Strategy for Ozone Reduction

The year 2003 promises to be an important year for planning to attain both state and national 1-hour ground-level ozone standards. The 2000 Clean Air Plan (CAP) to attain the state 1-hour ozone standard is due for its three-year update. The CAP is prepared under the California Clean Air Act of 1988 to meet the state ozone standard of 9 parts per hundred million (pphm).

The 2001 Ozone Attainment Plan (OAP) to meet the national 1-hour ozone standard contains the commitment to conduct a mid-course review in 2003 and submit an amendment, the Ozone Attainment Strategy, by early 2004. The OAP is required by the federal Clean Air Act Amendments of 1990 to attain the less stringent national 1-hour ozone standard of 12 pphm. After adoption of the OAP by the regional air quality planning agencies and approval by the state Air Resources Board (ARB), it is submitted to the US Environmental Protection Agency (EPA). Upon EPA approval, it becomes part of California's State Implementation Plan (SIP).

The three regional agencies charged with preparing the OAP are the Bay Area Air Quality Management District (Air District), the Metropolitan Transportation Commission (MTC), and the Association of Bay Area Governments (ABAG), who are coordinating activities through the Regional Agency Coordinating Committee (see What Is RACC?). The Air District and MTC are completing the review of a number of the Further Study Measures (FSMs) contained in the 2001 OAP (see FSMs below). In addition, the agencies have hired consultants to conduct complex ozone modeling to provide a sound technical basis for the ozone reduction strategy. The agencies have also begun the public involvement process for this round of ozone planning.

The three agencies are urging individuals and groups to become involved in the planning process. In January, a public notice requesting suggestions for ozone control measures and strategies, and ways to increase public involvement in the process, was issued. While suggestions will be received at any time, the earlier they are received, the better.

An advisory group, the Ozone Working Group, is being formed to discuss and provide input to the planning process. Anyone interested in the ozone planning process for the Bay Area is encouraged to participate in the Ozone Working Group meetings. The first meeting will be held on Thursday, March 27 from 10 am to 12 noon, at the Metro Center Auditorium, 101 Eighth Street, Oakland 94607. Subsequent meetings are expected to be held bimonthly, in May, July, September, and November of 2003, and January of 2004.

A public hearing on the 2004 Ozone Attainment Strategy and the CAP is anticipated in February 2004, with the regional agencies adopting the Ozone Attainment Strategy and CAP in March and submittal of the documents to ARB in April 2004.

The four FSMs for stationary sources being investigated by the Air District, along with ARB and EPA, are:

• FSM 8—Refinery Pressure Vessels, Blowdown Systems, and Flares. Refinery blowdown systems collect and recover liquids and gases discharged from process units. Flares provide backup safety devices. Pressure relief valves (PRVs) constitute another safety mechanism and can be vented to the atmosphere or to blowdown systems that may or may not have gas recovery systems and flares. Existing Air District regulations require PRVs on new sources to be vented to a gas recovery system or to flares. Such controls are also required for an existing PRV that vents a second release at a single source within five years. The study is looking at the feasibility, cost, and safety of further reducing emissions from these operations.
• FSM 9—Refinery Wastewater Systems. Most of the emissions from wastewater systems are controlled by Air District regulations and EPA standards. Controlling remaining emissions at one point in a system would risk increasing emissions at another point. The study is examining the wastewater system of each refinery to identify the ways of reducing emissions from each and the cost and effectiveness.
• FSM 10—Organic Liquid Storage Tanks. The study will compare the effectiveness of external and internal floating roofs on refinery storage tanks in controlling emissions. Also part of the study is the identification of a more accurate test method for measuring the vapor pressure of low vapor pressure liquids. These liquids are not under Air District regulation, and identifying those liquids near but above the regulatory threshold would allow further emissions reductions. The study includes consideration of more stringent tank cleaning standards.
• FSM 11—Marine Tank Vessel Activities. Air District regulations require the control of emissions from loading specified organic liquid cargos. The study will determine whether the regulation of less volatile liquid cargos would produce significant emissions reductions. Also being studied is the feasibility of regulating purging (venting to release hydrocarbon vapors) of marine vessel tanks.

The transportation-related FSMs being studied by MTC are:

• FSM 1—Study Benefits of a Particulate Trap Retrofit Program. MTC and the Bay Area transit operators studied emissions reductions from accelerating the retrofit of diesel buses with particulate traps, finding a net emissions reduction of about 4 tons of particulate matter per year, with the potential for expanding the program to more buses.
• FSM 2—Update High Occupancy Vehicle (HOV) Lane Master Plan. An updated HOV Master Plan and Regional Express Bus plan were adopted by MTC in February. The study included the present and projected use of HOV lanes, the effect of increased enforcement, increasing occupancy requirements, and allowing a buy-in for commercial vehicles. Conversion of some HOV lanes to bus-only lanes and the use of certain freeway shoulders by express buses during peak hours were also considered.
• FSM 3—Study Effects of High Speed Freeway Travel. MTC studied reduction of motor vehicle emissions by reducing freeway speeds to 60 and 55 miles per hour, finding emissions reductions would be 1-3 tons/day regionwide and probably more if enforcement were concentrated in the central Bay Area during morning peak hours. Although the reduction is small, it could be important during Spare the Air days and may be considered as an "episodic" measure.
• FSM 4—Implement Parking Management Incentive Program. The study examined incentives for cities to lower parking requirements near transit stations, convert free public parking to fee parking, and add new residential units near transit. The analysis determined that many cities already have charges for large lots and garages, and existing and new parking charges would need to be substantially increased to have significant impacts on air quality.
• FSM 5—Enhanced Housing Incentive/Station Access Program. The study by MTC, the Air District, and ABAG looked at expanding funding sources for MTC's Housing Incentive Program (HIP) to provide incentives for new housing near transit. The recommended strategy would pool funds from MTC, the Air District, congestion management agencies and state affordable housing funds, which could create a pool of $15 million available annually. Transit station access looked at shared station cars, bicycle facilities, and expanding shuttles. These measures would provide better mobility around stations but offer only limited emission benefits.
• FSM 6—Further Smog Check Program Improvements. In September 2002, AB 2637 (Cardoza) was signed into law, requiring an enhanced Smog Check Program to be implemented in the urbanized parts of the Bay Area. The program will be phased in between July 1 and October 1, 2003.
• FSM 7—Parking Cash Out Pilot Program. State law requires certain employers who offer employees subsidized parking to offer a cash allowance in lieu of a parking space, but compliance with such parking cash out programs is limited. MTC, the Air District, and ARB are implementing and evaluating a pilot outreach program, focusing on large public and private employers in heavily travelled corridors, to be completed in December 2003.

In addition to the above FSMs, MTC and the Air District have been considering episodic measures to be applied on Spare the Air days, when there is a high probability that ozone standards will be exceeded. Besides FSM 3, programs being considered include incentives for owners of older cars not to drive on Spare the Air days, and for employers who allow employees to telecommute or who offer employees free transit passes on Spare the Air days.

Suggestions for strategies to reduce emissions that contribute to the formation of ozone (reactive organic gases and oxides of nitrogen) should be submitted to Jean Roggenkamp, BAAQMD, 939 Ellis Street, San Francisco CA 94109, or e-mailed to jroggenkamp@baaqmd.gov, or faxed to (415) 749-4741.

For information on the Ozone Working Group, contact Henry Hilken at (415) 749-4642 or by e-mail at hhilken@baaqmd.gov.

For updated information on the Bay Area ozone planning process, check the Air District website at http://www.baaqmd.gov/planning/2004sip/2004sip.htm