2008 PM2.5 Plan 

## Chapter 2

Meeting Federal Requirements for Healthy Air2008 PM2.5 Plan This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air

2008 PM2.5 Plan 2-1 

## Chapter 2: Meeting Federal Requirements for Healthy Air

2.1 INTRODUCTION

Pursuant to the federal Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) sets primary air qual ity standards to protect public health and secondary standards to protect welfare. Achieving t he primary federal standards protects public health, reduces the region’s health care cost s, and improves the quality of life for Valley residents. This chapter describes PM2.5 health effects, EPA’s process for setting health-based standards, and how regions like the San Joaquin Valley work towards attaining those standards.

2.2 HEALTH EFFECTS

Any particles 10 microns or less are cons idered respirable. The potential health impacts of particle pollution is linked to t he size of the particles, with the smaller particles having larger impacts. PM10 (which includes PM2.5) can reach the alveoli, the gas exchange zone deep in the lungs. PM2.5 is of special concern to health because it is easily inhaled deep into the lungs, where it can be absorbed into the bloodstream or remain embedded for long periods of time without the ability to be exhaled (ALA 2002). PM can result in airway inflammation, and fi ner particles may carry toxic and biological materials, which can be absorbed by the blood in the gas exchange tissues of the lungs and carried to other parts of the body.

Numerous studies link PM to a variety of health effects, includ ing aggravated asthma, increased respiratory symptoms (irritation of the airways, coughing, difficulty breathing), decreased lung function in children, develop ment of chronic bronchitis, irregular heartbeat, nonfatal heart attacks, incr eased respiratory and cardiovascular hospitalizations, lung cancer, and premature death in people with heart or lung disease. Children, older adults, and indivi duals with heart or lung diseas es are the most likely to be affected by PM. As discussed in Chapter 1, PM2.5 occurs as a variety of chemical compounds, and there are severa l possible precursors. The species of PM2.5 can be a factor in the type and severi ty of health impacts.

The health impacts carry economic costs as well. In The Health and Related Economic Benefits of Attaining Healthfu l Air in the San Joaquin Valley , researchers Jane V. Hall, Victor Brajer, and Frederick Lurmann report t hat the economic benef its of meeting the

federal standards for both PM 2.5 and ozone (as compared to 2004 air quality) could save an average of nearly $1,000 per person per year Valley-wide for a total of more than $3 billion annually (2005 dolla rs). They report that a ttaining both standards may result in fewer premature deaths, fewer asthma attacks, fewer cases of bronchitis, fewerSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air

2008 PM2.5 Plan 2-2 hospital admissions, fewer lost productive work days, and fewer school absences.

These effects are attributed to attaini ng both the PM2.5 and oz one standards, although many of the potential health impacts in Hall’s study may be linked to diesel particulates (a component of PM2.5). The Hall report shows (in Table V-2) the total cost of health impacts from only PM2.5 to be approximat ely $3.2 billion annually, almost 100 times higher than the cost of ozone hea lth effects (Hall 2006). Hall’s study is the first of its kind for the San Joaquin Valley. Future studies will improve our understanding of air pollution effects and costs and affirm the import ance of programs that bring the Valley

into attainment of feder al air quality standards.

Health Effects of PM2.5

 Aggravated asthma

 Increased respiratory symptoms – irritati on of the airways, coughing, difficulty breathing

 Decreased lung function in children

 Development of chronic bronchitis

 Irregular heartbeat

 Nonfatal heart attacks

 Increased respiratory and card iovascular hospitalizations

 Lung cancer

 Premature death in people wi th heart or lung disease

Source: EPA, Particulate Matte r: Health a nd Environment, www.epa.gov/air/particlepollution/health.html ARB and ALA, Recent Research: Health Effects of Particulate Matter and Ozone Air Pollution, January 2004, http://www.arb.ca.gov/resea rch/health/fs/PM-03fs.pdf

As the Valley’s PM2.5 air quality improves , the health impacts will diminish. To communicate the variability of air pollution levels and potent ial health impacts, air quality agencies provide air quality forecasts and repor t a daily Air Quality Index (AQI), as specified by EPA. AQI levels and their corresponding colors communicate specific health advisories. Many Valley media out lets include the District’s AQI with their weather forecasts. Also, many schools th roughout the Valley participate in the Air Quality Flag program sponsored by asthma coalitions, the Dis trict, and other local organizations. Through this program, multi-co lored flags are flown each day to indicate the forecasted air quality. As of the end of the 2006-2007 school year, 184 schools throughout the Valley participated in this program. Over 40 schools in the southern portion of the Valley participate in a si milar program operated by the Kern County

Asthma Coalition.

When conditions warrant, the District also i ssues health advisories. This information and the daily AQI are available on the District’s website at www.valleyair.org/aqinfo/forecast.htm . The daily AQI, available for each of the 8 Valley counties, is also available in both English and Spanish on the District’s toll free number,

1-800-SMOG-INFO.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air

2008 PM2.5 Plan 2-3 Figure 2-1 AQI Values and Corresponding Air Quality, Colors, and Health

Advisories

Air Quality Index (AQI) Values Air Quality Colors Health Advisory

When the AQI is in this range: ...air quality

conditions are: ...as symbolized by this color: ... the health advisory is:

0 to 50 Good Green None.

51 to 100 Moderate Yellow Unusually sensitive people should consider reducing prolonged or heavy exertion.

101 to 150 Unhealthy for
Sensitive Groups Orange People with heart or lung disease, older adults, and children should reduce prolonged or heavy

exertion.

151 to 200 Unhealthy Red People with heart or lung disease, older adults, and children should avoid prolonged or heavy exertion. Everyone else should reduce prolonged or heavy exertion.

201 to 300 Very Unhealthy Purple People with heart or lung disease, older adults, and children should avoid all physical activity outdoors. Everyone else avoid prolonged or heavy exertion.

2.2.1 Other Ef fects of PM2.5

In addition to affecting health , air pollution also affects public welfare. PM can be transported long distances to create regional haze, with PM2.5 fr om sources hundreds of miles away contributing to visibility problem s at remote locations, such as the Sierra Nevada Mountain Range or national parks. As PM settles out of the air, it can make lakes and streams acidic, change an ecosyst em’s nutrient balance, and affect ecosystem diversity. PM can affect vegetation by dam aging foliage, disrupting the chemical processes within plants, r educing light adsorption, and disrupting photosynthesis. This can impact green spaces as well as crops. PM can also stain and damage stone and other materials. As the Va lley progresses towards attainment of EPA’s health-based standards, there will also be less impact to public welfare.

2.3 HEALTH-BASED STANDARDS

Since the federal PM10 standards were estab lished in 1987, a lar ge number of studies have been published on PM health effects, su ch as premature mortality, hospitalSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air

2008 PM2.5 Plan 2-4 admissions, and respiratory illnesses. Based on health studies, PM2.5 is considered to be more adverse to human health than any other pollutant. Based on human health and environmental considerations, the St ate and the federal government each set ambient air quality standards for PM2.5. An air qualit y standard includes pollution concentration levels, guidelines for calculat ing the attainment te sts for designation and classification, and other requirements. This section outlines the ty pes of standards, the

current levels of the standards , and how the standards are set.

2.3.1 State Standards

California standards are set to protect public health. The California ambient air quality standards are considerably mo re stringent than the federal standards and are more protective of human health. California has no specific dates by which state air quality standards must be attained. State implementa tion plans (SIPs), such as this PM2.5 plan, focus on federal standards . California Health and Sa fety Code (CH&SC) Section 39602 says, “Notwithstanding any other prov ision of this division, the state implementation plan shall on ly include those provisions necessary to meet the requirements of the [federal] Clean Air Ac t.” As such, SIPs are limited to those measures necessary to attain the federal standards. However, progress towards federal standards also brings areas closer to the lower, State standards. ARB set the

first state standard for PM2.5 in 2002. The leve l of this standard is shown in Table 2-1.

2.3.2 Federal Standards

The EPA’s “primary standards” are set to prot ect public health with a margin of safety. Federal “secondary standards” are established to protect public welfare in issues such as crop damage, material degradation, haze, and environmental effects. The primary and secondary standards for PM 2.5 are equivalent.

When EPA reviews the national ambient air quality standards (NAAQS) for a pollutant such as PM2.5, it develops a "criteria document," a compilation and scientific

assessment of health and environmental effect s studies. EPA develops a staff paper on the information available that is compiled by technical staff who interpret the most

relevant information in the criteria document to be used in making policy decisions. The staff paper also contains st aff recommendations to the EPA Administrator regarding any

revisions to the standards needed to protect public health and welfare.

Both the criteria document and staff paper are based on thousands of peer-reviewed scientific studies and are par t of an extensive scientific assessment process that includes rigorous scientific peer review and public comment. Before these documents become the basis for policy decisions, they undergo repeated, detailed reviews by the scientific community, industry, public intere st groups, the general public, and the Clean Air Scientific Advisory Committee, a Congressionally mandat ed group of independent scientific and technical experts. 1 As part of its mandate, the Clean Air Scientific

1 EPA’s December 7, 2006 changes to the NAAQS review process modified the role of CASAC in the standard-setting process.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air

2008 PM2.5 Plan 2-5 Advisory Committee also makes recomm endations to EPA on the adequacy of the standards. By reaching the federal health-b ased standards for PM2.5, we will greatly reduce the negative health impacts of this pollutant.

EPA adopted the first national ai r quality standards for the fine fraction of particulates, PM2.5, in July 1997 (62 FR 38651-38701). EPA set the annual PM2.5 standard at 15 μg/m 3 and the 24-hour PM2.5 standard set at 65 μg/m 3 . EPA designated the Valley as

nonattainment for PM2.5 based on ambient ai r quality data collected from 2001-2003. The Valley’s 2004-2006 air quality is wit hin the 1997 24-hour standard, but not the

annual standard. The District must show how the Valley will attain the 1997 PM2.5

standards in the 2008 PM2.5 Plan

.

On October 17, 2006, EPA issued its final rule to revise the PM10 and PM2.5 NAAQS in the Federal Register (71 FR 61143-61233). This rule revoked the annual PM10 standard and retained the existing 24-hour PM10 standard of 150 μg/m 3 . EPA also retained the existing annual PM2.5 standard of 15 μg/m 3 , but lowered the 24-hour PM2.5 standard to 35 μg/m 3 . EPA will designate areas under the new standard by November 2009, effective April 2010, and state implementation plans for the 2006

standards will be due to EPA in the 2012-2013 time frame. Areas must attain the 2006 standards within five years of the effectiv e date of EPA designations (which should be finalized effective 2009-2010), though up to a five year extension is possible. Although the plan focused on the 2006 PM2.5 standar ds is not due to EPA until 2012-2013, the

control measures in the 2008 PM2.5 Plan will help bring the Vall ey closer to the 2006 standard, and feasibility measures in the plan may result in control measures that might

be used in future PM2.5 Plans.

Both the 1997 and 2006 PM2.5 NAAQ S are shown in Table 2-1.

Table 2-1 Federal and State Ambien t Air Quality Standards for PM2.5

Standard Level of the Standard

24-hour 65 μ g/m 3 Federal (1997) Annual 15 μ g/m 3

24-hour 35 μ g/m 3 Federal (2006) Annual 15 μ g/m 3

24-hour NA California Annual 12 μ g/m 3

2.4 DESIGNATIONS AND REQUIREMENTS

On January 5, 2005 (70 FR 943-1019), EPA promulgated air quality designations for all areas for the national ambient air quality st andards (NAAQS) for fine particles, signedSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air

2008 PM2.5 Plan 2-6 on December 14, 2004 and effective April 5, 2005. The San Joaquin Valley Air Basin is designated nonattainment for the 1997 PM2.5 NAAQS, and the PM2.5 State Implementation Plan (SIP) is due to EPA by April 5, 2008.

Unlike the 8-hour ozone and PM10 standards , the PM2.5 NAAQS does not use a

nonattainment area classification system (i.e., moderate, seri ous, severe, and extreme). While CAA Subpart 1, Secti on 172(a)(1) allows for a classification system, a classification system is not required. No t using a nonattainment classification system simplifies the attainment year as well as other planning requirements. The 1990 CAA Amendments do not include any subpart for PM 2.5 because the PM2.5 standards were not yet established at that ti me. Therefore, the nonattainme nt area plan provisions in CAA Section 172 of subpart 1 apply. C AA 172(c) requires RACT, RACM, RFP, contingency measures, emission inventor y, and NSR, and thes e requirements are

discussed in further detail in the Clean Air Fine Particle Impl ementation Rule, Final Rule (72 FR 20586-20667). Consistent with CAA Sect ion 172(b), SIPs are due within 3 years of area designations, so SIPs for the 1997 PM2.5 standards are due by April 5, 2008 (72 FR 20599). Federal CAA requirements fo r PM2.5 plans are summarized in

Table 2-2.

All areas are to attain the standard as expedit iously as practicable, but by an initial attainment deadline of Apr il 5, 2010 (based on 2007, 2008, and 2009 data, making 2009 the compliance year). Areas demonstrating that attainment is impracticable by 2009 can receive an extension of up to five years, making the final attainment deadline April 5, 2015 (based on 2012, 2013, and 2014 data, wit h 2014 as the compliance year). To be granted an extension, areas must:

 Submit an attainment demonstration s howing that attainment by 2009 is impracticable due to the severity of the nonattainment pr oblem, the lack of available control measures, and any other pertinent information.

 Show that the area will attain the st andard by an alternative date that is as expeditious as practicable. A full ex tension to 2015 is not automatic, and some areas may obtain shorter extensions.

 Must demonstrate that all local contro l measures that are reasonably available and technically feasible for the ar ea are currently being implemented.

 Show that implementation of all RACM and RACT local control measures for the area were considered (72 FR 20601).

Once the federal government sets a standard, states and air districts with nonattainment areas are required to adopt plans, rules, an d programs that reduce emissions to bring

the area into attainment of t he standard. In California, ai r pollution control districts and/or air quality management districts are responsible for developing the overall attainment strategy in their respecti ve geographic areas. Plans, such as the 2008

PM2.5 Plan , are the first step in the local proce ss. To develop a plan, areas evaluate air quality data, emissions inventory data, an d computer modeling results to determine the rules and programs that ar e needed to reach the federal standards by the deadlines specified in the CAA. The rules and programs in a plan are then implemented over timeSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air

2008 PM2.5 Plan 2-7 to reduce the emissions that go into the air, reducing unhealthful c oncentrations of air pollutants and helping areas reac h federal air quality standards.

The state reviews all of the air quality plans for the stat e’s nonattainment areas and, if they meet federal r equirements, approves them and sends them on to EPA for approval into the California SIP. During the regional planning process, ARB develops and applies air quality models, conducts and funds air quality research, develops emissions inventories, develops emission control m easures for statewi de applicability, and provides other assistance to local air districts.

Periodic plan revisions may be necessary to ensure reasonable further progress and to

reflect the latest science. Once an area’ s ambient air quality dat a meets the federal standard, the area will request a finding of at tainment. Then a maintenance plan and other requirements must be met before an area can be officially redesignated to

attainment.

References

American Lung Association (ALA) (2002). ALA Fact Sheet Particulate Matter Air Pollution

. <www.lungusa.org/air/pm_factsheet99.html>.

Hall, Jane V; Brajer, Victor; and Lurmann, Frederick W. (March 2006). “The Health and Related Economic Benefits of Attaining Healthful Air in the San Joa quin Valley.” Institute for Economic and Environmental
Studies.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air

2008 PM2.5 Plan 2-8 Table 2-2 Federal Requirements for PM2.5 Nonattainment Areas

General Requirements Federal
CAA PM2.5 Implementation

Rule Description 2008

PM2.5

Plan

Attainment

Demonstration

Due Date 172(b) 72 FR 20599 PM2.5 SIPs are due to EPA by April 5, 2008, which is three years from the designation date. NA

Attainment

Date 172(b)(2) 72 FR 20601 Nonattainment areas should reach attainment as expeditiously as practicable, but no later than 5 years from the designation date, except that the Administrator may extend the attainment date for a period of no greater than 10 years from the designation date, considering the severity of nonattainment and the availability and feasibility of control

measures. Chapter 9

RACT/RACM 172(c)(1) 72 FR 20609-

20633 SIP provisions should provide for the implementation of reasonably available control measures (RACM), including, at minimum, reasonably available control technologies (RACT). Chapter 6, Chapter 7

RFP 172(c)(2) 72 FR 20633-

20642 SIP provisions must provide for reasonable further progress. Chapter 8

Contingency

Provisions 172(c)(1) 72 FR 20642-

20645 The SIP must provide for the implementation of specific measures

that would take effect without further action by the State and that would be

undertaken if the area fails to make

RFP or attainment on time. Chapter 9

Emissions Inventory 172(c)(3) 72 FR 20647-

20651 The SIP must include a comprehensive, accurate, current inventory of actual emissions from all sources of the relevant pollutants in the

area. Appendix

B

NSR 172(c)(4- 5) 72 FR The SIP must identify and quantify the emissions of pollutants that will be allowed (in accordance with section 173(a)(1)(B), from t he construction and operation of major new or modified stationary sources in the area. The SIP must require permits for new or modified stationary sources. Appendix

D

Other

measures 172(c)(6) 72 FR 20599 The SIP must include enforceable

emission limitations and other such control measures and techniques, including schedules for compliance to provide for attainment by the applicable

attainment date. Chapter 6