date:
Disposition Date:
RESTRICTION CODES
Presidential Records Act - [44 U.S.C. 2204(a)]
Freedom of Information Act - [5 U.S.C. 552(b)]
P-1 National Security Classified Information [(a)(1) of the PRA]
(b)(1) National security classified information [(b)(1) of the FOIA]
P-2 Relating to the appointment to Federal office [(a)(2) of the PRA]
(b)(2) Release would disclose internal personnel rules and practices of an
P-3 Release would violate a Federal statute [(a)(3) of the PRA]
agency [(b)(2) of the FOIA]
P-4 Release would disclose trade secrets or confidential commercial or
(b)(3) Release would violate a Federal statute [(b)(3) of the FOIA]
financial information [(a)(4) of the PRA]
(b)(4) Release would disclose trade secrets or confidential or financial
P-5-Release would disclose confidential advise between the President
information [(b)(4) of the FOIA]
and his advisors, or between such advisors [a)(5) of the P.RA]
(b)(6) Release would constitute a clearly unwarranted invasion of
P-6 Release would constitute a clearly unwarranted invasion of
personal privacy [(b)(6) of the FOIA]
personal privacy [(a)(6) of the PRA]
(b)(7) Release would disclose information compiled for law enforcement
purposes [(b)(7) of the FOIA]
C. Closed in accordance with restrictions contained in donor's deed of
(b)(8) Release would disclose information concerning the regulation of
gift.
financial institutions [(b)(8) of the FOIA]
(b)(9) Release would disclose geological or geophysical information
Attachment D
Elements
1. Chemical list
2. Source Categories List
3. Technology-based standard
4. Residual Risk follow-up
5. Negligible-risk variance and
other correction factors
6. Permit system/permit fees
1. Chemical List
Used to identify and prioritize source categories for
regulation; not for chemical-by-chemical regulation.
Cover credible amount of toxic air releases reported under
Toxic Release Inventory (SARA 313).
2.
Source Categories List
Identified as sources of chemicals on list.
o
Prioritized: Sources of most toxic chemicals released in
largest amounts in urban areas are ranked at the top of
the scale.
3. Technology-based standards
Based on cost and feasibility.
o
Apply to major sources (emit 10 tons per year of one
listed chemical, or 25 tons of a mixture).
o
Achieve a good level of control for toxics emissions
generally.
o
Findings not risk-based, corrections for high-risk under-
control or low-risk, over-controls are separately applied.
4. Residual Risk follow-up
Check risk after technology-based controls are in place.
Further regulate as needed.
5. Negligible-risk variances and other corrections
Sources demonstrate negligible risk to obtain variance
from regulation.
0
EPA discretion to drop source categories causing
negligible risk.
6.
Permits System/Permit Fees
Withdrawal/Redaction Sheet
(George Bush Library)
Document No.
Subject/Title of Document
Date
Restriction
Class.
and Type
01c. Report
"Comparison of H.R. 4 and S. 816." (3 pp.)
n.d.
P.S
Collection:
Record Group:
Bush Presidential Records
Office:
Speechwriting, White House Office of
Series:
Speech File, Backup
Open on Expiration of PRA
Subseries:
(Document Follows)
WHORM Cat.:
By SN (NLGB) on 4/5/2005
File Location:
Clean Air Act Announcement 6/8/89 [5]
Date Closed:
9/30/2004
OA/ID Number:
06264
FOIA/SYS Case #:
Re-review Case #:
2004-2265-S
P-2/P-5 Review Case #:
MR Case #:
Appeal Case #:
MR Disposition:
Appeal Disposition:
Disposition Date:
Disposition Date:
RESTRICTION CODES
Presidential Records Act - [44 U.S.C. 2204(a)]
Freedom of Information Act - [5 U.S.C. 552(b)]
P-1 National Security Classified Information [(a)(1) of the PRA]
(b)(1) National security classified information [(b)(1) of the FOIA]
P-2 Relating to the appointment to Federal office [(a)(2) of the PRA]
(b)(2) Release would disclose internal personnel rules and practices of an
P-3 Release would violate a Federal statute [(a)(3) of the PRA]
agency [(b)(2) of the FOIA]
P-4 Release would disclose trade secrets or confidential commercial or
(b)(3) Release would violate a Federal statute [(b)(3) of the FOIA]
financial information [(a)(4) of the PRA]
(b)(4) Release would disclose trade secrets or confidential or financial
P-5 Release would disclose confidential advise between the President
information [(b)(4) of the FOIA]
and his advisors, or between such advisors [a)(5) of the PRA]
(b)(6) Release would constitute a clearly unwarranted invasion of
P-6 Release would constitute a clearly unwarranted invasion of
personal privacy [(b)(6) of the FOIA]
personal privacy [(a)(6) of the PRA]
(b)(7) Release would disclose information compiled for law enforcement
purposes [(b)(7) of the FOIA]
C. Closed in accordance with restrictions contained in donor's deed of
(b)(8) Release would disclose information concerning the regulation of
gift.
financial institutions [(b)(8) of the FOIA]
(b)(9) Release would disclose geological or geophysical information
Attachment E
Comparison of H.R. 4 and S. 816
Number of Categories Regulated
H.R. 4 (EPA)
O First 50% of initial list to be regulated.
O Second 50% of initial list to be discretionary with
EPA.
O EPA may drop any category presenting negligible risk.
Senate bill
O 100% of initial list to be regulated.
Technology Standard
H.R. 4 (EPA)
O Maximum achievable reduction considering cost and
feasibility.
O New sources: Most stringent achieved in practice by a
source in the category or subcategory, considering cost
and feasibility.
O Existing Sources: may be less stringently controlled
than new sources.
O Variance from compliance when source presents
negligible risk.
O Enforced under operating permit.
Additional
EPA recommendations:
O
Variance for source achieving voluntary 90%
reduction in emissions of listed pollutants in
previous 5 years. (Particulates control credit
may be based more appropriately on a different
percent).
O
Modified sources should be under existing-source
standards not new source standards.
This will limit new source stringency to those
sources that are newly built (or more than half
rebuilt) where industry says it designs
state-of-the-art for business reasons.
Most of the industry concerns about the new
source provision have had to do with modified, not
newly-built sources. This would allay those
concerns.
Senate bill
O Maximum achievable reduction considering cost and
feasibility.
New sources more stringently controlled than existing
sources as under H.R. 4, but existing source benchmark
of expected reduction is 90% reduction from
uncontrolled emissions.
O No variance for regligible risk.
O Enforcement under operating permit.
Alternative
O EPA would provide informational guidance on Best
Practicable Control Technology (BPCT). BPCT would
describe control technologies, their costs and what
emission reductions they yield. The states would use
BPCT information in writing permits for sources.
Residual Risk
H.R. 4 (EPA)
O After-control "significant risk of serious or
widespread adverse effects on health" would prompt
further control (A high risk threshold).
O Added control - up to 90% further reduction in
emissions -- whatever percent protects from significant
risk of serious or widespread effects.
O Compliance period is 5 years.
Senate Bill
O After-control risk of 10⁻⁴ or above prompts further
control.
O Added control to get below 10⁻⁴.
Immediate compliance, but may obtain "extraordinary
economic hardship" extension up to 5 years.
Alternative
O EPA guidance on assessing residual risk.
O States conduct source by assessment and decide on
further control.
(Neighborhood epidemiology studies are not feasible)
Variances
H.R. 4 (EPA)
O Variance from any added control for sources at
negligible risk.
O Grace period of 5 years from time any controls are
installed for purposes of other Clean Air Act programs.
EPA recommended
O Variance from relevant MACT requirements for sources
achieving 90% reduction in emissions of listed
pollutants in the 5 years.
Senate bill
O No variance form MACT for negligible risk.
Source undergoes review, feasible added control (s) and
public hearings every 5th year as long as they are
causing greater than 1 in a million risk to anyone
(10 )
O Variance from relevant MACT requirements for sources
achieving 90% reduction in emissions of listed
pollutants between 1987 and 1993.
Attachment F
ANNUAL RISK OF DEATH FROM CERTAIN ACTIVITIES AND CAUSES
Actual U.S. Deaths in 1983
Cause
Annual Deaths
Heart Disease
733,235
Malignant Neoplasms (Cancer)
403,395
Smoking
337,000
Cerebrovascular Disease (Stroke)
169,488
Motor Vehicle Accidents
53,524
Drowning
6,872
Fires
5,991
Construction Work
2,100
Agricultural Work
1,800
Emissions from Cars & Trucks
1,220
Boating
1,178
Major Stationary Sources
750
Appendicitis
682
Electrocution
500
Weather (tornadoes, floods, lightning)
440
Hunting
290
Snowmobiling
60
Bee Stings
40
Water Skiing
32
Hang Gliding
13
Football
9
Measles
6
Amusement Park Rides
6
Baseball
5
Ingestion of Toothpicks
1
Attachment G
Air Toxics Regulatory Activities To Be Undertaken
Under Other Sections of the Clean Air Act or Other Statutes
Statute/Activity
Baseline
Reduction
Incidence (from
from
existing sources)
Control
Clean Air Act
Motor Vehicles
792 to 1,499
Diesel Particulate Standards
185
Refueling and On-Board Controls
HC Emissions for Light Duty
Trucks
Methanol Emission Standards
Municipal Waste Incinerators
2 to 40
1 to 20
NSPA and 111 (d)
Resource Conservation and Recovery Act
TSDF Rule
140
120
Clean Water Act
Sewage Sludge Incineraton
12
3-9
Attachment "
KEV
Area Sources
(16%)
Point Sources (24%)
150Fs
Hoodsmoke (3.7%)
(6.4%)
Cooling lowers (2.5%)
Geseline Marketing (2.5%)
Coal and 011 Combustion (2.0%)
Selvent Use/Degreasing (1.38)
MOTOR VEHICLES
POTW's (0.6%)
(52.0%)
Other (1.5%)
Electroplaters
(10.58)
Manufacturing Sources (4.0%)
Miscellaneous (2.5%)
Unspecified Sources (2.1%)
Chemical Users and Producers (1.3%)
Iron and Steel (0.8%)
Secondary Formation
of Formaldehyde (6.38)
Relative Contribution of Source Categories to Total
Nationwide Annual Incidence
TABLE OF CONTENTS
OZONE NONATTAINMENT
Page
Part I
Background
1
Part II
Issues on Control Options
Issue 1. Neat Fuels Program
10
Issue 2. Neat Fuels "Opt-Out"
15
Issue 3. Enhanced Inspection and Maintenance
17
Issue 4. Extended Useful Life
18
Issue 5.
Refueling Program
20
Issue 6. Additional State Requirements
22
Part III
Alternatives for Ozone Control
23
Alternative 1
26
Alternative 2
28
Alternative 3.
30
Alternative 4
32
Appendices
34
CARBON MONOXIDE NONATTAINMENT
Part I
Background
1
Part II
Alternatives for Controlling Carbon Monoxide
4
CLEAN AIR ACT OPTIONS PAPER:
OZONE NONATTAINMENT
I. BACKGROUND
The Clean Air Act requires attainment of air quality standards
(NAAQS) that protect public health with an adequate margin of safety.
The Act assumes that all cities would have attained the ozone and
carbon monoxide standards no later than 1987, and gives no guidance
on how Federal, State and local governments should respond to post-
1987 nonattainment. This has left the Federal Government vulnerable to
lawsuits that can force EPA to take over State and local responsibilities
by developing Federal implementation plans (FIPS) to attain the
standard. Legal actions of this sort are already underway in various
parts of the country and more are likely.
Congress has attempted to enact a nonattainment bill for the past
several years. All Congressional proposals would have extended
attainment deadlines. However, these bills would also have required
nonattainment areas to implement a variety of control measures - some
expensive and potentially requiring major lifestyle changes -- in return
for extension of the deadlines.
Because of the controversial nature of the control measure requirements,
none of the proposals has ever moved close to enactment. Last year's
Senate bill (S. 1894), sponsored by Sen. Mitchell, is the most stringent
bill. It included tight deadlines, the most stringent control measures,
and the largest number of Federally mandated controls. On the House
side, the Waxman bill (H.R. 3054) was similar to the Mitchell bill in
stringency, but was marginally less costly and less prescriptive. The
"Group of Nine" Democrats in the House proposed a still more
moderate bill with longer deadlines, lower cost, and fewer Federally
mandated control measures than either Mitchell or Waxman.
Formation of ozone
Unlike other NAAQS pollutants, ozone - the major component of
urban smog - is not emitted directly. Instead, it is formed when
volatile organic compounds (VOCs) are mixed with nitrogen oxides
(NOx) in the presence of sunlight. Heat speeds up the reaction, and
therefore concentrations are usually higher in the summer months.
Areas with hotter climates, such as Los Angeles and Houston, are
especially susceptible to ozone problems.
EPA's ozone control strategy focuses on VOCs. NOx controls generally
reduce ozone but can increase its formation in certain situations. Since
ozone reacts upon contact with surfaces, ozone exposure is not a
problem indoors.
Sources of VOCs
The major sources of VOCs are motor vehicles (40%); small "area
sources", e.g., bakeries, dry cleaners, and consumer solvents (40%);
large point sources, e.g., petroleum refineries (15%); and gasoline
refueling (5%). Many large point sources have already been required to
reduce emissions by roughly 80% from uncontrolled levels under the
Clean Air Act, and tailpipe emissions from new vehicles have been
reduced by 90%. The smaller "area" sources are largely uncontrolled.
Trends in emissions and ambient levels
VOC and NOx emissions have decreased nationally since 1978 -VOCs -
by 17 percent and NOx by 8 percent - despite growth in population,
travel, and industrial activity. As a consequence, the trend in ambient
ozone concentrations was actually down by 9 percent from 1979 to 1987.
Increases did occur in 1987 and 1988, although it should be noted that
those increases occurred in years with abnormally high summer
temperatures.
The downward trend in VOC emissions is largely due to growth in the
share of newer, more stringently controlled vehicles in the vehicle fleet.
These "fleet turnover" reductions have been achieved despite a 25%
growth in vehicle miles travelled (VMT). Over the next decade,
however, both EPA and the Federal Highway Administration estimate
that VMT will begin to outpace fleet turnover and that VOC emissions
will increase after 2000. EPA projects a 60 percent increase in VMT by
2005, although the Federal Highway Administration expects a lesser
40% increase.
Effects
The current ozone standard is 0.12 parts per million (ppm) over a one-
hour period. The health-based standard is designed to protect healthy
exercising individuals from acute respiratory symptoms (coughing, chest
pain, shortness of breath) that are usually temporary and reversible.
Ozone is also suspected of playing a role in the long-term development
of chronic lung diseases, permanent lung structure damage, and in
initiating asthma attacks. EPA's Clean Air Science Advisory Committee
is currently debating whether the standard should be tightened to create
a more appropriate margin of safety, based on chronic effects. The
Committee is unanimous that the standard should not be relaxed.
In addition to health effects, ozone has "welfare" effects on vegetation,
including crops such as soybeans, wheat, and corn; is damaging forests
in southern California; and is suspected as a contributing agent in
damage to forests in the Southeastern U.S.
Nonattainment
An area is classified as being in nonattainment if the 0.12 ppm standard
is exceeded at the highest reading monitor more than three hours on
separate days over a consecutive three-year period. The so-called
"design value" is the fourth-highest reading over a running three-year
period. The design value reading is frequently used as a proxy for the
severity of the ozone problem in an area. It is also the primary basis
for categorizing areas according to severity in Congressional bills.
Based on 1988 data, 81 cities, with an aggregate population of 100
million people, are in nonattainment for ozone. While individuals
usually are exposed to levels that exceed the standard only a small
percentage of the time, over 30 cities exceeded the standard 10 or more
days in the hot summer of 1988.
The degree to which urban areas do not attain the standard varies
dramatically, from Los Angeles with readings 200 percent above the
standard and exceedances 140 days of the year, to Kansas City which
exceeded the standard four times in a two-year period. Los Angeles is
a special case -- it has four times the number of exceedances of any
other city in America. Appendix A shows the 1987 design values and
the number of exceedances for nonattainment areas.
Chart 1 shows the number of cities that will remain out of attainment
(absent additional State control measures) for different levels of VOC
reductions beyond the current program.
Chart 1
Number of Non-Attainment Areas Remaining After Applying
Additional Control Measures
1995
2000
2005
Current Program
58
58
72
+ 15%
32
33
51
+ 20%
26
26
32
+ 25%
14
18
26
+ 30%
9
10
14
+ 35%
4
4
9
+ 40%
2
2
4
NOTE: Projections are very sensitive to vehicle miles travel (VMT) projections, which vary widely.
upoons
Benefits of VOC reductions
EPA has evaluated health benefit categories for which it could value the
effects in the Northeast. These categories include primarily short-term
respiratory effects. They do not include the more serious categories
such as potential long-term chronic effects and structural changes in lung
function. This evaluation indicates that the value of these limited
categories ranges up to $2600/ton with a "best guess" point estimate of
$480 per ton. This does not include additional benefits that would be
gained by reductions in air toxics from mobile sources, which are
estimated to range up to $750/ton. Recent estimates are that the
economic consequences of ozone effects on crops approach $2 billion
per year. This does include damage to forests or materials.
Costs of VOC reductions
EPA's current vehicle tailpipe standards, along with State vehicle
inspection/maintenance programs and other State control measures, will
reduce VOC emissions by about 9% in 2005, net of growth. One
analysis done for EPA estimates that these measures will add about $7
billion in annual costs to the economy by the year 2000.
EPA estimates that requiring certain Federal control measures that
together achieve a 29% reduction in VOC emissions (38% including
current gasoline volatility controls) beyond the base program would cost
about $3-4 billion per year beginning in the early 1990s. According to
EPA, reductions beyond this amount -- which the Agency proposes to
achieve through a requirement for 3% annual VOC reductions -- would
cost an additional $5-9 billion per year beginning in the late 1990s,
resulting in a total additional cost above the current program of $8 to
$13 billion annually in order to bring all cities into attainment.
Estimates by other sources of the cost of achieving attainment are even
higher. This is due to higher estimates of the cost of specific control
measures and to the assumption of higher costs for additional,
unidentified controls that States would have to develop and implement
to reach attainment.
Current program
Federally mandated ozone control measures already in place include:
vehicle tailpipe emission controls; gasoline volatility restrictions (Phase
I); vehicle inspection & maintenance programs for certain nonattainment
areas; emission limits for various VOC source categories; and State
controls on existing stationary sources for which EPA has issued
"Control Technology Guidelines" (CTGs).
State Implementation Plans (SIPs) also already include additional
controls measures developed and implemented by the States in order to
demonstrate attainment. For example, areas with relatively severe ozone
problems may include controls on stationary sources of VOCs not
covered by Control Technology Guidelines.
EPA also has several regulations under development that will further
reduce VOC emissions: vehicle evaporative emission controls; light duty
truck emission standards; hazardous waste facility air emissions
regulations; vehicle refueling controls and additional gasoline volatility
restrictions (Phase II).
Additional measures
Based on EPA's estimates of VOC emissions, VMT growth, and
stationary source growth, the current and proposed measures discussed
above will not be sufficient to bring all areas into attainment by 2005.
Together, these measures are expected to achieve a percentage reduction
in VOC emissions of about 29 percent (above and beyond the 18
percent reduction from base programs already underway or planned
under current law). Eighteen of the areas will need percentage
reductions beyond the base program of more than 29 percent to achieve
attainment in 2005 and the four areas with the worst ozone problems
will need to achieve reductions of 50% or greater.
Potential measures for achieving attainment in those areas needing
controls beyond current and proposed measures can be divided into
three categories: 1) nationwide controls Federally mandated, 2)
nonattainment area controls Federally mandated, and 3) nonattainment
area controls developed by the States through SIPs.
While one way to achieve attainment might be to simply extend
attainment deadlines and let States develop and implement all
additional controls measures, this approach has several drawbacks. First,
many States have failed thus far to implement the measures committed
to in SIPs because of their cost and/or disruption of lifestyles. Second,
several control measures with the potential to achieve large, relatively
cost-effective reductions are more appropriately implemented at the
national level.
Some also argue that additional controls should include Federally
mandated requirements specifically for nonattainment areas. While
controls in this category would limit State discretion in designing control
measures and would risk over-control for some nonattainment areas,
such controls would provide a better guarantee (recognizing previous
experience) of progress toward attainment. To correct for the problems
inherent in mandating State action, some have suggested that States be
allowed to "opt out" of Federally mandated measures if they can
demonstrate that a substitute measure would achieve at least the same
VOC reduction.
Finally, even if every control measure discussed within the working
group were included as part of the Administration proposal, the
percentage reduction achieved would still not be sufficient to bring all
areas into attainment. Those nonattainment areas requiring over
29 percent reductions in VOCs by 2005 beyond the base program would
still need to develop and implement additional control measures. Such
measures might include restrictions beyond Federal emission limits on
new sources, tighter restrictions on existing stationary sources, tighter
enforcement of existing regulations, transportation control measures
designed to reduce VMT and market based strategies.
Nationwide control measures
Nationwide control measures would affect both areas in and out of
attainment. If a neat fuels program is included in serious and severe
nonattainment areas, the percentage reductions achieved in these areas
by the other mobile source measures on the list will decrease, and vice
versa.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 7
The table below provides estimates of the cost-effectiveness and
percentage reductions achieved by potential nationwide measures. Some
of the percentage reductions would be smaller if a neat fuels program is
included. Those proposals which sparked considerable discussion in the
working group are marked by asterisks. Separate discussion papers on these
subjects follow.
2005 Cost
Nationwide
% VOC
Effectiveness
Annual Costs
Reduction
$/Ton
($M)
1.° Onboard Controls 2.6
0 - 2,500
0 - 1,500
Would require automobile manufacturers to put canisters on every vehicle to
prevent refueling emissions. The same refueling emissions could also be captured
by Stage II controls installed at service stations only in nonattainment areas.
(See next page.)
2.* Extended Useful
1.0
525
130
Life
EPA would promulgate regulations extending the design life of emission control
devices from 50,000 to 100,000 miles. State/local governments in-use
testing/inspection of vehicles for compliance would cease after 75,000 miles and
the manufacturer's warranty would continue for 50,000 miles as currently
required.
3. Light Duty Truck
Emissions
0.2
650
33
Requires light duty trucks (e.g., pickups, mini-vans) to meet the same 0.41 grams
per mile (gpm) standard currently being met by automobiles. Heavier trucks
would have to meet a 0.50 gpm standard. Although small reductions are
obtained, the growth in small trucks as a substitute for automobiles is expected to
continue and on equity grounds alone similar emission standards should be met.
4. Commercial/consumer
Products
2.5
0 -2,000
640
EPA would be authorized to regulate VOC emissions from a variety of smaller
sources such as consumer solvents, paints, barge loading and municipal landfills.
This would be a new Clean Air Act authority for EPA.
5. Automotive Tailpipe
0.4
1,200
114
Controls
EPA would promulgate a regulation to tighten the VOC emission standard to the
level currently required on all California vehicles (from 41 to .25 grams per
mile). This represents a 98% reduction from uncontrolied levels, and a 2%
reduction beyond current tailpipe standards.
Federally Mandated Control Measures for Nonattainment Areas Only
Below is a list of Federal mandates which States could be required to
implement unless they could demonstrate alternative local measures with
commensurate VOC reductions.
2005 Cost
Nationwide
% VOC
Effectiveness
Annual Costs
Reduction
$/Ton
($M)
1.* Neat Fuels Programs
7.4 (2005)
390 - 11,000
244
EPA Proposal - 50%
12.4 (2010)
390 - 11,000
N/A
With Other Measures
1.7 (2005)
1,200 - 11,000
244
4.2 (2010)
1,200 - 11,000
N/A
One option would require that, beginning in 1995, 50% of all vehicles in severe
and serious nonattainment areas use neat fuels (methanol, ethanol, compressed
natural gas) and that service stations provide neat fuels in these areas at prices
competitive with gasoline. Another option would require neat fuels only for
urban buses and centrally fuelled fleets of 10 or more vehicles. The figures
above are for the former option.
2.* Stage II Controls
1.5
450 - 1,000
60 - 135
Would require service stations in nonattainment areas to install special nozzles to
prevent refueling emissions. The same refueling emissions could also be captured
by onboard controls imposed on vehicles nationwide.
3. Control Technology
Guidelines (CTGs)
3.5
0 - 2,000
430
EPA would issue, subject to the normal regulatory review process, stationary source
guidelines for states to use in controlling existing major emitters in nonattainment
areas. EPA would issue the most cost-effective CTG's first so that states will always
be assured that least-cost control strategies are being implemented.
4.* Enhanced I/M
1.2
1,200
90
EPA would mandate that states improve and expand their inspection programs in
non-attainment areas. This would include increasing the stringency of inspections
and requiring added tampering and fuel switching checks to existing programs.
Graph 1 (below) shows the number of cities brought into attainment by
individual control measures.
Clean Air Act Options Paper: Ozone NonAttainment
May 22, 1989
Page 9
Graph 1
EFFECT OF VOC CONTROL MEASURES ON # OF CITIES
BROUGHT INTO ATTAINMENT IN 2005
This chart shows how many cities will be brought into attainment
by achieving incremental reductions of VOCs; the reductions
could be achieved by the kinds of measures listed.
Cities
Cum. VOC
Cities Remaining
% Reduction
Out of Attainment
Current Program (18.0%)
(18.0)
72
(includes Volatility Phase 1)
Cum. Reductions
Beyond Current Program
Volatility - Phase II (8.0%)
8.0
58
Vehicle Evaporative (4.2%)
12.2
54
Haz. Waste Facilities (3.2%)
15.4
51
Consumer Solvents (2.5%)
17.9
35
Oxygenated Fuels (0.5%)
18.4
33
Light Duty Truck Stds. (0.2%)
18.6
33
Enhanced I&M (1.2%)
19.8
33
Refueling (2.6%)
22.4
30
CTGs (3.5%)
25.9
26
Extended Useful Life (1.0%)
26.9
26
Auto Tailpipe (0.4%)
27.3
21
Neat Fuels (1.7%)
29.0
18
18 cities still out
of attainment
0
10
20
30
40
50
60
70
80
% VOC Reduction
Needed for Attainment
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 10
II: ISSUES ON CONTROL OPTIONS
Issue 1.
Should the Administration propose a program to encourage
and/or require the use of "neat fuels" in buses, fleets, and
private automobiles.
Options:
1.
Require "neat fuels" in all urban buses and fleets of
10 cars or more.
2.
Require that 50% of the fleet in "serious" and
"severe" nonattainment areas be neat-fueled vehicles.
3.
Let States "opt out" of the 50% requirement if they
can demonstrate commensurate reductions in the
nonattainment areas through other measures.
Discussion: The President has long been an advocate of removing
barriers to market entry for alternative fuels and of promoting their
use. During the campaign, he stated:
"One of my priorities as Vice President has been to lead the search
for alternative fuels so-called 'clean fuels' such as methanol made
from remote natural gas and ethanol made from grain -- and to
promote their use."
(Speech at Scripps Institution, San Diego, CA, October 14, 1988).
Current automobiles are capable of using blends of gasoline and
alternative fuels such as methanol and ethanol. While these blends can
achieve major CO reductions, achieving major VOC reductions from
mobile sources would require "neat fuels", such as compressed natural
gas (CNG), and pure ethanol or methanol. The use of these alternative
fuels would also reduce aromatic emissions from gasoline, especially
benzene, a know carcinogen. HHS has argued that the most important
issue from a public-health perspective is to reduce potentially harmful
vehicle aromatic emissions. Aromatics currently constitute over
25 percent of hydrocarbon emissions from gasoline-powered vehicles
(3 percent benzene, 22 percent other aromatics).
Neat-fueled buses are now operating in several cities and prototype
neat-fueled passenger cars have been successfully demonstrated.
However, for neat-fueled vehicles to come into widespread use, neat
fuels must be priced competitively with gasoline. At present, neat fuels
generally are not competitive, but this is due in part to economies of
scale currently achieved by the gasoline production and distribution
system.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 11
In addition, according to one industry estimate, it would require the
construction of 90 world scale methanol plants to provide enough
methanol to meet the motor vehicle needs of California alone. There
are currently 16 world scale methanol plants in the non-Communist
world.
Neat fuels proponents argue that the environmental benefits of neat
fuels outweigh the costs of ensuring their availability at competitive
prices through Federal mandate and that these costs will diminish over
time as neat fuel vehicle and fuel systems begin to achieve economies of
scale. Skeptics contend, however, that ensuring the availability of neat
fuels would be much more costly than proponents assume and would
inappropriately require extensive intervention into both the fuel and
vehicle markets.
Because of the disagreement over the desirability and feasibility of a
neat fuels program, the option of letting States with ozone
nonattainment areas "opt out" of a mandatory Federal program and the
option of requiring a program limited to buses and centrally fueled
fleets of ten or more are also presented.
Option 1: Require the use of neat fuels in all new urban transit buses and
all urban fleets of 10 cars or more in 25 severe and serious nonattainment
cities beginning in 1992
Advantages of Option 1
Follows up on the President's promise to enhance the use of neat
fuels. Dirty buses and black soot they emit are a symbol of
urban pollution; clean buses would be a highly visible start of a
neat fuels program.
Bus fleets are centrally fueled so that fuel availability is not a
major problem.
Allows for gradual introduction of neat fuel vehicles to help
resolve outstanding concerns (e.g., safety) and demonstrate
benefits of these vehicles.
Disadvantages of Option 1
Would not be cost-effective since only 0.6% VOC reductions
would be achieved and cost would be about $10,000 per ton. A
larger program is needed to be both cost-effective and
environmentally effective.
Would substantially increase the cost of acquiring buses and other
fleet vehicles.
Would not help neat fuels overcome the formidable barriers to
entry since Federal mandate would create a de minimis market.
Clean Air Act Options Paper: Ozone NonAttainment
May 22, 1989
Page 9
Graph 1
EFFECT OF VOC CONTROL MEASURES ON # OF CITIES
BROUGHT INTO ATTAINMENT IN 2005
This chart shows how many cities will be brought into attainment
by achieving incremental reductions of VOCs; the reductions
could be achieved by the kinds of measures listed.
Cities
Cum. VOC
Cities Remaining
% Reduction
Out of Attainment
Current Program (18.0%)
(18.0)
72
(includes Volatility Phase I)
Cum. Reductions
Beyond Current Program
Volatility - - Phase II (8.0%)
8.0
58
Vehicle Evaporative (4.2%)
12.2
54
Haz. Waste Facilities (3.2%)
15.4
51
Consumer Solvents (2.5%)
17.9
35
Oxygenated Fuels (0.5%)
18.4
33
Light Duty Truck Stds. (0.2%)
18.6
33
Enhanced I&M (1.2%)
19.8
33
Refueling (2.6%)
22.4
30
CTGs (3.5%)
25.9
26
Extended Useful Life (1.0%)
26.9
26
Auto Tailpipe (0.4%)
27.3
21
Neat Fuels (1.7%)
29.0
18
18 cities still out
of attainment
0
10
20
30
40
50
60
70
80
% VOC Reduction
Needed for Attainment
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 10
II. ISSUES ON CONTROL OPTIONS
Issue 1.
Should the Administration propose a program to encourage
and/or require the use of "neat fuels" in buses, fleets, and
private automobiles.
Options:
1.
Require "neat fuels" in all urban buses and fleets of
10 cars or more.
2.
Require that 50% of the fleet in "serious" and
"severe" nonattainment areas be neat-fueled vehicles.
3.
Let States "opt out" of the 50% requirement if they
can demonstrate commensurate reductions in the
nonattainment areas through other measures.
Discussion: The President has long been an advocate of removing
barriers to market entry for alternative fuels and of promoting their
use. During the campaign, he stated:
"One of my priorities as Vice President has been to lead the search
for alternative fuels .. so-called 'clean fuels' such as methanol made
from remote natural gas and ethanol made from grain -- and to
promote their use."
(Speech at Scripps Institution, San Diego, CA, October 14, 1988).
Current automobiles are capable of using blends of gasoline and
alternative fuels such as methanol and ethanol. While these blends can
achieve major CO reductions, achieving major VOC reductions from
mobile sources would require "neat fuels", such as compressed natural
gas (CNG), and pure ethanol or methanol. The use of these alternative
fuels would also reduce aromatic emissions from gasoline, especially
benzene, a know carcinogen. HHS has argued that the most important
issue from a public-health perspective is to reduce potentially harmful
vehicle aromatic emissions. Aromatics currently constitute over
25 percent of hydrocarbon emissions from gasoline-powered vehicles
(3 percent benzene, 22 percent other aromatics).
Neat-fueled buses are now operating in several cities and prototype
neat-fueled passenger cars have been successfully demonstrated.
However, for neat-fueled vehicles to come into widespread use, neat
fuels must be priced competitively with gasoline. At present, neat fuels
generally are not competitive, but this is due in part to economies of
scale currently achieved by the gasoline production and distribution
system.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 11
In addition, according to one industry estimate, it would require the
construction of 90 world scale methanol plants to provide enough
methanol to meet the motor vehicle needs of California alone. There
are currently 16 world scale methanol plants in the non-Communist
world.
Neat fuels proponents argue that the environmental benefits of neat
fuels outweigh the costs of ensuring their availability at competitive
prices through Federal mandate and that these costs will diminish over
time as neat fuel vehicle and fuel systems begin to achieve economies of
scale. Skeptics contend, however, that ensuring the availability of neat
fuels would be much more costly than proponents assume and would
inappropriately require extensive intervention into both the fuel and
vehicle markets.
Because of the disagreement over the desirability and feasibility of a
neat fuels program, the option of letting States with ozone
nonattainment areas "opt out" of a mandatory Federal program and the
option of requiring a program limited to buses and centrally fueled
fleets of ten or more are also presented.
Option 1: Require the use of neat fuels in all new urban transit buses and
all urban fleets of 10 cars or more in 25 severe and serious nonattainment
cities beginning in 1992
Advantages of Option 1
Follows up on the President's promise to enhance the use of neat
fuels. Dirty buses and black soot they emit are a symbol of
urban pollution; clean buses would be a highly visible start of a
neat fuels program.
Bus fleets are centrally fueled so that fuel availability is not a
major problem.
Allows for gradual introduction of neat fuel vehicles to help
resolve outstanding concerns (e.g., safety) and demonstrate
benefits of these vehicles.
Disadvantages of Option 1
Would not be cost-effective since only 0.6% VOC reductions
would be achieved and cost would be about $10,000 per ton. A
larger program is needed to be both cost-effective and
environmentally effective.
Would substantially increase the cost of acquiring buses and other
fleet vehicles.
Would not help neat fuels overcome the formidable barriers to
entry since Federal mandate would create a de minimis market.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 12
Option 2: In addition to Alternative 1, require beginning in 1995 that 50
percent of all new vehicles, including passenger cars, buses, and commercial
cars and truck fleets in 25 of the worst ozone areas have the capability of
using neat fuels. In addition, require fuel wholesalers and retailers in these
areas to make neat fuels available at prices competitive with gasoline.
Advantages of Option 2
Creates a broad market for neat fuels and neat-fueled vehicles
while still allowing the marketplace to choose the type of neat
fuel that best suits local economic and environmental
circumstances.
Could be a major component of the President's toxic air pollution
control strategy. It provides substantial reduction in urban air
toxic emissions such as benzene, 1-3 butadiene, polycyclic organic
matter and diesel particulate. While direct formaldehyde
emissions increase somewhat, indirect formaldehyde decreases
even more due to the lower reactivity of methanol emissions.
Represents the largest and most dramatic control measure for
automobiles, thus obviating the need for other more costly
automobile controls.
Disadvantages of Option 2
If other motor vehicle control measures are adopted, provides
only small VOC reductions (1.7% by 2005).
Requires the Federal Government to impose new extensive,
regulation on vehicle manufacturers and refineries in order to
artificially create new markets. In the short term, most methanol
would have to be imported from the Mideast, the Caribbean, and
perhaps some Pacific nations.
May not be workable. Issues of how to induce consumers to
purchase neat fueled vehicles and to assure that neat fuels will be
sold at prices competitive with gasoline remain unresolved. The
imposition of gasoline prices controls by local governments may
be required. Moreover, many technological issues regarding the
development of neat fueled vehicles remain unresolved.
Methanol is not economically competitive with gasoline, costing
30% or more at current prices, and may not be so in the next
ten years. OTA (April 1988) estimated a cost-effectiveness of
$38,000/ton based on a projected 50% price differential.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 13
Option 3. Same as Alternative 2 but allow individual States to "opt out" of
the alternative fuel mandate in exchange for other ozone controls (not
otherwise required by law) that result in equal or greater air quality
improvements than alternative fuels in these nonattainment areas.
Advantages of Option 3
Both opponents and proponents argue that this option will prove
their case.
All of the benefits of Options 2 and more cost-effective, because
States could substitute other ozone control measures if they are
cheaper than the alternative fuels option.
Allows some "targeting" of alternative fuels to the cities that
would benefit most.
Allows at least partial local decision-making, and thereby avoids
imposition of Federal mandates with no flexibility.
Disadvantages of Option 3
Reduces economies of scale and size of the Federally established
market.
Adds considerable uncertainty concerning the size and scope of
the program, which will delay implementation and raise concerns
over long-term commitment to a serious shift to these fuels.
If other Federally mandated mobile source control measures are
not required by legislation, it is very unlikely that many states can
make the necessary showing that other ozone controls resulting in
equal or greater reductions are available.
Note: If a neat fuels program is included in severe and serious
nonattainment areas, the percentage reductions achieved in those
areas by the other mobile source measures on the list will
decrease, and vice versa. Therefore, the reduction achieved by
each mobile source measure is presented in Chart 2 in two ways:
first, assuming that neat fuels measures are not adopted; second,
assuming that all measures, including neat fuels are adopted.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 14
Chart 2
COMPARISON OF VOC REDUCTIONS ACHIEVED BY VARIOUS
MOBILE SOURCE CONTROL MEASURES
VOC Reductions by Year 2005
With Baseline 1/
Controls but
With (or After) 1/
Neat Alternative Fuels
Without Other
Baseline Controls
(Methanol or Compressed
Federal Mobile
& Other Federal Mobile
Natural Gas)
Source Measures
Source Measures
1. 50 percent mandate
7.4
1.7
in 25 serious and
and severe non-
attainment cities
with local opt-out
(2005)
2. Same mandate in 2010
12.4 (2010)
4.2 (2010)
3. Gas Volatility (Phase II)
(RVP from 10.5 to 9.0)
8.0
5.2
4. Stage II Vapor Recovery
1.5
1.1
5. Enhanced Inspection
and Maintenance
1.2
0.8
6. Extending Useful Life
of Catalysts
1.0
0.7
7. Hydrocarbon Tailpipe
0.4
0.3
1/ Note: These reductions are relative to the year 2005. The neat fuel reductions
would be higher if based on 2010.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 15
Issue 2. To what extent should the Act allow States to opt out of a
neat fuels program by implementing other control activities
instead?
Option 1. States opting out would impose alternative controls based on
their own (rather than EPA) baseline projections and
estimates of reductions achievable from such controls. States
would be required to notify EPA within 18 months if they
plan to "opt out," and must adopt an alternative program
(including any necessary enabling authority) within 12 months
after notification to EPA. An alternative program must
achieve the same resulting emissions levels as would be
obtained through the implementation of a mandatory neat
fuels program using EPA baseline projections. EPA would
retain authority to rebut and overturn a State alternative plan
through a rule-making action. Any State whose alternative
control plan was overturned by EPA would then automatical
become subject to the mandatory neat fuel requirements.
Option 2. States may opt out of a neat fuels program if EPA approves
replacement controls that provide equal or greater long-term
environmental benefits (including toxic air emissions) than
those achieved by neat fuels. Alternatives must be over and
above those required by the Act and must be approved by
EPA within 18 months of adoption of Clean Air Act
amendments.
Discussion: While all members of the working group believe that
States should have flexibility to substitute alternatives, such as local
transportation plans or additional stationary source controls, in lieu of a
neat fuels program, the amount of flexibility is a significant issue.
Advantages of Option 1
Provides States with more flexibility than Option 2 to pursue less
costly alternative control measures, but would still achieve the same
emissions levels as the mandatory neat fuels program.
EPA's mobile source estimates are based on questionable
assumptions. This alternative gives States the flexibility to make
revisions to the estimates.
States would be fully responsible for defending VOC estimates and
alternative measures, relieving the Federal Government of any legal
risk or responsibility if States impose unpopular measures.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 16
Disadvantages of Option 1
EPA will be in the undesirable position of initiating a rule-making
action if there are unresolved disagreements with a State.
If some States' estimates are found to be faulty, then those States
would be forced to adopt a neat fuel program at an accelerated
pace.
These provisions would radically deviate from the current Clean Air
Act which requires that EPA approve all reduction estimates made
by States to achieve ambient health standards.
Advantages of Option 2
Provides ample flexibility consistent with the current statutory
requirement that EPA either approves a proposed State action or
implements a Federal program necessary to achieve the health
standard.
Avoids the obvious tendency to seek short-term non-controversial
measures that avoid exceedances but do not result in long-term
reductions.
The 18 month rule forces States to declare their intentions early so
that the fuels industry will know the extent of neat fuels
requirements nationwide and can begin to establish refining and
distribution networks.
Disadvantages of Option 2
Requiring that alternative controls be subject to EPA approval will
preclude their implementation. EPA assumptions clearly favor a neat
fuels program.
Continues the overly inflexible and intrusive Federal intervention in
State/local government affairs that exists throughout the Clean Air
Act.
It is unfair to require air toxics reductions as a condition of an opt
out that would not be required in areas not subject to the neat fuels
program.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 17
Issue 3. Require that all serious and severe ozone and CO
nonattainment areas implement enhanced vehicle Inspection
and Maintenance (I/M) programs.
National Cost: $90M; Cost/ton: $1,200/ton; %VOC Reduction: 1.2%
Discussion: Essentially all areas that would be required to have
enhanced I/M already have basic I/M programs. Enhanced I/M would
require a more thorough check of the car, i.e., tampering and fuel
switching checks in addition to the existing exhaust check.
Advantages:
With many of the administrative overhead and consumer
inconvenience costs already in place, enhancements via a more
thorough inspection and repair can be made cost-effectively.
The option avoids confrontation on the issues that are most sensitive
with state legislatures (new programs and expanded coverage area),
and allows states to make local decisions on those points.
Disadvantages:
Inspection and maintenance programs have been enormously
controversial and have met with stiff consumer resistance. Even the
suggestion of more rigorous inspections would be controversial.
At $1200 per ton removed, this is one of the least cost-effective
measures under consideration.
Technology improvements in future vehicles will make I/M less
effective. For example, vehicles that can self-diagnose problems,
alert the driver and direct a mechanic to properly repair the problem
will go a long way to alleviating the very problems that I/M
programs catch. Also, the disappearance of leaded gas at many
service stations will reduce mis-fueling.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 18
Issue 4. Extend the statutory definition of "useful life" for passenger
cars from 5 years/50,000 miles to 10 years/100,000 miles.
National Cost: $130M; Cost/ton: $525/ton; %VOC Reduction: 1.0%
Discussion: The current law restricts the useful life of cars to 5 years
or 50,000 miles, whichever comes first. This provision effectively limits
the auto manufacturers' liability to design and produce emission control
systems that are durable only for this length of time. Of course, cars
are operated for much longer periods of time.
The useful life definition for passenger cars would be 10 years/100,000
miles as it applies to the certification and in-use (recall) requirements;
however, recall test vehicles would be limited to 75,000 miles. The
warranty requirements, which are the most politically contentious
because of the strong opposition of the aftermarket service industry to
any extension, would remain at 5 years/50,000 miles.
Advantages:
Provides one of the more cost effective reductions, affecting all
passenger car tailpipe and evaporative pollutants by requiring more
durable emission control equipment; affected pollutants are tailpipe
hydrocarbons, carbon monoxide, oxides of nitrogen, and evaporative
gasoline vapors, and mobile source toxics.
An extended useful life for cars is clearly not a technical problem.
For other vehicle classes EPA has the authority to set the
appropriate useful life. Vehicle manufacturers since 1984 have had
to build light trucks to comply with standards for 120,000 miles.
Heavy trucks and buses have useful lives, depending on weight
classification, that extend up to 290,000 miles. Only for automobiles
does the Clean Air Act restrict the useful life to 50,000 miles.
Disadvantages:
Greatly increases performance requirements on the automobile
industry, which is already being hit hard by other proposed control
measures.
Will cost $25 per vehicle for a total cost of about $250 million per
year.
Most excess emissions above 50,000 miles may be maintenance
related. A longer useful life will only slightly help that problem.
Clean Air Act Options Paper: Ozone NonAttainment
May 22, 1989
Page 19
Typical Emissions System Performance
E
M
I
Present Standard
S
S
PRESENT TASK
50,000 miles
I
O
N
100,000 Mile
Useful Life
TASK WITH EXTENDED
USEFUL LIFE
L
E
V
E
L
O
50,000
100,000
USEFUL LIFE (Miles)
Source: Ford Motor Company
EPA Note: The above theoretical chart, provided by the auto companies,
conflicts with emissions data from those same companies. Since,
1984, light trucks have had a full (120,000 mile) useful life
requirement. The data submitted to EPA by vehicle manufacturers
when certifying light trucks indicate a deterioriation curve
which flattens out (not continues to increase) after 50,000
miles. This shows it is technically feasible to improve emission
control system durability while not having to lower the "zero-
mile emissions level.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 20
Issue 5. Form of Refueling Requirement
Refueling Options:
1. Require "Stage II" devices on gasoline pumps at service stations
in ozone non-attainment areas only.
2. Require onboard controls on all future gasoline-powered vehicles
nationwide.
Gasoline vapors escape during vehicle refueling. These VOC vapors can
be controlled by either ensuring that gas pump nozzles fit tightly over
gas intake tubes or installing onboard canisters to capture vapors that
would otherwise escape during vehicle refueling.
An EPA regulation known as Stage I required that many non-attainment
cities install controls on gasoline storage tanks at service stations during
in the late 1970s and early 1980s. The debate over further control of
refueling emissions, if any, has been raging ever since that time. Hence,
the term "Stage II." In the absence of new legislation, environmental
groups have filed successful suits against large non-attainment cities to
require Stage II controls. California, St. Louis, New York, New Jersey
and Washington, D.C., have or will put Stage II controls in place.
Others such as Massachusetts and Connecticut are awaiting the outcome
of the legislative debate, but may be forced by the courts to implement
these controls anyway.
The automobile and petroleum industries are naturally divided on this
issue. In addition, non-industry estimates also vary widely and are
below. contradictory. Therefore, high and low estimates for each are presented
Annual Costs
%reduction
Cost Effectiveness
Nationwide
Control Technique
VOC
$/Ton
$M
1. Onboard
2.6
Credit - 2,500
Proponents
Credit
720
Opponents
2,500
900
2. Stage II
1.5
450-1,000
Proponents
450
170
Opponents
1,000
870
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 21
Advantages of Stage 11 devices at gasoline pumps (Refueling Option 1)
Stage II can be targeted to non-attainment areas. Thus, Stage II
provides a limited, regional control program in areas where the
benefits of controlling gasoline vapors are high.
A Stage II system will achieve major VOC reductions much earlier
than on-board devices within two or three years. On the other hand,
less than 60 percent of the vehicle fleet will have on-board systems
in place by the year 2000.
Reduces toxic air-related cancer deaths in non-attainment areas by
the same degree and sooner than onboard option. VOCs are toxic
pollutants with direct local exposure to individuals. This option is
far more consistent with principle of early reduction under the
Administration's toxic air pollution legislative strategy than on-board
canisters.
An analysis for the Office of Technology Assessment concluded that
Stage II was substantially more cost-effective than on-board ($548 per
ton V. $2,425 per ton.)
No safety concerns are associated with Stage II devices. The safety
of an on-board control system has been questioned by critics. Last
October, the National Highway Traffic Safety Administration
(NHTSA) reported unresolved safety concerns.
Several major cities already have Stage II in place and more will
have them soon, thus reducing the benefits of on-board controls.
Advantages of "on-board" canisters in all automobiles:
Onboard canisters are more convenient than the Stage II devices and
would improve fuel economy, thereby offsetting vehicle hardware
costs.
Reduces benzene and other "air toxics" nationwide, thus providing
health benefits in these areas not provided by Stage II. Given the
significant toxic benefits to people refueling their cars, it makes no
sense not to protect motorists nationally.
Would relieve States from the responsibility of having to implement
a difficult to operate, controversial system (Stage II), that has been
the source of great consumer dissatisfaction.
Without onboard canisters, the major burden of national non-
attainment controls will have to be borne by the petroleum industry.
The auto industry should bear their fair share of the burden.
On-board will relieve State and local enforcement.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 22
Issue 6: Require states that will remain in nonattainment after
implementing Federal measures achieve 3 percent annual
progress towards meeting environmental goals.
Discussion: Even if all measures discussed on previous pages are
adopted, some areas will remain out of attainment of the ozone
standard. The question then becomes whether further progress should be
mandated without specifying specific actions and if so, what annual rate
of "progress" is appropriate. EPA would provide an exemption to the
3% requirement if an area can demonstrate attainment with lesser
reductions, show that a three percent reduction is infeasible, or show
that equivalent NOx control would be more cost-effective. If an annual
reduction option is rejected, the normal State implementation planning
program would remain in effect as the mechanism for ultimately
achieving compliance with the ozone standard.
Advantages
A requirement for steady further progress will make other less
stringent provisions (compared to Congressional bills) in the
Administration's bill more acceptable. In particular the ability to
obtain an extension of attainment deadlines will be politically tied to
a strategy for reductions beyond Federal measures.
Provides a escape valve for States if a reduction requirement turns
out to be unnecessary. Reductions attributable to measures such as
CTGS, hazardous waste rules and I/M would count toward 3% and
may be enough in many areas. Adds flexibility to include NOx
controls if these prove to be more cost-effective.
States have been unwilling to implement tough, politically
sensitive controls without a strong Federal mandate.
Disadvantages
Additional State controls could add $5 - 9 billion per year to cost of
the bill. The 3% per year approach is the more costly way to
achieve additional reductions because the approach is less flexible
and achieves reductions sooner.
Automatic 3% reduction would force the States to adopt draconian
measures based on inaccurate speculative models. NOx controls,
controls over smaller sources, transportation controls or other
contentious controls may be required before the effects of various
other Federal and State control actions are known.
The current SIP process will allow for long term more cost-effective
solutions rather than the constant search for the next 3% to get by
one more year.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 23
III. ALTERNATIVES FOR OZONE CONTROL
From the lengthy and vigorous debate within the DPC working group,
there emerged a consensus on several principles that have subsequently
framed the selection of control alternatives.
1. The goal is to make a major effort toward bringing non-attainment
areas into attainment with health standards. Federal leadership in the
form of some national measures will be needed to address and
resolve problems that transcend State boundaries or to achieve more
efficient or cost-effective solutions nationally.
2. Control measures to achieve progress toward attainment of the
standards should be selected on the basis of the extent to which they
achieve the greatest reductions at the least cost.
3. The Clean Air Act's principle of Federalism should be retained
where possible and economically appropriate. Cities and States should
have maximum flexibility to tailor and fashion individual control
strategies. States should have the option where possible of
substituting local measures not required in the Act for Feder-
ally-mandated local measures as long as commensurate reductions
can be achieved.
4. States should be given reasonable time to implement controls.
5. The selection of control measures should reflect consideration of
their ability to reduce emissions of toxic air pollutants.
Range of Alternatives
Four alternatives are presented on the following pages that include a
package of controls for addressing the ozone problems. Table 1
provides a summary of the controls included in each option. There are
four consensus control measures agreed to by all members of the
working group. These measures are:
Volatility Phase II (8.0% VOC Reduction; $390 per ton)
Vehicle Evaporative Controls (2.9% VOC Reduction; $140 per
ton)
0
Hazardous Waste Facility Controls (3.2% VOC Reduction; $900
per ton)
Commercial/Consumer Product Controls new authority (2.5%
VOC Reduction; $2,000 per ton)
Reductions and costs for these measures will be included in each
alternative but not mentioned further in the text. The cost of the
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 24
additional State controls cannot be estimated for most alternatives. The
cost of a 3% annual reduction after all identifiable controls are applied
(29% VOC reduction beyond current program) is $5 - 9 billion per year.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 25
Table 1: Summary Comparison of Alternatives
Consensus Controls
1
2
3
4
Volatility Phase II
X
X
X
X
Vehicle Evaporative
X
X
X
X
Hazardous Waste
Facilities
X
X
X
X
Commercial/Consumer
Products
X
X
X
X
Additional Measures
Neat Fuels
a. Buses
X
b. Fleets and Buses
X
C. 50% with opt-out
X
X
d. 50% with opt-out
and fuel pooling
X
Refueling Controls
a. Stage II
X
X
b. Onboard
X
Vehicle Emission
Trading
X
X
Light Duty Trucks
X
X
X
Extended Useful Life
X
X
X
Auto Tailpipe Stds
X
Enhanced I&M
X
X
CTGs
X
X
X
Results of Alt's:
1
2
3
4
% VOC Red. 2005
21
25
27
29
Ann. Cost ($ B)
2.4*
3.2-3.3*
3.0-3.1*
3.1-4.6*
Remaining Nonattain-
ment Areas in 2005
34
26
25
23
#
Cost estimates do not include the cost of the neat fuels program.
DECISION:
-
-
-
-
Additional State Controls
a. Current SIP Process. X
X
b. 3% Progress Mandate
X
X
C. Neat Fuels for
Other Areas
X
DECISION:
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 26
Alternative 1
Description
Neat Alternative Fuels program
-- Mandate alternative fuels for metropolitan buses.
-- Require the 25 most serious non-attainment areas with a total
population of 80 million to reduce emissions by an amount
equivalent to a 50% implementation of alternative fuel vehicles in
the year 2005. Areas would either be required to use such
vehicles or demonstrate that equivalent reductions could be
achieved through reductions of emissions from any other sources.
-- Set average standards for fuel cleanliness and allow refineries the
flexibility to "fuel pool" (i.e. meet the standards by selecting the
least cost mix of very clean alternative fuels and cleaner refined
oil products).
Mobile Source Controls - Allow complete vehicle emissions trading
for all new vehicles sold in the United States within one year after
enactment of the Act. Such trading would allow automobile
manufacturers flexibility to meet new emissions standards on
average), rather than for every vehicle or class of vehicle.
Additional State Controls - Require a neat fuels program for other
cities that require additional controls to come into attainment, even
after imposing the consensus controls.
Cost and Percent VOC Reduction for Identifiable Controls
VOC Reduction 1995: 12%; 2000: 17%; 2005: 21%
Annual
Cost:
$2.4
billion. Does not include cost of neat fuels.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 27
Advantages
Disadvantages
Fulfills the President's
Failure to include any control
commitment to neat fuels by
measures for gasoline vehicles
creating a broad market for
will be viewed as a serious
clean alternative fuels and
weakness by environmentalist
vehicles capable of using
and many members of
those fuels. Allows the
Congress.
marketplace to choose the
mix of clean fuels that best
The neat fuels program may
suits local circumstances.
not be workable as a sole
Federal vehicle control
The local opt-out allows
measure and EPA cannot
States to substitute cheaper
verify that fuel pooling is
ozone control measures if
feasible. A 50 percent share
they obtain greater VOC
will be difficult to guarantee
reductions, thereby targeting
and the issue of how to
neat fuels to the cities that
induce consumers to purchase
benefit most and allowing at
neat fueled vehicles remains
least partial local decision-
unresolved.
making.
Neat fuels are not
economically.competitive with
Represents the largest and
gasoline. Opponents claim
most dramatic reduction of
that neat fuels cost 30%
automobile VOC emissions,
more than regular gasoline at
obviating the need for other
current neat-fuels prices, and
more costly automobile
are not likely to be
controls.
economically competitive in
the next ten years. (The
Fuel pooling, California's
differential is less for
innovative measure to reduce
premium gasoline.)
aromatic levels of gasoline,
directly addresses the most
serious health risks (benzene
and other aromatic emissions)
while obtaining low-cost,
flexibly-achieved reductions in
ozone reactive hydrocarbon
emissions.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 28
Alternative 2
Description
Neat Alternative Fuels for Buses and Fleets - Beginning in 1992,
require the use of neat fuels in severe and serious non-attainment
areas for new buses and centrally fueled fleets of 10 cars or more.
Refueling Controls - require Stage II controls at service stations in
non-attainment areas only.
Mobile Source Controls - Require Light Duty Truck Standards to be
equivalent to current auto standards, Extend Useful Life of
automobile catalysts, and require Enhanced Inspection and Main-
tenance for non-attainment areas.
Stationary Sources Controls - Require EPA to publish a schedule
within 6 months promulgating Control Technology Guidelines, but do
not mandate a specific number.
Additional State Controls - Developed through existing SIP process.
States would be given 4 years to develop new SIPs including 2 years
to develop revised emissions inventories. EPA would retain the
current array of sanctions for failure to plan or implement a plan,
but all sanctions would be discretionary.
Other - The National Research Council would be required to
undertake a study of exposure rates to ozone and to quantify health
improvements for VOC reductions at levels near the standard.
Cost and Percent VOC Reduction for Identifiable Controls
VOC Reduction 1995: 19%; 2000: 23%; 2005: 25%
Annual Cost: $3.2 - 3.3B. Does not include the extra cost of neat
fuels.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 29
Advantages
Disadvantages
Fulfills the President's pledge
The current SIP process is
to encourage the use of neat
not sufficient to achieve
fuels, but proposes a limited
additional reductions. States
program designed to build
have already proven that they
public acceptance and
are not willing to implement
provide further information
tough, politically sensitive
on costs and benefits.
controls without a strong
Federal mandate.
Avoids major implementation
problems of the 50 percent
A failure to include vehicle
requirement which may not
tailpipe standards will be
work and may be extremely
viewed as a serious weakness
costly (OTA has estimated
by environmentalists and
$38,000/ton VOC removed)
many members of Congress.
depending on the price of
methanol.
Misses the opportunity to
take a bold stand to promote
Using the current SIP process
acceptance of alternative
will allow more cost-effective
fuels. A bus and fleet
solutions than the constant
program will not develop the
search for the next 3%
infrastructure needed for
reduction
general use of neat fuels.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 30
Alternative 3
Description
Neat Alternative Fuels with State "Opt-Out" - Beginning in 1995,
require 50 percent of all vehicles in non-attainment areas including
passenger cars, buses and commercial car and truck fleets use clean
fuels and require that service stations provide neat fuels in these
areas. States would have the ability to "opt out" of the requirement
if they can demonstrate commensurate reductions in the
non-attainment areas through other measures.
Refueling Controls - Require Stage II controls at service stations in
nonattainment areas only.
Mobile Source Controls - Require Light Duty Truck Standards to be
equivalent to current auto standards and Extend Useful Life of
automobile catalysts.
Stationary Source Controls - Issue additional Control Technology
Guidelines to use in controlling existing major emitters in non-
attainment areas.
Additional State Controls - Mandate 3 percent per year reduction in
all except marginal nonattainment areas. The percent requirement
will be averaged over a 5 year period. Serious and severe areas
would have to continue this reduction for a longer time but could
seek a waiver if additional reductions were unnecessary or infeasible.
Federal measures except for volatility and current vehicle emissions
standards could count against this target.
Cost and Percent VOC Reduction for Identifiable Controls
VOC Reduction 1995: 18%; 2000: 23% 2005: 27%
Annual Cost: $3.0 - 3.1B. Does not include the extra cost of neat
fuels.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 31
Advantages
Disadvantages
Provides almost the same
Neat fuels currently are not
level of control as Alternative
economically competitive with
4 except for the two controls
gasoline and a 50% share
(auto tailpipe standards and
will be difficult to guarantee.
enhanced I&M) that are the
Further, the program will
least cost-effective.
cause a substantial disruption
of the economy for only an
Fulfills the President's
additional 1.7% VOC
commitment to neat fuels by
reduction in 2005.
creating a broad market for
clean alternative fuels and
The 3 percent requirement
vehicles capable of using
provides less flexibility than
those fuels. Allows the
the SIP process to implement
marketplace to choose the
more cost-effective long term
mix of clean fuels that best
control options, which could
suits local circumstances.
unnecessarily drive up costs
due to the search for the
The local opt-out allows
next 3 percent.
States to substitute the
cheaper ozone control
Failure to include tailpipe
measures if they obtain
standards will be viewed as a
greater VOC reductions
serious weakness by
thereby targeting these fuels
environmentalists and many
to the cities that benefit and
members of Congress.
allows least partial local
decision-making.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 32
Alternative 4
Description
Neat Alternative Fuels Program - same as Alternative 3 (i.e. 50
percent of new vehicles purchased after 1995 in serious ozone
attainment areas required to use neat fuels) except the "opt out"
provision would be somewhat more restrictive.
Refueling Controls - require Onboard Canisters nationwide on every
vehicle to prevent refueling emissions.
Mobile Source Controls - Require all mobile source controls under
consideration including: 1) tighter Light Duty Truck Standards; 2)
Extended Useful Life of automobile catalysts; 3) tighter automobile
tailpipe standards; and 4) Enhanced Inspection and Maintenance in
non-attainment areas.
Stationary Source Controls - Issue additional Control Technology
Guidelines as in Alternative 3.
Additional State Controls - same as Alternative 3. Mandate 3
percent per year reduction in all except marginal nonattainment
areas. The percent requirement will be averaged over a 5 year
period. Serious and severe areas would have to continue this
reduction for a longer time but could seek a waiver if additional
reductions were unnecessary or infeasible. Federal measures except
for volatility and current vehicle emissions standards could count
against this target.
Cost and Percent VOC Reduction for Identifiable Controls
VOC Reduction
1995: 18%;
2000: 24%;
2005: 29%
Annual Cost: $3.1 - 4.6 B.
Does not include the extra cost of neat
fuels.
Clean Air Act Options Paper: Ozone Nonattainment
May 22, 1989
Page 33
Advantages
Disadvantages
Obtains the greatest
Neat fuels currently are not
degree of reductions and
economically competitive with
a better guarantee than
gasoline and a 50% share
the current SIP process
will be difficult to guarantee.
that all areas will achieve
Further, the program will
attainment by the revised
cause a substantial disruption
deadlines.
of the economy for only an
additional 1.7% VOC
Balances state and
reduction in 2005.
Federal roles. National
controls will address
Most costly option. Tailpipe
mobile sources, which
controls, in particular, are not
cannot be regulated on a
very cost-effective particularly
State by State basis.
since they would apply and
States would retain
impose costs in areas that
authority for designing
need no controls.
control plans and selecting
specific additional
Provides the least flexibility
controls.
to states and, therefore, is
the least consistent with the
Fulfills the President's
Federalism objective.
commitment to neat fuels
Further, the 3 percent
by creating a broad
requirement could
market for clean
unnecessarily drive up costs
alternative fuels and
due to the search for the
vehicles capable of using
next 3 percent.
those fuels. Allows the
marketplace to choose the
mix of clean fuels that
best suits local
circumstances.
Clean Air Act Options Paper: Ozone NonAttainment
May 22, 1989
Page 34
Appendix A
Ozone
Areas with 1985-87 scene expected exceedances greater then 1.0
1985-87
1987
Avg.
2nd
EPA
Besign
Est.
Daily
Est.
Region
Matropolitan Area (CHSA/MSA)
Value
Exe
Max
Exc
One-Mr
Explanation: This table
I
Beston, NA (CKSA)
0.14
2.2
0.14
6.3
I
Mass., CT-MA (Note (ii)
0.17
5.8
0.17
11.6
shows the average number
I
*Hanceck County, KZ
0.13
1.3
0.12
1.1
of days each area was out
I
*Kannebac County, KI
0.12
1.2
0.09
o
1
*Knex County, KE
0.15
4.4
0.13
6.5
of attainment in 1985-1987.
I
*LinceIn County, KE
0.13
2.4
...NO
DATA--
I
New Bedford, MA
0.14
2.4
0.12
_1.0
I
Pertland, ME
0.14
3.6
0.16
6.0
I
Portsmouth-Dever, WH-ME
0.13
3.2
0.13
3.2
I
Previdence, RI-MA (QISA)
0.16
6.5
0.16
7.8
I
Vercester, MA
0.13
2.1
0.11
0
I
*York County, KE
0.15
4.2
0.16
4.9
II
Atlantic City, IU
0.14
3.4
0.16
4.0
II
*Jefferson County, BY
0.13
4.7
0.13
4.7
II
Bev York, NY-MJ-CT (CHSA)
0.19
7.5
0.19
19.2
III
Allentwn-Bethlehem, PA-KJ
0.13
1.4
0.13
3.2
III
Baltimors, MD
0.17
7.9
0.17
11.1
III
Muntington, WV-KY-OH
0.14
3.8
0.14
5.2
III
*Kent County, DE
0.13
1.8
0.15
3.2
III
Morfelk, VA
0.13
2.0
0.13
2.0
III
Parkersburg, WV-OH
0.13
1.5
0.15
3.5
III
Philadelphia, PA-KJ-DE (CMSA)
0.16
13.6
0.18
23.2
III
Pittsburgh, PA (CMSA)
0.13
1.7
0.14
6.1
III
Richmond, VA
0.13
1.3
0.14
3.0
III
Washington, DC-MD-VA
0.15
6.2
0.16
10.5
IV
Atlanta. CA
0.17
13.5
0.17
15.0
IV
Birsingham, AL
0.25
3.2
0.16
3.1
IV
Charlotte, NC-SC
0.13
3.0
0.14
6.0
IV
Jacksonville. FL
0.16
2.1
0.12
1.1
IV
Laxington, KY
0.13
1.6
0.11
1.1
IV
Louisville, KY
0.16
4.0
0.13
2.0
IV
Memphis, TW-AR-MS
0.13
2.0
0.13
2.0
IV
Miami-Mialsah, FL (CHSA)
0.15
2.1
0.15
3.1
IV
Mentgomery, AL
0.14
2.2
0.14
6.3
IV
Nashville, TN
0.14
3.2
0.14
3.2
IV
Raleigh-Durham. NC
0.13
1.6
0.13
3.2
IV
Tempa, FL
0.13
2.1
0.16
4.2
V
Chicago. IL-IN-VI (CMSA)
0.17
7.4
0.18
12.8
V
Cincinnati, OH-KY-IN
0.14
1.6
0.15
2.1
V
Cleveland, OH
0.13
1.8
0.13
V
2.2
Detroit. MY (CMSA)
0.13
2.0
0.13
2.1
V
Grand Rapids. NI
0.13
1.3
0.14
3.0
V
Indianapelis, IN
0.13
1.3
0.12
1.1
V
*Revaunee County, WI
0.13
1.9
0.14
5.8
V
Milwaukee, VI (6 Shebeygan, 0.17
3.7
0.20
12.9
v
Muskagon, MI
0.17
6.0
0.18
11.0
VI
Beten Rouge, LA
0.14
3.0
0.16
5.1
VI
Beaument-Pert Arthur, TX
0.13
2.1
0.13
3.2
I
Dallas-Fert Worth, TX (CMSA)
0.16
6.1
0.14
5.2
VI
E1 Pase, TX
0.16
9.0
0.17
11.1
VI
Mouston, TX (CMSA)
0.20
19.1
0.18
20.8
VI
*Iberville Parish, LA
0.13
2.4
0.13
2.1
VI
Tulss, OK
0.12
1.1
0.12
1
Note: In 1988 more areas
VII
St. Leuis, NO-IL
0.16
5.4
0.17
8.0
VIII
-Salt Lake City. UT
were out of attainment
0.15
3.8
0.11
1.0
IX
Bakersfield, CA (Note @5)
0.16
35.1
0.16
47.6
and other areas had
IX
Fresno, CA
0.17
30.5
0.17
42.6
IX
*Kings County, CA
0.13
5.6
0.13
greater exceedances.
5.6
IX
Les Angeles, CA (CMSA)
0.35
143.5
0.32
141.2
IX
Medesto, CA
0.15
16.2
0.15
20.8
IX
Phoenix, AZ (Note @5)
0.14
2.4
0.11
0
IX
Secramento, CA (Note #5)
0.17
9.7
0.17
IX
14.6
San Diego, CA
0.18
12.5
0.18
II
26.8
Ban Francisco, CA (CMSA)
0.14
3.6
0.15
LX
4.1
Santa Barbara, CA
0.14
1.7
0.13
IX
3.4
Stockton, CA (Note #5)
0.14
8.1
0.12
IX
(inc.)
Visalia. CA (Note #5)
0.15
11.9
0.15
X
21.6
Pertland, CR-MA (CHSA)
0.15
1.8
0.11
1.2
*Not a metropelitan statistical area.
SOURCE:
U.S.
EPA,
"Inviremental
News."
ureas
Hav
,
1888
CLEAN AIR ACT OPTIONS PAPER:
CARBON MONOXIDE NONATTAINMENT
CARBON MONOXIDE
I. BACKGROUND
The second major air quality "non-attainment" issue is carbon monoxide
(CO).
There are currently 52 areas out of attainment with the EPA's carbon
monoxide standard. The CO non-attainment situation, however, is much
less intractable than the ozone non-attainment situation since ongoing
EPA programs under the Clean Air Act will help reduce CO emissions
over the next decade.
Carbon monoxide is a colorless, odorless gas that tends to reduce the
oxygen carrying capacity of the blood. It is a particularly serious health
threat to individuals who suffer from cardiovascular disease, especially
those with angina or heart disease. There is limited information,
derived from animal studies, suggesting that CO may adversely affect
development of the fetus.
Unlike VOC emissions which come from a wide range of sources,
two-thirds of CO emissions come from mobile sources. Other major
sources of CO are industrial processes and wood stoves.
The carbon monoxide standard is nine ppm measured over an eight-hour
period, based on the second maximum eight-hour period in one year. If
an area exceeds the standard for two or more eight-hour periods, it is
classified non-attainment. Fifteen of the 50 carbon monoxide
non-attainment areas are moderately out of attainment. An additional
six are seriously out of attainment.
Carbon monoxide ambient levels decreased 32 percent from 1978 to
1987 and the number of eight-hour exceedances decreased by 91 percent
during that same period.
Emissions of carbon monoxide decreased 25 percent from 1978 to 1987
largely due to reductions in mobile sources emissions, despite a
24 percent increase in vehicle miles traveled in the last 10 years. Some
improvement from controls on automobiles will continue, due to fleet
turn-over. For example, cars purchased before 1981 amount to only 38
percent of the vehicles miles traveled (VMT), but they account for over
86 percent of CO emissions.
Clean Air Act Options Paper: CO Nonattainment
May 22, 1989
Page 2
This improvement is expected to level off in the 1990s, however,
because EPA projects continuing sharp increases in VMT. EPA
estimates that VMT nationwide will grow 5.1 percent by the year 2000.
Initial EPA estimates project an additional 24 percent reduction in total
CO emissions by the year 2005 due to fleet turnover under the current
program after taking increased VMT into account. EPA estimates that
this will bring 24 of the 51 non-attainment areas into attainment with
the CO standard.
In addition, several of the provisions being contemplated in the ozone
non-attainment section of the bill will also help reduce CO. A
description of these, plus other envisioned controls on mobile sources,
follows:
Light duty truck CO standards
Within 12 months, EPA will issue regulations under existing law
requiring lower-weight light trucks to meet a 3.4 grams per mile
standard in the 1992 model year. This will reduce CO emissions
by about two percent.
Auto cold temperature CO standards
Within 12 months, EPA will issue regulations under existing law
for a cold temperature standard and test procedures. This will
reduce CO emissions by 7 to 12 percent.
Extended definition of "useful life"
Auto manufacturers currently must certify that emissions control
devices for passenger cars will meet the CO standard at 5 years
or 50,000 miles. EPA would amend the Clean Air Act to change
this to ten years/100,000 miles for certification at time of
production. However, EPA would not require a change in vehicle
warranties and would limit recall testing to 75,000 miles. This
will reduce CO by up to 10 percent.
Enhanced inspection and maintenance
An enhanced inspection and maintenance (I&M) program would
allow some State flexibility in design, but generally would include:
(1) tightening of definitions for vehicles exempt from current I&M
programs; (2) tightening pass/fail limitations; and (3) increased
sophistication of the emissions test. Programs would be required
for CO non-attainment areas with population over 200,000 and
Clean Air Act Options Paper: CO Nonattainment
May 22, 1989
Page 3
CO design values of 17 ppm or higher. This would reduce CO
emissions by four to five percent.
In total, according to EPA, the current program plus these measures will
reduce CO emissions by 45.6 percent by the year 2005. This will still
leave six cities out of attainment without additional measures.
Moreover, because some national measures targeted at automobiles will
take some years to implement fully, EPA estimates that as many as 10
cities could remain out of attainment in the year 1995.
In order to bring these areas into attainment, EPA is proposing a major
new initiative in oxygenated fuels.
Clean Air Act Options Paper: CO Nonattainment
May 22, 1989
Page 4
II. ALTERNATIVES FOR CONTROLLING CARBON
MONOXIDE
Issue: Should an oxygenated fuels program be mandated to control
carbon monoxide.
Option 1: No Federally mandated oxygenated fuels program.
Option
2:
Require serious CO nonattainment areas to use oxygenated
fuels of their choice (with no specific oxygen requirement)
on a seasonal basis as needed, but allow areas to "opt out"
if they can demonstrate that other control measures are
sufficient to achieve attainment.
Option 3:
Require at least 2.7 percent oxygenation of fuels in
moderate and serious CO nonattainment areas, but allow
areas to "opt out" if they can demonstrate that other
control measures are sufficient to achieve attainment.
Option 4:
Require at least 2.7 percent oxygenation of fuels in
moderate and serious CO nonattainment areas, as well as
in other CO nonattainment areas with serious and severe
ozone problems. Allow no "opt out".
Discussion: Oxygenated fuels are blends of gasoline and ethanol,
methanol, MTBE, or ETBE. Current technology vehicles can use
oxygenated fuels of up to about 3 % oxygen content without engine
modifications. Oxygenated fuels accounted for about 30 percent of total
U.S. gasoline sales in 1988.
According to EPA estimates, a broad oxygenated fuels program (Options
3 and 4) would reduce CO emissions by 18% in 2005. Oxygenated fuels
can also help reduce emissions of benezene, a proven carcinogen. On
the other hand, they can produce higher NOx emissions that contribute
to ozone formation.
The cost of a broad oxygenated fuels program depends on assumptions
as to Federal ethanol subsidies. If the current 60 cents per gallon
subsidy were repealed, it is probable that MTBE (a blend of gasoline,
methanol and ether) would be used exclusively to meet a Federal
mandate for oxygenated fuels. This would result in a cost-effectiveness
figure of $235 per ton in 1992.
It is not likely, however, that the Federal ethanol subsidy will be
repealed. Under this assumption, ethanol would probably be cost-
competitive with MTBE and could account for about 50 percent or
more of the blends used to meet a Federal oxygenated fuel mandate.
Clean Air Act Options Paper: CO Nonattainment
May 22, 1989
Page 5
This would result in a cost-effectiveness figure of $390 per ton in 1992
and $800 per ton in 2005.
Cost Estimates: $235/ton in 1992 (no gasohol tax exemption);
$390/ton in 1992 and $800/ton by 2005 (with
continued gasohol tax exemption).
Option 1:No Federally mandated oxygenated fuels program.
Advantages of Option 1
Allows nonattainment areas maximum flexibility in selecting
control measures for achieving attainment with the CO standard.
The Federal government would not be picking "winners and
losers" among fuels. Commercial development of ETBE and
other new oxygenated fuels would not be hindered.
Recognizes that if enhanced I&M, extended useful life, and light
duty truck control measures are selected, there will be less need
for a mandatory oxygenated fuels program.
Disadvantages of Option 1:
Would not provide as much assurance relative to other options
that attainment would be achieved.
Does not support the President's commitment to alternative fuels.
May forego possible gains in air toxics risk reductions from
alternative fuels.
Clean Air Act Options Paper: CO Nonattainment
May 22, 1989
Page 6
Option 2:
Require serious CO nonattainment areas to use oxygenated
fuels of their choice (with no specific oxygen requirement)
on a seasonal basis as needed, but allow areas to "opt out"
if they can demonstrate that other control measures are
sufficient to achieve attainment.
Advantages of Option 2:
Compared to Option 1, this Option allows nonattainment areas
almost as much flexibility in selecting control measures for
achieving attainment with the CO standard.
Allowing oxygen percentages less than 2.7 would expand consumer
fuel choice. A 2.7 percent requirment would preclude the use of
ETBE and would severely curtail the use of MTBE without
further EPA waivers. Allowing a seasonal strategy (such as
Denver's) would reduce costs and lower the risk of exacerbating
the ozone problem.
Provides some support for the President's commitment to alterna-
tive fuels.
Disadvantages of Option 2:
Would not provide as much assurance relative to Options 3 and 4
that attainment would be achieved.
May not be sufficient to make good on the President's commit-
ment to the farm (ethanol) constituency.
May forego possible gains in air toxics risk reductions from
alternative fuels.
Option 3:
Require at least 2.7 percent oxygenation of fuels in
moderate and serious CO nonattainment areas, but allow
areas to "opt out" if they can demonstrate that other
control measures are sufficient to achieve attainment.
Advantages of Option 3:
Provides more assurance, relative to Options 1 and 2, that CO
attainment will be achieved.
Consistent with the President's campaign promise to establish a 3
percent oxygen standard for CO nonattainment areas.
Promises more air toxics risk reductions than Options 1 or 2.
Clean Air Act Options Paper: CO Nonattainment
May 22, 1989
Page 7
Disadvantages of Option 3:
Would limit fuel choice, especially if an "opt out" is made difficult
to obtain.
To the extent that ethanol and ETBE are subsidized, the cost to
the Treasury (Highway Trust Fund) will increase -- potentially
$1.7 billion per year.
Option 4:
Require at least 2.7 percent oxygenation of fuels in
moderate and serious CO nonattainment areas, as well as
in other CO nonattainment areas with serious and severe
ozone problems. Allow no "opt out".
Advantages of Option 4;
Provides the greatest CO, air toxic, and VOC reductions of any
option.
Consistent with the President's campaign pledge to establish a 3
percent oxygen standard in CO nonattainment areas.
May be an ineffective environmental strategy in the later years as
newer vehicle controls reduce the effectiveness of an oxygenated
fuels program.
Disadvantages of Option 4:
Provides the least flexibility for nonattainment areas of any
Option which will result in unnecessary costs for some areas.
Will result in increased NOx emissions and may be an ineffective
environmental strategy in the later years as newer vehichle
controls reduce the effectiveness of an oxygenated fuels program.
Most expensive Option in terms of Federal subsidies.
Clean Air Act Options Paper: CO Nonattainment
May 22, 1989
Page 8
Oxygenated Fuels Decision:
/ / Option 1:
No Federally mandated oxygenated fuels program.
/ / Option 2:
Require serious CO nonattainment areas to use
oxygenated fuels of their choice (with no specific
oxygen requirement) on a seasonal basis as needed,
but allow areas to "opt out" if they can demonstrate
that other control measures are sufficient to achieve
attainment.
/ / Option 3:
Require at least 2.7 percent oxygenation of fuels in
moderate and serious CO nonattainment areas, but
allow areas to "opt out" if they can demonstrate that
other control measures are sufficient to achieve
attainment.
/ / Option 4:
Require at least 2.7 percent oxygenation of fuels in
moderate and serious CO nonattainment areas, as
well as in other CO nonattainment areas with
serious and severe ozone problems. Allow no "opt
out".
MAY 31 '89 10:27 EPA
P.1
US ENVIRONMENTAL PROTECTION AGENCY
TELECOMMUNICATIONS CENTER
WASHINGTON, DC 20480
&EPA
FACSIMILE REQUEST AND COVER SHEET
PLEASE PRINT IN BLACK INK ONLY
O
OFFICE/PHONE Mark Lange
WHite HOUSE
REGION/LAB Fax # 456 - 6218
FROM PHONE SEft Clark
MAIL CODE
475-7360
OAR- 443
OFFICE
Opar
DATE
NUMBER OF PAGE3 TO INCLUDE THIS COVER SHEET
5/31/89
4
Please number all pages
INFORMATION FOR SENDING FACSIMILE
MESSAGES TO EPA HEADQUARTERS
FACSIMILE NUMBER
VERIFICATION
EQUIPMENT
NUMBER
NUMBER
RAPICOM
(202) 382-7883 (auto)
(202) 382-2078
PANAFAX
(202)382-7884 (auto)
(202) 382-2078
PANAFAX
(202) 382-7886 (auto)
(202) 382-2078
MANUAL
(202) 382-2078
The EPA Communications Center has the capability for sending and receiving facsimile messages to
CCITT Group 1. II, and III Equipment
EPA Form 5040-5 (Rev. 12.83) Replaces EPA Form 5040-5A and the previous edition of EPA Form 6040-5. which are obsolete.
To MARK LANGE - Growth in Vehicle Miles Travelled
us. Passenger Cars IN Operation
Extended Page 1.1
year
Cars
(Millions)
VMT by CARS
CBILLIONS
1970
80
797
1989
124
1,203
2005
161
1,558
2010
173
1,670
Jeft clarke
APR 5 '89 9:01 FROM OAQPS, DURHAM, NC
TO OAR
PAGE. 002
3 copies Bealt please
WHY CONTROL ACID RAIN?
kete
Brenner
Introduction
The acid rain problem is frequently mischaracterized as
pitting the interests of Northeast US and Canadian "receptor"
regions, who are suffering all of the environmental damages,
against midwestern "source" regions, who would gain nothing from
acid rain controls. This misperception comes from
"compartmentalizing" the environmental damages from regional
sulfur and nitrogen oxide emissions and focusing only on those
related to what is deposited in rainfall. The total
environmental effects of concern include the traditional acid
rain effects - - destruction or alterations of sensitive aquatic
ecosystems, effects on certain terrestrial ecosystems such as
high elevation forests, and regional deterioration of stone,
metal, paint, and other outdoor structural components - - but
also encompase air quality related effects, including destruction
of visibility throughout the eastern U.S., increased respiratory
illness in children and in respiratory disease related hospital
admissions, a significant increase in total mortality, as well as
effects on crops, forests, and human health related to elevated
Extended Page
1.2
Sources and Transformations: Acid rain and related regional air
pollution is derived from emissions of sulfur and nitrogen
oxides, largely from coal fired utilities, industrial boilers,
and smelters. Photochemical reactions involving nitrogen oxides
and volatile organic chemicals play a role in transforming these
emissions into acid sulfate particles, which affect health and
visibility, as well as nitric acid. The chemical reactions also
reduction in SOX emissions will probably produce a less than 50%
limit the effectiveness of emission reductions such that a 50%
reduction in deposition.
Benefits of a Major Reduction: The benefits of a major (8, 10,
or 12 million ton reduction in sulfur oxides) would increase in a
manner roughly proportional to the emissions increase. The
benefits include:
- Aquatic systems: recovery of hundreds of lakes and
thousands of kilometers of streams in the Northeast and
mideast US and recovery of thousands of lakes and streams in
eastern Canada. A number of lakes and streams in the
southeast will be prevented from becoming acidic. Acidic
substantially reduced by SOX reductions, but more so if
"episodes" that produce short term damages will be
accompanied by a reduction in NOX deposition.
- Terrestrial systems: ecological scientists are concerned
about long term (25-50 year) changes in many soils in the
east. Reductions would reduce markedly reduce the chance of
complex ecosystem changes related to such changes. The
major damage of present concern is the observed forest
declines and death mountainous areas. Major reductions
would reduce the acidity of mountain clouds that are
suspected of damaging the trees and scils in these areas.
NOX reductions could reduce the elevated ozone levels
observed in such regions.
- Materials Damage: Major reductions would proportionally
reduce the component of materials damages due to regional
SOx loadings. Damages include corrosion and tarnishing of
metals, erosion of building stone, and erosion, soiling, and
cracking of paints. Benefits would accrue throughout the
eastern U.S., but be greatest nearer the source regions.
- Health Effects: Controls would reduce the substantial
health risks associated with the presence of acid sulfate
particles. Based the available data, our science advisors
have recommended preparing the documentation and
Don't
instrumentation needed to decide upon a national ambient air
quality standard for acid particles. The Harvard 6 City
use
study has shown as strong relationship between acid sulfates
this
and the presence of bronchitis in school children. A
Canadian study found significant associations between
temin.
respiratory hospital admissions and sulfates, even taking
loesnot
ozone effects into account. Other researchers at Harvard,
Brookhaven, Carnegie Mellon, and elsewhere have found a
gree (yet) EPA
persistent relationship between sulfates and excess
mortality, with the suggestion that on the order of 2 to 5%
of mortality in areas with high sulfates may be caused by
these pollutants. A 50% reduction might cut these risks in
half, preventing on the order of 20,000 to 40,000 early
deaths each year. Even if the effects are only a fraction
of the above (e.g. 0.1 s of mortality), the health benefits
- - for those who place dollar value on morbidity and
mortality - - are well in excess of the costs of the control
program.
- Visibility: Summertime skies in the eastern US are
noticeably hazy much of the time. This haze is not, as
commonly thought, a natural phenomenon, but is caused
Extended Page
1.3
eastern visibility would be in the range OI 4U to DU
rather than the 10 miles commonly seen today. A major
reduction in SOx emissions would increase visibility by up
to 30 to 40%, with the larger increases more likely as the
emissions reduction increase. Preliminary benefits
estimates suggests that the societal value of such
improvements would account for a significant fraction of the
costs of the control program.
** TOTAL PAGE. 003 **
MAY 26 '89 15:29 EPA
P.1
To : Mark Lange
From : Jeff Clark, EPA
3 pgs. to follow
WHY CONTROL ACID RAIN
(10 MM TONS)
Extended Page 1.1
tons of SO2 and NOx Into the atmosphere. JEFF CLARK
@ EPA:
The U.S. now spends $160 billion per year on
electricity. An acid rain control program would add 382- 5580
$1-2 billion In the 90's and $3-4 billion after the
year 2000. on the dollar
2 bilian
= just our apeny
100 (1.25) on he dolor
a 90s;
The longer we walt to reduce those emissions the and 2/2 cer
more costs we Incur in terms of:
after 2000
-
materials damage
-
visibility impairment
-
continued acidification of lakes and streams
Don't use
Information from several public health school
studies indicates that these emissions are
the
responsible for significant morbidity (emphysema,
bronchitis, asthma, etc.) and up to 40,00-80,000
premature deaths per year (i.e., 3 percent "excess
mortallty")
Even If the actual number Is only 5,000 premature
deaths (three-tenths of one percent excess
mortality) that would be more than enough reason
to Justify our proposal (for those who think you can
value lives: the program would reduce those
fatalities by half and at any plausible value per life
the benefits--v
materials, lakes
ML -
according to fiff
Clark, you #'s are fine.
exceed the costs
Every year that we wait, those costs continue to be
Incurred.
The researchers from Harvard who are conducting
on of the public health studies presented their
prellminary results to the Congress last year.
They will give similar testimony this summer. Given
these health concerns, It will be very difficult for the
Administration to argue for delaying implementation
of controls or for achieving less than a 10 million
ton reduction.
Extended Page
1.2
WHY CONTROL AIR TOXICS?
Toxic air emissions are responsible for about 2000
fatal cancers per year plus numerous other adverse
health effects including neuro-toxicity, fetal damage,
and liver disease.
About half of these fatal cancers come from motor
vehicles and will be reduced as a result of measures
aimed at reducing hydrocarbon, NOx and diesel
particulate emissions.
The remainder of these fatal cancers are produced
by stationary source emissions. H.R. 4 would
address the problem in two stages. In stage one
most sources would be required to Install available
control technology (considering costs). In stage
two the remaining risks would be evaluated and, If
deemed unacceptable, additional controls would be
required. This program would be phased in over a
25 year period.
Extended Page
1.3
o
It is not possible to "do nothing" on air toxics.
-
Recent court decisions require the Agency to
either place very stringent controls on sources
of toxic air emissions (so stringent that many
will be forced to shut down within 2 years) or
declare them to be "safe" (i.e., determine that
annual cancer risks of about one In one-
thousand are acceptable). The first of these
decisions under the new court requirements will
be made this summer.
T0# 2304460
25:20 80/90
ENVIROMENTAL PROTECTION AGENCY
REGION I
JFK FEDERAL BUILDING
BOSTON, MA 02203
TELECOPIER REQUEST
To
Office
White Hanse
mark Lang
Phone
Telecopier # 202-456-6218
Confirming 202-456-2930
From
Cannie Denne
Office mike Deland
Phone# 565-3400
Number of Pages to Follow
/
Date Sent
PANAFAX MV 3000
FTS: 835-3468
(automatic)
Time
Comm: (617) 565-3468
By
VERIFICATION:
Confirmed
Yes
No
FTS: 835-3420
Comm; (617)565-3420
When sent and verified please return to
MIKE DEALAND
secog as
EPA
Region I. administrator
moved shaker in
CEQ
Council ON Enviratil
environment
Quality.
wheelefair
in adenowledgement
Ben announced as chair
of
20 30 20# 2304460
25:52 80/90
MICHAEL R. DELAND
REGIONAL ADMINISTRATOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
BOSTON, MASSACHUSETTS
Michael R. Deland is the New England Regional Administrator of the
U.S. Environmental Protection Agency. In this capacity, he
oversees and administers the federal government's programs dealing
with air and water pollution control, hazardous waste management,
drinking water, toxic substances, radiation, and pesticides.
Prior to Mr. Deland's appointment as Regional Administrator in June
1983, he was Counsel at Environmental Research and Technology,
Inc., a national firm headquartered in Concord, Massachusetts.
From 1973-76, he was the Chief of the EPA Region I's Enforcement
Branch in charge of preparing all enforcement actions brought by
EPA in New England. From 1972-73, he was the Chief of the Agency's
Legal Review Section. Between 1971 and 1972, Mr. Deland worked as
one of EPA's first enforcement attorneys in New England.
Mr. Deland received his Bachelor of Arts degree from Harvard
College in 1963 and served as an officer in the U.S. Navy before
obtaining his law degree from Boston College in 1969. He is a
member of the Massachusetts Bar and the American Bar Association
and its Natural Resources Committee. Mr. Deland was President of
the Business Associates Club (Boston) from 1981-82 and is a former
Director of the Environmental Lobby of Massachusetts and the Center
for Environmental Intern Programs, a national non-profit
organization headquartered in Boston.
Mr. Deland is former Chairman of the Boston Federal Executive
Board, a "coordinating group" composed of the heads of all Federal
agencies in the Boston area representing 40 departments and
independent agencies with a total work force of approximately
34,000 employees.
Mr. Deland has received numerous awards and citations, including
the Massachusetts Audubon Society Award for his leadership in
cleaning up Boston Harbor and the New England Environment
Leadership Award from the New England Environmental Network. In
1987, he was honored as "Environmentalist of the Year" by the
Massachusetts Association of Conservation Commissions. In March
of 1989 he was awarded the National Wildlife Federation's Special
Achievement Award for his role in prompting the clean up of Boston
Harbor, for his efforts at protecting valuable fishing areas from
off-shore oil drilling, and for his early endorsement of
environmentally-based growth controls on Cape Cod. Mr. Deland is
also the recipient of "Save the Bay Award" He resides in
Wellesley, Massachusetts, with his wife and three children.
06/06/89
15:24
U.S.F.W.S. HQ
NO. 900
P001
THE
TMENT of the
nows release
OFFICE OF THE SECRETARY
For Release June 1, 1989
Steve Goldstein
(0)
202-343-6416
(H) 202-887-5248
INTERIOR SECRETARY LUJAN ANNOUNCES THAT THE UNIFED WARS
IS CO of RING NEW MEASURES TO END ILLEGAL DE IN
AFRICAN ELEPHANT IVORY
Secretary of the Interior Manuel Lujan, Jr., today announced
that the United States is seriously considering additional trade
restrictions to halt the importation of African elephant ivory.
"We have already banned ivory imports from more than 70
countries, including Somalia, and are on the verge of extending
the import ban pursuant to the Elephant Protection Act," Lujan
said. "I am outraged over the illegal poaching of African
elephants and the level of ivory imports into certain countries.
I urge others to do as the United States is doing in banning
importation of ivory from countries that do not have elephant
populations. We have reason to believe that some of this ivory
is from illegal trading and that the commercial trading is out
of control."
Lujan said the Department of the Interior is extending the
import ban on specific countries and working with the Departments
of Commerce and State to seek international cooperation in an
effort to protect the species.
(over)
on
Achplant
T
06/06/89
15:24
U.S.F.W.S. HQ
NO. 900
P002
-2-
On May 9, Lujan announced that the United States will
support the international ban on commercial trade in African
elephant ivory at the October meeting of the 101-member-nation
Convention on International Trade in Endangered Species (CITES).
"We are considering all the options for halting illegal
ivory trade," Lujan said. "our concern is that no solution to
the elephant problem can be effective without the full
participation of the African nations that have elephants.
We
must also work with other countries interested in bringing to a
halt the massive illegal destruction of the African elephant
populations. We are reviewing this issue carefully and meeting
with representatives of African countries to be sure that any
actions taken by the United States are in fact helpful and
constructive."
In that regard, Lujan said the Department is providing
$15,000 to send African representatives to a July meeting of the
CITES Elephant Working Group to assist them in developing
elephant conservation plans.
According to current available information, African elephant
numbers have declined drastically in the last decade, from an
estimated 1.5 million in 1978 to perhaps 700,000 currently.
Poaching for the illegal ivory trade is the major cause of the
decline.
"If, prior to the Ocotber 10 meeting, the Department
receives new information to indicate an emergency ban of all
commercial imports is appropriate and necessary for the
conservation of the African elephant, we will move expeditiously
to review that information and determine whether current
regulations need to be amended," Lujan said.
This announcement comes on the heels of a May 9, 1989,
announcement by Lujan on a finding to accept a petition to
reclassify the African elephant as endangered. The Interior's
Fish and Wildlife Service is proceeding with a full status review
of the species, including an opportunity for public comment.
-DOI-
THE UTILL
INT REG 1912-89