Saturday, January 14, 2012

Attainment Plan Focused on Causes

The Chamber, as you may recall, was very active during the formation of the (Tacoma-Pierce County metro) nonattainment area designation for PM2.5, a regulatory requirement of the federal Clean Air Act, under the jurisdiction of the U.S. Environmental Protection Agency (EPA).

We opposed the broad boundaries suggested by Puget Sound Clean Air Agency (PSCAA) then, as the exceedance was based on a single monitor at So. L Street and was clearly caused by residential wood smoke from fireplaces and wood stoves.  The tideflats monitor had not and has not yet (unless during the recent burn bans) exceeded the tolerances.  While the area boundaries set are larger than we desired, we were successful in getting Northeast Tacoma and Joint Base Lewis-McChord excluded. 

The new attainment plan focuses the effort where it must be – on residential wood stoves.  The EPA allows only 6% of achievable improvements to come from "education."  State legislation exempts fireplaces from any regulatory efforts. Provisions in the plan call for assistance to those with low-income.  And, the plan recognizes the tremendous earlier contributions and continuing standards and improvements applied to industry and cars.  

If you shut down the port, you could not achieve attainment.

The Chamber, represented by Tom Pierson, Pres./CEO and Anthony L-T Chen, MD, MPH, Director, Tacoma-Pierce County Health Department recently wrote, and was published in The News Tribune, a guest editorial explaining  the necessity of local initiative to solve our air quality challenges ourselves.

From the perspective of business and the economy, we know that a non-attainment designation under the Clean Air Act carries serious repercussions including the loss of federal highway funding and the loss of economic development opportunities.

Nonattainment can hinder economic development and tourism in the region. In the nonattainment area, there are stricter requirements on large industries seeking to expand and on new large businesses interested in moving to the area compared to the requirements in an attainment area. New or expanded large industries would be required to better control fine particle pollution than in an attainment area and any increase in emissions would need to be offset by a reduction within the nonattainment area. These factors can prompt businesses to locate their operations elsewhere. Tourism also can be affected by the perception that the area has “dirty” air.

Nonattainment can also have an effect on our transportation system.  Federal transportation funds can be at risk if we don't comply with the air quality requirements.  The region also has to show the pollution from transportation cannot exceed the amount allotted to it in the attainment plan.

Loss of Federal Highway and Transit Funding (Transportation Conformity)*
One year from the date of a non-attainment designation, federally funded highway and transit projects will not be allowed to proceed unless the state demonstrates there will be no increase in emissions associated with the projects.

Boutique Fuels 
Non-attainment areas are subjected to the federal Clean Air Act's reformulated gasoline program, which significantly raises the price of motor vehicle fuels for consumers.

Enhanced Regulatory Oversight 
Once an area is designated as being in nonattainment, EPA has the authority to intervene and revise permitting decisions throughout the state.

Restrictive Permitting Requirements 
New and upgraded facilities in, or near, non-attainment areas are required to install the most effective emissions reduction controls without consideration of cost. Operators of existing facilities may also be required to install more restrictive control technologies than are otherwise required for similar units in areas that are in attainment.

Mandatory Emissions Offsetting 
Prior to permitting the construction of new facilities, a state must offset any emissions increases by achieving reductions at existing facilities.

Loss of Economic Development Opportunities 
The added regulatory and paperwork burdens, as well as expenses associated with constructing new facilities, or expanding existing ones, limit the amount of economic investment in non-attainment communities. 

*Cost of ‘Transportation Conformity' – Nonattainment communities are required to conduct extensive analysis and coordinate transportation and air quality issues. Computer modeling is used to ensure transportation projects do not affect the area’s ability to regain and/or maintain attainment. Transportation conformity requirements are time consuming, costly and include using a mobile emissions ‘budget’ from which to determine the impact transportation projects, once implemented, would have on regional air quality. In nonattainment areas, transportation projects can proceed only if it can be demonstrated that they will not result in increased emissions. Air quality conformity analysis is generally the responsibility of the community’s transportation planning organization.

The final report with its recommendations has officially been released.

The PSCAA has notified the 600+ people who provided input on the draft strategies last fall about the report and recommendations, and alerted them that their Board of Directors will review, discuss and hear input about the recommendations at its January 26 meeting.

Here are links to:

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