Wednesday, May 31, 2017

What does Non-attainment actually mean?

If you hadn't heard, the Salt Lake and Provo area failed the last round of EPA air quality tests. It's not a big surprise--we've been just skating by for years. But what does that mean? Well, I asked my good friend Google, who directed me to the EPA website.

  • All requirements above, with
    • Major source threshold 50 tpy
    • NSR offset ratio 1.2:1
  • 18% RFP over 6 years
  • Enhanced monitoring plan
  • Modeled demo of attainment
  • Milestone contingency measures for RFP
  • Enhanced I/M
  • Clean fuels program (if applicable)
  • NSR requirements for existing source MODS
  • Vehicle miles traveled (VMT) demonstration, and transportation control measures if needed
Which is a pile of acronyms, and not very helpful. Decoded, it reads:

  • All requirements above, with
    • Major source threshold 50 tons per year
    • New Source Review offset ratio 1.2:1
  • 18% reasonable further progress over 6 years
  • Enhanced monitoring plan
  • Modeled demo of attainment
  • Milestone contingency measures for Reasonable Further Progress
  • Enhanced Inspection and Maintenance
  • Clean fuels program (if applicable)
  • New Source Review requirements for existing source MODS
  • Vehicle miles traveled demonstration, and transportation control measures if needed
'Major Source' I presume to mean any single polluter emitting more than 50 tons a year of anything gets hassled; hence, any major single company is going to have a hard time (which may make them reluctant to come to Utah, or stay here).

'New Source Review' covers new polluters; they can pollute, if they can obtain 'offsets' by reducing pollutants from other sources. We're now at a 1.2:1 ratio, so for every 5 tons of new pollutant a New Source would emit, they have to find a way to reduce 6 tons of pollutant someplace else.

'18% Reasonable Further Progress' seems to indicate that while we don't have to fix the air quality immediately, we will need to demonstrate serious effort to do so; that serious effort being an amount of reduction in the next 6 years; ie, 18% of the total necessary reduction. 'Milestone Contingency' measures is related to this--things that we agree to do if we fail the 18% reasonable Further Progress. 

VMT & 'Transportation Control Measure' is the scary one: It's a mandatory 'hard cap' on the amount of driving people are allowed to do. (57% of emissions in Salt Lake come from vehicles, I seem to recall). Crazy things like 'alternate day driving'.

All this makes me wonder how other places are doing: Current Non-Attainment Counties

In 'Serious' Non-attainment.
AZ: Maricopa, Pinal
CA: Fresno, Imperial, Inyo, Kern, King, Los Angeles, Madera, Merced, Orange, San Bernardino, Riverside, San Joaquin, Stanislaus, Tulare, Ventura..

In 'Severe' Non-attainment:
CA: El Dorado, Los Angeles, Placer, Riverside, Sacramento, San Bernardino, Solano, Sutter, Yolo.

In 'Severe' Non-attainment:
CA: Fresno, Kern, King, Los Angeles, Madera, Merced, Orange, Riverside, San Bernadino, San Joaquin, Stanislaus, Tulare.

I don't think any of these are part of a club that Utah wants to be part of. Barring two counties in AZ, these are all in California. The California Air Resources Board (CARB) can do some pretty draconian things. 

Oh, and if Utah (for mad reason) elects not to comply with air quality standards, we don't get our share of the Federal Gas Tax funds. Which pays for 50-80% of all roadway and transit projects. (80% for freeways). So, without that money, the amount Utah taxpayers would have to pay our per freeway QUINTUPLES.


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