## Report No. SR2007-09-03



# Assessment of the Need for Long-Term Reduction in Consumer Product Emissions
in the South Coast Air Basin

prepared for: 

## Consumer Specialty Products Association

September 12, 2007

prepared by:

Sierra Research, Inc.
1801 J Street Sacramento, California 95811 (916) 444-6666Report No. SR2007-09-03



### Assessment of the Need for Lo ng-Term Reductions in Consumer
Product Emissions in the South Coast Air Basin

prepared for:

Consumer Specialty Products Association

September 12, 2007

Principal author:

James M. Lyons

Sierra Research, Inc.

1801 J Street Sacramento, CA 95811 (916) 444-6666-i

### Assessment of the Need for Lo ng-Term Reductions in Consumer
Product Emissions in the South Coast Air Basin

Table of Contents

Page

1. Executive Summary.......................................................................................................1

2. Introduction................................................................................................................ ....3

3. Consumer Products Overview .......................................................................................5

4. The 2007 AQMP............................................................................................................7

4.1 General AQMP Requirements ............................................................................. 7
4.2 Emission Reduction Targets of the 2007 AQMP ................................................ 8

4.3 2007 AQMP Control Measures ......................................................................... 10

5. Assessment of the Need for Long-Te rm Reductions in Consumer Product
Emissions .....................................................................................................................1 3-ii- List of Tables

Table Page

Table 4-1 2007 AQMP PM 2.5 Control Strategy.................................................................9

Table 4-2 2007 AQMP Ozone Control Strategy..............................................................10

Table 4-3 2023 SCAB Emission Reduc tions From 2007 AQMP Ozone Control

Measures ..........................................................................................................11

Table 5-1 Environ Ozone Air Quality Modeling Results Without Measure SCLTMO3.....................................................................................................................14-1- 

### 1. EXECUTIVE SUMMARY

The long-standing efforts to eliminate the air quality problems related to photochemical “smog” in Southern California’s South Coas t Air Basin (SCAB) are well known. These efforts have been primarily aimed at bringi ng the SCAB into complia nce with the federal National Ambient Air Quality Standard ( NAAQS) for ozone. As with all other NAAQS,
the ozone standard has been set at a level designed to protect public health.

More recently, public exposure to high ambient concentrations of fine particulate matter (PM 2.5 ) * has also become a major concern, lead ing to the establishment of a NAAQS for that pollutant. As is the case with respect to ozone, considerable efforts have been made
to reduce emissions of both PM 2.5 as well as its precursors.

The latest step in the efforts to bring the SCAB into compliance with both the ozone and

PM 2.5 NAAQS has been the development of the 2007 Air Quality Management Plan (AQMP) by the South Coast Air Quality Management District (SCAQMD). Compliance
with the PM 2.5 NAAQS in the SCAB is required by 2015, while compliance with the ozone NAAQS is required by 2024. The 2007 AQMP includes an air quality modeling
assessment intended to establish the emissions le vels of pollutants that can be tolerated in the SCAB while assuring that levels of ozone and PM 2.5 do not violate the respective NAAQS, and a suite of control measures de signed to bring emissions down to those levels. This suite of control measures, which will be implemented by both the SCAQMD and the California Air Resources Board (C ARB), targets virtually every source of pollutants related to ozone and PM 2.5 , but focuses primarily on reductions in oxides of nitrogen (NOx) emissions as the strategy for attainment of both the ozone and PM 2.5 NAAQS.

One of the emissions sources targeted by the 2007 AQMP is consumer products, the use
of which results in emissions of VOC but not NOx. Although consumer products have been subject for almost 20 years to increasi ngly stringent emissions regulations imposed by CARB, additional reductions in VOC emissions from this source are sought in the 2007 AQMP. The AQMP proposes additional consumer product regulations—including additional near-term CARB regulations and a lo ng-term measure that would take effect beyond 2020. † The near-term consumer product re gulations are expe cted to aid in achieving both the PM 2.5 and the ozone NAAQS. In cont rast, the long-term consumer

* Fine particulate matter is defined as particles with a diameter of less than 2.5 microns.

† The near-term CARB control measure is referred to as CARB’s Consumer Products Program, and the long-term measure is designated as SCLTM-03 in the 2007 AQMP. As discussed in Section 4, there are three SCAQMD near- and mid-term consumer product control measures discussed in the AQMP.-2- product regulation is intended to achieve th e very last increm ent of VOC emission reductions that the air quality analysis performed for the 2007 AQMP indicates may be required for attainment of the ozone NAAQS. However, the 2007 AQMP has not
examined the need for this s econd round of regulation in detail, and it is not clear it will actually be required to achieve co mpliance with the ozone NAAQS.

This report presents the results of a detail ed air quality modeli ng analysis performed using the same data, models, and methods used in preparation of the 2007 AQMP and specifically examines the need for the s econd round of long-term consumer product regulations incorporated into the 2007 AQMP. The results of this analysis show that the long-term regulations seeking additional redu ctions in consumer product VOC emissions

are not necessary for the achievement of co mpliance with the ozone NAAQS in the

SCAB.

###-3- 

### 2. INTRODUCTION

Air quality problems related to photochemi cal “smog” have been well documented in
Southern California’s South Coast Air Basin (SCAB) since Professor A.J. Haagen-Smit first determined the chemical processes l eading to its formation during the 1950s. The principal component of smog is ozone, which is formed in the atmosphere as the result of photochemical reactions involving oxides of nitrogen (NOx) and reactive volatile organic compounds (VOCs). Since that time, efforts to reduce ambient ozone concentrations to acceptable levels have been on-going. These efforts have been primarily aimed at bringing the SCAB into compliance with the federal National Ambient Air Quality Standard (NAAQS) for ozone. As with all other NAAQS, the ozone standard has been set at a level designed to protect public health.

More recently, public exposure to high ambient concentrations of fine particulate matter (PM 2.5 ) * has also become a major concern, lead ing to the establishment of a NAAQS for that pollutant. Fine particulate matter may be directly emitted by sources such as Diesel vehicles or, like ozone, may be formed in the atmosphere from precursors such as NOx, oxides of sulfur (SOx), and VOC. As is th e case with respect to ozone, considerable
efforts have made to reduce emissions of both PM 2.5 as well as its precursors.

The latest step in the efforts to bring the SCAB into compliance with both the ozone and

PM 2.5 NAAQS has been the development of the 2007 Air Quality Management Plan (AQMP) by the South Coast Air Quality Management District (SCAQMD). Compliance
with the PM 2.5 NAAQS in the SCAB is required by 2015, while compliance with ozone NAAQS is required by 2024. The 2007 AQMP includes an air quality modeling
assessment intended to establish the emissions le vels of pollutants that can be tolerated in the SCAB while assuring that levels of ozone and PM 2.5 do not violate the respective NAAQS, and a suite of control measures de signed to bring emissions down to those levels. This suite of control measures, which will be implemented by both the SCAQMD and the California Air Resources Board (C ARB), targets virtually every source of pollutants related to ozone and PM 2.5 , but focuses primarily on reductions in NOx emissions as the strategy for a ttainment of both the ozone and PM 2.5 NAAQS.

One of the emissions sources targeted by the 2007 AQMP is consumer products, the use
of which results in emissions of VOC but not NOx. Although consumer products have been subject for almost 20 years to increasi ngly stringent emissions regulations imposed by CARB, additional reductions in VOC emissions from this source are sought in the

* Fine particulate matter is defined as particles with a diameter of less than 2.5 microns.-4- 2007 AQMP. The AQMP proposes that CARB and perhaps the SCAQMD adopt additional consumer product regulations in the near-term and that an additional long-term regulatory effort targeting consumer produc ts take effect beyond 2020. The near-term consumer product regulations wi ll aid in achieving both the PM 2.5 and the ozone NAAQS. The long-term consumer product regu lations, however, are intended to achieve the very last increment of VOC emission reductions that the ai r quality analysis performed for the 2007 AQMP indicates may be required for attainment of the ozone NAAQS. The 2007 AQMP has not, however, ex amined the need for the long-term regulations in detail and it is not clear that it will actually be required to achieve compliance with ozone NAAQS . Given this, the purpose of th is report is to investigate the need for additional long-term reductions in VOC emissions from consumer products in greater detail than was done dur ing preparation of the 2007 AQMP.

This introduction is followed by a brief overview of consumer products and their regulation; a summary of the 2007 AQMP; a nd, lastly, a summary of a detailed air quality modeling analysis perf ormed using the same data, models, and methods used in preparation of the 2007 AQMP, and that specifi cally examines the need for the long-term consumer product regulations incorp orated into the 2007 AQMP.

###-5- 

### 3. CONSUMER PRODUCTS OVERVIEW

The California Air Resources Board (CARB) has a well-establishe d regulatory program for consumer products that is intended to reduce emissions of volatile organic compounds (VOC) from these products. From the pers pective of air quality, a consumer product is defined by the Section 41712 of the Calif ornia Health and Safety Code as:

a chemically formulated product us ed by household and institutional consumers, including, but not limite d to, detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products; but do es not include other paint products, furniture coatings, or architectural coatings.

The one common characteristic of consumer pr oducts is that their formulations contain VOCs that, to some degree, enter the atmosphere. VOC emissions from consumer products were first targeted for regula tion by CARB during the late 1980s when the agency approved its first “Consumer Products Control Plan.” * Beginning with the adoption of the Phase I Consumer Products Re gulations in 1990, to date there have been 15 separate CARB rulemakings related to the regulation of VOC emissions from consumer products. † Control measures targeting VOC emissions from consumer products were incorporated into CARB’s stat ewide control strategies for both the 1994 and 2003 ozone State Implementation Plans (SIPs). ‡

As part of the most recent CARB rulemaking, the agency estimated that by 2010 its existing consumer product regulations would re sult in the eliminati on of approximately 180 tons per day of VOC emissions statewide. § This translates into about a 42%
reduction in VOC emissions from the entire consumer products category relative to uncontrolled levels. The magnitude of th is reduction is remarkable given that reformulation is the only m eans of reducing VOC emissions from consumer products and the presence of specific VOC compounds is, in many cases, essential to product efficacy and performance.

* Consumer Products Control Plan, State of California Air Resources Board, June 16, 1989.

† See http://www.arb.ca.gov/consprod/regact/passhearings.htm
‡ See http://www.arb.ca.gov/planning/sip/sip.htm

§ Proposed Amendments to the California Consumer Products Regulation and the Aerosol Coatings Regulation, California Air Resources Board, September 29, 2006.-6- Another important factor associated with VOC emissions from consumer products is that they tend to have lower photochemical reactiv ity or “ozone forming potential” than VOC emissions from other sources. A previous study * determined that consumer product VOC emissions are approximately 50% less photoc hemically reactive than the average VOC emissions from other sources. In addition, CARB staff has reported that motor vehicle
exhaust VOC emissions are three times mo re reactive than VOC emissions from consumer products. † This means that eliminating VOC emissions from sources other than consumer products is likely to result in a considerably larger air quality benefit than would be achieved by reducing an equivale nt mass of VOC emissions from consumer products.

In summary, many consumer products, by their very nature, must include VOC compounds in their formulations to ensure e fficacy and proper performance. Some of these VOC compounds enter the atmosphere wh ere they can cause adverse impacts on air quality, with increased ambient ozone concentrat ions being the primary effect. This fact has long been recognized by CARB, which ha s been regulating VOC emissions from consumer products for almost 20 years, and th ere have been dramatic reductions in VOC emissions from consumer products as a resu lt of regulations imp lemented during that time. Finally, on a per-unit basis, VOC emissions from sources other than consumer products lead to greater increas es in ambient ozone levels.

###

* Impact of Consumer Products on California’s Air Quality, Sierra Research Report SR97-07-01, July
1997.

† See http://www.arb.ca.gov/planning/sip/2007sip/2007sip.htm-7- 

### 4. THE 2007 AQMP

The most recent South Coast Air Quality Mana gement District Air Quality Management Plan has been designated as the 2007 AQMP. * The 2007 AQMP describes how compliance with federal NAAQS for ozone and PM 2.5 † will be achieved in the South Coast Air Basin. As noted previously, th e SCAB is currently classified as a
nonattainment area with respect to the PM 2.5 NAAQS and a “severe” nonattainment area with respect to the ozone NAAQS. As part of the 2007 AQMP, however, the SCAQMD is requesting redesignation of the SCAB to an “extreme” ozone nonattainment area. Under federal law, the SCAB is required to come into attainment with the PM 2.5 NAAQS no later than 2015. Assuming that the SCAB is redesignated as an extreme ozone nonattainment area, compliance with the NAAQS is required by 2024. Attainment of the NAAQS requires that observed ambient levels of PM 2.5 and ozone demonstrate that compliance with the NAAQS has been achieved.



### 4.1 General AQMP Requirements

The main purpose of the 2007 AQMP is to demonstrate and document how the SCAB will achieve compliance with the PM 2.5 and ozone NAAQS by the applicable deadlines. In general terms, this required the following:

1. Development of an inventory of current emissions from all sources;

2. Development of an inventory of projecte d future-year emissions from all sources that accounts for all existing emission control measures;

3. Performance of an air quality modeling analysis to determine which pollutants need to be controlled and to what degr ee emissions of those pollutants must be reduced to achieve compliance with the NAAQS; and

4. Development of a suite of emission contro l measures that achieve the required emission reductions by the required compliance dates.

The results of the air quality modeling analys is are particularly important because they both demonstrate that the area can be brought into attainment with the NAAQS and
establish limits on the amount of pollutants that can be emitted while maintaining

* The draft final version of the SCAQMD 2007 AQMP is available at http://www.aqmd.gov/aqmp/07aq mp/07AQMP_draftfinal.html.

† The fine particulate NAAQS applies to particles that are less than 2.5 microns in diameter.-8- compliance with the NAAQS. This limit is fr equently referred to as the emissions “carrying capacity” of the area.

Subtracting the projected future-year emissi ons of a given pollutant at the compliance date from the carrying capacity for that pol lutant yields the amount of emissions that must be eliminated by the new control measures incorporated into the AQMP by that compliance date. Federal law imposes requirements on the new control measures that include the following:

1. The emission reductions that would resu lt from the implementation of each measure must be quantifiable;

2. The emission reductions due to each meas ure must be surplus (e.g., not already assumed to have occurred for purposes of attaining the NAAQs);

3. The emission reductions due to each measure must be permanent;

4. It must be demonstrated that each measure can be implemented; and
5. Each measure must be federally enforceable.

Another issue with respect to control measures is that federal and state laws have created distinct authorities with respect to the imposition of emission regulations on specific sources. For example, only the federal govern ment has the authorit y to regulate certain sources, such as new locomotives and aircraf t; the state has the authority to regulate ubiquitous sources such as on-road vehicles , pesticides, and consumer products; and the SCAQMD has the authority to regulate local sta tionary sources such as power plants and refineries, and most commercial faciliti es. The 2007 AQMP describes the emission control measures proposed for adoption by bot h the SCAMQD and the state, with the latter also being described in CARB’s Proposed State Strategy. *

Finally, an important aspect of the redesi gnation of the SCAB to an “extreme” ozone nonattainment area is that it provides (in add ition to a later complian ce deadline) a “black
box” to which some of the emission reductions required for attainment can be allocated.
Emission reductions allocated to the black box are not required to be associated with defined control measures, but rather are reductio ns that are anticipated to be achieved as
the result of “advancements” in emission cont rol technology. Despite the fact that the black box affords time for technological develo pment prior to the specification of the control measures that will be implemente d, the SCAQMD has already defined four longterm control measures in the 2007 AQMP.



### 4.2 Emission Reduction Targets of the 2007 AQMP

As discussed previously, the relative importance of emissions of different pollutants differs with respect to compliance with the PM 2.5 and ozone NAAQS and there are two
distinct deadlines for compliance. As a result, the 2007 AQMP has two distinct emission

* See http://www.arb.ca.gov/planning/sip/2007sip/2007sip.htm-9- reduction targets, which are discussed below. It is important to note, however, that, in general, there is little documentation provided in the 2007 AQMP regarding how these targets were selected, what alternatives were considered, and how sensitive the attainment demonstrations are to change s in the target emission levels.

Beginning with the PM 2.5 emission reduction targets, the pollutants of concern include
direct PM 2.5 emissions as well as emissions of SOx, NOx, and VOC, which are all precursors to the formation of secondary PM 2.5 . Based on the ai r quality modeling analysis for the 2007 AQMP, the relative reduction in ambient PM 2.5 concentrations due to the reduction of a given mass of SOx emissions is 10 times greater than that of the
same mass reduction in VOC emissions. In a ddition, the effects of reductions in a given
mass of NOx and direct PM 2.5 emissions are 5 and 3 times greater, respectively, than are reductions in VOC emissions. Using these and other data, the SCAQMD determined the carrying capacity (or the level of emissions of these pollutants that can be tolerated) for achieving the PM 2.5 NAAQS by the 2014 deadline. These data are presented in Table 4-1, along with baseline emissions data for 2005 and 2014. As shown in the table, the focus of the SCAQMD strategy for achieving the PM 2.5 NAAQS requires dramatic
reductions in SOx and NOx emissions and sma ller, but still substantial, reductions in
emissions of direct PM 2.5 and VOC.

Turning to the carrying capacity for achie vement of the ozone NAAQS, the 2007 AQMP air quality analysis indicates, as shown in Table 4-2, that dramatic reductions in NOx emissions will be required, along with signifi cant but much more modest reductions in VOC emissions. Also, as noted above, the 2007 AQMP has allocated some of the emission reductions required fo r attainment to the black box; these allocations are also
shown in Table 4-2.

Table 4-1 2007 AQMP PM 2.5 Control Strategy Pollutant Emissions (tons per day)

Direct PM 2.5 Sox NOx VOC

2005 Baseline 106 62 1029 720

2014 Baseline 102 43 654 528 2014 Carrying Capacity 87 19 454 469 Required Reductions from 2014
Baseline 15 24 200 59

Reductions as % of 2014
Baseline 15% 56% 31% 11%-10- Table 4-2 2007 AQMP Ozone Control Strategy Pollutant Emissions (tons per day)

NOx VOC

2005 Baseline 1029 720

2023 Baseline 506 536 2023 Carrying Capacity 114 420 Total Required Reductions from 2023 Baseline 392 (188) a 116 (28) a

Total Reductions as % of 2023 Baseline 78% 22%

Black Box Reductions as % of 2023 Baseline 37% 5%

a Values in parenthesis are reductions attributed to the advanced technology control measures of the black

box.

Overall, as shown, the 2007 AQMP strategy for attainment of the ozone NAAQS relies heavily on NOx emission reductions and NOx reductions dominate the black box. The focus of the 2007 AQMP control strategy for both PM 2.5 and ozone on NOx emission reductions is significant because the relati onship between NOx and VOC emissions and ozone is complicated and non-linea r. As a result, it is possi ble that at some points along the AQMP’s NOx reduction pathway, additiona l reductions in VOC emissions may yield little or no additional improvement in ambient ozone levels.



### 4.3 2007 AQMP Control Measures

As noted above, given the differences in th e legal authority of CARB and the SCAQMD to adopt control measures targeting differe nt sources, the 2007 AQMP includes a suite of measures that each agency will implement. The SCAQMD measures generally target stationary and area sources and, to a limited degree, mobile sources. In contrast, the CARB measures, which are implemented on a statewide (rather than local) basis, primarily target mobile sources as well as consumer products.

Table 4-3 summarizes the reductions in NOx and VOC emissions in the SCAB in 2023 resulting from control measures to be implemented by the SCAQMD and other local agencies and those to be implemented by CARB and other state agenci es that have been incorporated into the 2007 AQMP. As show n in the table, the 2007 AQMP will result in the implementation of new control measures ta rgeting virtually all sources of emissions and will include additional CARB regulations for consumer products. These additional CARB regulations, which are to be adopted by 2012 and implemented by 2014, are expected to yield VOC reductions of 14 t ons per day in the SCAB in 2023. The
reductions in VOC emissions achieved due to these near-term CARB consumer product measures are quite significant as they amount to 16% of all identified VOC reductions and 12% of the total required VOC reductions , including those allocat ed to the black box.-11- Table 4-3
2023 SCAB Emission Reductions From 2007 AQMP Ozone Control Measures Emission Reductions (tons per day) Agency/Source NOx VOC

SCAQMD/All Short- and Mi d-Term Measures 9 19 CARB/Passenger Vehicles 7 10

CARB/On-Road Trucks 18 2

CARB/Goods Movement 100 3

CARB/Other Off-Road 16 26

CARB/Consumer Products 0 14 Additional CARB Measures Proposed by SCAQMD 34 14

Local Goods Movement Measures 11 0

Total Identified 195 88

Black Box 188 28

Total 383 116

Although general authority to regulate cons umer products in California rests with CARB, * the SCAQMD’s list of short- and mid- term control measures includes the following measures targeting consumer products:

• CTS-01 – Emission Reductions from Lubricants;

• CTS-03 – Consumer Product Certificati on and Emission Reductions from Use of Consumer Products at Institutional and Commercial Facilities; and

• CTS-04 – Emission Reductions from the Re duction of VOC Content of Consumer Products Not Regulated by the State Board.

However, despite the fact that the AQMP associates 2023 SCAB VOC emission reductions of 2.0, 2.2 and 6.0 tons per day with CTS-01, CTS-03, and CTS-04, respectively, it also notes that these reducti ons are not included in the reductions claimed for all of the SCAQMD’s short- and mid-te rm measures. The AQMP’s treatment of these measures is further confused by the f act that the SCAQMD’s air quality modeling analysis assumes that the consumer product emission reductions associated with CTS-03
are realized but that those associated with CTS-04 are not. Also, the SCAQMD air quality modeling analysis in cludes the reductions associ ated with CTS-01, but those
reductions are assumed to come from a s ource category other than consumer products.

* See Section 41712, California Health and Safety Code.-12- In addition to identifying the control measures summarized above, the SCAQMD has included in the 2007 AQMP recommendations for four long-term control measures that could provide at leas t some of the emission reductions allocated to the black box. Despite being included in the 2007 AQMP by the SCAQMD, all four measures would target sources that only CARB has authority to regulate: mobile on- and off-road sources and consumer products. The SCAQMD’s r ecommended measures are described in the 2007 AQMP as follows:

• SCLTM-01A – Further Reductions from On-Road Mobile Sources;

• SCLTM-01B – Further Emission Reduc tions from On-Road Heavy-Duty Vehicles;

• SCLTM-02 – Further Reductions from Off-Road Mobile Sources; and

• SCLTM-03 – Further Reductions from Consumer Products.

The 2023 emission reductions in the SCAB attr ibuted to these control measures by the SCAQMD are 62 tons per day of NOx for th e combination of SCLTM-01A and -01B, 116 tons per day of NOx for SCLTM-02, and 20 tons per day of VOC for SCLTM-03.

The long-term consumer product control m easure, SCLTM-03, would account for twothirds of the VOC reductions allocated to the black box. Ba sed on the discussion of this measure in the 2007 AQMP, it appears that it was selected simply because, by 2023, consumer product emissions will be the single largest remaining source of VOC emissions. The 20 ton per day reduction assi gned to SCLTM-03 is relative to an 88 ton per day total consumer product emission inventory. It is not clear that it will be technically or commercially feasible * to achieve the additional 23% reduction in consumer product emissions ascribed to SCLTM -03 from what will be an already highly controlled source. Further, given the lack of documenta tion in the 2007 AQMP regarding how the VOC carrying capacity was determin ed, it is not clear that the VOC emission reductions from SCLTM-03 are even necessary to demonstrate or achieve attainment with the ozone NAAQS.

###

* Nor is it clear that the other requirements of Health and Safety Code Section 41712 can be satisfied.-13- 

### 5. ASSESSMENT OF THE NE ED FOR LONG-TERM REDUCTIONS

IN CONSUMER PRODUCT EMISSIONS

As discussed above, there are a number of fact ors that call into question the need for the inclusion of SCLTM-03 in the AQMP. These factors include the following:

• The methodology used to determine the requ ired VOC reductions attributed to the black box;

• The magnitude of the required NOx reductions attributed to the black box;

• The projected margin of compliance with the eight-hour ozone NAAQS; and

• The fact that the long-term consumer products measure will result in only limited reductions in emissions of low reactivity VOCs.

Given the above factors, an assessment of the need for the inclusion of SCLTM-03 was
undertaken. This assessment involved the re plication of the SC AQMD ozone air quality modeling analysis that forms the basis for the AQMP attainment demonstration with and
without the inclusion of SCLTM-03. Th is assessment, performed by ENVIRON, * is documented in Appendix A.

These results are summarized in Table 5- 1, which shows the eight-hour ozone design values calculated by ENVIR ON without SCLTM-03 in place and the increase in design
value if the measure is eliminated from th e AQMP. As shown, the peak eight-hour ozone value of 84 ppb at Crestline is unchange d by the elimination of SCLTM-03 and the maximum increase in eight-hour ozone le vels at any site is 1 ppb.

The results of the ENVIRON assessment indi cate that if the SCLTM-03 control measure were not implemented, the eight-hour average ozone levels at all monitoring sites would remain below the NAAQS attainment level of 85 ppb. More simply stated, even if the SCLTM-03 measure were eliminated from the 2007 AQMP, the SCAB would be expected to attain the ozone NAAQS based on the air quality analysis that forms the basis for the 2007 AQMP. Therefore, measure SCLTM-03 can be eliminated from the 2007 AQMP even before an assessment is made as to whether it would conform to Health and Safety Code Section 41712.

* ENVIRON developed the CAMx model used by the SCAQMD; all of the models, inputs, and other data required for the assessment were provided to ENVIRON by SCAQMD staff.-14- Table 5-1 Environ Ozone Air Quality Modeling Results Without Measure SCLTM-O3

Site Design Value without

SCLTM-03 (ppb) Increase in Design Value Due to
Elimination of SCLTM-03 (ppb)

Azusa 62 1 Banning Airport 68 1

Burbank 68 0

Crestline 84 0

Lake Elsinore 61 0

Fontana 81 1

Glendora 80 1

Indio 55 0

Pasadena 73 1

Perris 80 1 Palm Springs 58 0

Pomona 76 1

Redlands 81 0

Reseda 66 0

Rubidoux 77 1

Santa Clarita 75 1

###

### APPENDIX A

ENVIRON Report on

“Need for Additional Consumer Product VOC Controls Beyond the ARB’s Control
Measure to Achieve Attainment of the 8-Hour Ozone Standard in Southern
California”A-1 Need for Additional Consumer Product VOC Controls Beyond the
ARB’s Control Measure to Achieve Attainment of the
8-Hour Ozone Standard in Southern California

Ralph Morris and Bonyoung Koo ENVIRON International Corporation 101 Rowland Way Novato, California 94945

September 6, 2007

BACKGROUND

The South Coast Air Quality Management Di strict (SCAQMD) has released a 2007 Air Quality Management Plan (AQMP) that proposes control measures to achieve the 8-hour ozone NAAQS by 2024. The 8-hour ozone at tainment demonstration was based on photochemical modeling using the Comprehens ive Air Quality Mode l with extensions (CAMx). CAMx was run for a 2002 base case emissions scenario and a 2023 base case and 2023 AQMP control case and the results used to project 8-hour ozone Design Values to 2023 for comparison with the NAAQS. The projected 2023 8-hour ozone Design Values under the 2007 AQMP control plan were all below the 85 ppb NAAQS, thereby demonstrating attainment of the 8-hour ozone standard.

The 2007 AQMP attainment demonstration includes three control measures for controlling volatile organic compound (VOC) emissions from Consumer Product (CP)
sources. The California Air Resources Bo ard (ARB) has jurisdiction over Consumer Products and developed the near-term cont rol measure ARB-CONS-01 to control VOC emissions from CP sources. On top of th is, the SCAQMD developed an additional longterm CP control measure, SCLTM-03, that speci fies additional VOC CP controls that go beyond the ARB CP control measure. Among th e additional short-term control measures proposed by the district, only CTS-03 was a pplied to CP sources. CTS-01 measure was applied to non-CP district-con trolled sources and CTS-04 was not used in the attainment
demonstration.

The Consumer Specialty Products Association, Inc. retained ENVIRON to determine the effects of removing the SCAQMD’s additi onal SCLTM-03 CP VOC control measure on the 2007 AQMP 8-hour ozone attainment demonstration.

APPROACH

ENVIRON acquired the CAMx modeling inputs and outputs fr om the SCAQMD used in the 2007 AQMP 8-hour ozone attainment demonstration modeling. The 2007 AQMP ozone modeling database was stored in an IDE hard disk and shipped to ENVIRON inA-2 mid April 2007 by Satoru Mitsutomi at SC AQMD. The disk contained CAMx v4.40beta source code and input database for the following modeling periods:

3⁄4 August 4-7, 1997 3⁄4 August 4-8, 2004 3⁄4 May 17-24, 2005 3⁄4 July 14-19, 2005 3⁄4 August 2-9, 2005 3⁄4 August 25-29, 2005

The modeling input database includes:

3⁄4 Initial and boundary conditions 3⁄4 Photolysis rate inputs 3⁄4 Albedo/haze/ozone inputs 3⁄4 Landuse input 3⁄4 Meteorological inputs (height/p ressure/wind/temperature/water vapor/cloud/rain/vertical diffusivity) 3⁄4 Merged/premerged area and point-sour ce emissions for base (2002/2004/2005), future (2023), and intermed iate (2009/2012/2014/2017/2020) years 3⁄4 Emission control factor inputs

The disk also contained GEM emission m odel code and scripts, various emission preprocessing tools, and postprocessing t ools for CAMx model outputs. The CEPA program used to prepare the emission contro l factors was provided to ENVIRON in late May 2007 by Susan Yan at SCAQMD via FTP transfer.

As noted earlier, three control measures were applied to VOC emissions from CP sources: ARB-CONS-01 developed by ARB, and further reductions applied by SCAQMD (SCLTM-03 and CTS-03). Emissions adjustment factors for these control measures were specified in a CEPA input file. The SCLTM-03 CP control measure was removed from the 2007 AQMP control plan by setting the adjustment factors for the SCLTM-03 in the CEPA input file to 1.0 and re-running the CEPA program. The 2023 modeling was performed without the addi tional SCLTM-03 CP control measure to
determine whether it is needed to attain the 8-hour ozone NAAQS in southern California.

RESULTS

ENVIRON first tried to reproduce the 2023 8- hour ozone attainment demonstration published in the 2007 AQMP using the 2002 ba se case and 2023 control case CAMx output files provided by the SCAQMD. The calculated 2023 8-hour ozone Design Values for the 2007 AQMP control plan were cl ose, but did not exactly match the values published in the 2007 AQMP. The differences were traced to differences in the CAMx 2002 base case ozone estimates. The SCAQM D was contacted and the district staff
noted the CAMx 2002 base case emissions i nputs used in generating the 2023 8-hourA-3 ozone Design Values published in the 2007 AQMP were different than what was supplied to ENVIRON and that the emission f iles had been accidentally overwritten so could not be provided at the moment. Acco rding to Satoru Mitsutomi, the SCAQMD is currently in the process of re producing the lost emissions and they will be available soon. Instead, the SCAQMD provided the 2002 base case CAMx modeling outputs that it claims were used for the 2007 AQMP. Alt hough using the output data made it possible to reproduce the ozone Design Values published in the 2007 AQMP within rounding error (it appears th at the design values published in the 2007 AQMP were rounded; ENVIRON used truncation, which is conventional for design value calculation) for most of the monitoring sites, ther e still was a significant difference in the design value
ENVIRON calculated and that published in the 2007 AQMP fo r two of the sites: Azusa
and Burbank. † For this analysis, ENVIRON proceeded using the 2002 base case modeling results provided by the SCAQMD, whos e use still demonstrated that 8-hour
ozone attainment would be achieved in 2023 under the 2007 AQMP control plan.

The SCLTM-03 CP control measure was then eliminated from the 2007 AQMP control plan and new 2023 modeling was performed that included all of the control measures in the 2007 AQMP with the exception of the SC LTM-03 CP control measures. In the 2023 base case, there was a total of 496 tons pe r day (TPD) of anthropogenic VOC emissions,
114 TPD associated with CP sources. Th e 114 TPD CP VOC emissions are adjusted downwind by 5 TPD for a baseline adjustment and reduced an additional 14 TPD, 2.5
TPD and 21 TPD due to the ARB-CONS -01, CTS-03, and SCLTM-03 CP control measures, respectively. Based on the adjustment factors specified for each of the control measures, the CEPA program generates the cont rol factor inputs, which are then used by GEM emission model to prepare future year emissions inputs for CAMx.

Table 1 displays the projected 8-hour ozone Design Values in 2023 (1) as published in the 2007 AQMP; (2) as calculated by ENVI RON using the 2002 base case and 2023 AQMP control case CAMx output files as provided by the SCAQMD; and (3) as calculated by ENVIRON using the 2002 base case CAMx outputs provided by the SCAQMD and the 2023 CAMx output genera ted by ENVIRON that represents implementation of all control measures in the 2007 AQMP except the SCLTM-03 CP control measure. The maximum projected 8-hour ozone Design Valu e anywhere in the
basin in all three scenarios occurs at the Crestline monitor, where an 83 ppb value was published in the 2007 AQMP; as this is le ss than 85 ppb, it therefore demonstrates attainment. The Crestline Design Value calculated by ENVIRON using the 2007 AQMP data provided by the SCAQMD was 84 ppb, 1 ppb higher than was published in the 2007 AQMP but still below 85 ppb, so still demons trating attainment of the 8-hour ozone
standard. The removal of the SCLTM-03 CP control measures has no effect on the

† Seeing different Design Values than those published even using the SCAQMD modeling outputs, it appears that the district has used a different methodol ogy for the two sites. It is not clear in the AQMP document, however, what the methodology is. It is also noted that there exist some inconsistencies in the document: for example, multiplying the 2002 Design Value by the published RRF does not produce the published 2023 Design Value for some sites, including Azusa and Burbank. Nevertheless, it is immaterial
since both sites are in attainment in either case.A-4 projected Design Value at Crestline so attainme nt is still demonstrated even without the
SCLTM-03 CP control measure.

CONCLUSIONS

Removal of the SCLTM-03 additional Consumer Product VOC control measure from the 2007 AQMP control plan does not affect the 2023 8-hour ozone attainment demonstration. Thus, the 2007 AQMP control plan without the SCLTM-03 measure is a
viable and more cost-effective 8-hour ozone attainment plan. This result is not surprising since the SCAQMD is pursuing a NOx-heavy emissions control strategy in the 2007 AQMP; once ozone goes over the “ridge lin e” in the VOC/NOx isopleths, further NOx control very effectively reduces ozone concen trations. One reason for the pursuit of the NOx heavy control plan is the presence of large amounts of uncontrollable biogenic VOC emissions, which explains the little sensit ivity of ozone to the CP SCLTM-03 VOC
control measure.

Table 1. Projected 2023 8-hour ozone Design Values (ppb) for the 2007 AQMP control plan (1) as published in the 2007 AQMP and (2) as calculated by ENVIRON using the CAMx output data as provided by the SCAQMD and (3) as calculated by ENVIRON removing just the SCLTM-03 CP control measures fro the 2007 AQMP control plan.

Monitoring Published (1) Calculated (2) Calculated (3)

Site 2007 2007 without
AQMP AQMP SCLTM-03

Azusa 69 61 62 Banning Airport 68 67 68

Burbank 63 68 68
Crestline 83 84 84

Elsinore 62 61 61

Fontana 81 80 81
Glendora 79 79 80

Indio Jackson 56 55 55

Pasadena 73 72 73

Perris 79 79 80 Palm Springs 59 58 58

Pomona 75 75 76

Redlands 81 81 81

Reseda 66 66 66

Rubidoux 76 76 77

Santa Clarita 74 74 75