Protecting Ecosystems from S and N Emissions – EPA’s

Perspective

Presentation for Riverside Critical Loads WorkshopBy

Richard Haeuber and Vicki SandifordOffice of Air and Radiation, EPA

February 16, 2005

• Current mechanisms under the Clean Air Act to protect ecosystems– PSD/NOX increment rule proposal– National Ambient Air Quality Standards – welfare

effects– Acid Rain Program

• Potential future emissions reduction programs– Clean Air Interstate Rule– Clear Skies Act

• Ecosystem-related accountability drivers• NAS report on air quality management – an

opportunity for creative thinking

Protecting Ecosystems – Where We’ve Been, Where We’re Headed

PSD/NOX Increment Rule

• 1988 EPA was sued on NOX Increment Rule• 1990 Court remanded case to EPA “to develop

an interpretation of sec. 166 that considers both subsections (c) and (d), and if necessary to take new evidence and modify the regulations.”

• 2003 – Environmental Defense petitioned court for EPA to take action on earlier remand

• Settlement to issue proposal Sept. 30, 2004• ED and EPA agreed to delay to Feb. 14, 2005 to

allow EPA time to consider alternatives to increment approach (including critical loads).

Secondary NAAQS

• Sec. 109 (CAA) “Any national secondary ambient air quality standard…shall specify a level of air quality the attainment and maintenance of which…is requisite to protect the public welfare from any known or anticipated adverse effects associated with the presence of such air pollutant in the ambient air.”

NAAQS: Definition of Welfare

• Sec. 302(h):

• “All language referring to effects on welfare includes but is not limited to, effects on soils, water, wildlife, weather, visibility, and climate,…, whether caused by transformation, conversion, or combination with other air pollutants.”

Current PM NAAQS Review

• 01/31/05 -PM 2nd Draft Staff Paper stated: – “Though these current activities hold promise

for using CLs approach in environmental assessments…insufficient data are available at this time to quantify the contribution of ambient PM to total reactive nitrogen or acidic deposition…”

– www.epa.gov/ttn/NAAQS

Review Process for NAAQS

Scientific studies on health and environmental effects

EPA Criteria Document – extensive assessment of scientific studies

EPA Staff Paper – interprets scientific data and identifies factors to consider in setting standards including staff recommendations for standards

Scientific peer review of published studies

Reviews by CASAC and the public

Reviews by CASAC and the public

Public hearings and comments on proposals

Proposed decision

on standards

Final decision on standards

• Acid deposition occurs when emissions of

SO2 and NOx react in the atmosphere to

create acidic gases and particles which

reach the Earth in wet and dry forms.

• The greatest sulfur and nitrogen

deposition occurs in areas of the Midwest

and northeastern United States which are

downwind of the highest SO2 and NOx

emission areas.

• Impacts occur in both the eastern U.S.

and mountainous areas of the West.

• Effects of acid deposition include:

• Acidification of lakes and streams,

making them unable to support

fish and other aquatic life;

• Damage to forests through

acidification of soil, depletion of

soil nutrients, and direct injury to

sensitive tree leaves and needles;

Acid Rain Damages Lakes, Streams, and Forests

• Despite substantial emissions reductions over the last 20 years, high levels

of sulfur and nitrogen deposition still enter acid-sensitive lakes and streams,

leading to high levels of acidity.

Wet Sulfate Deposition (2000-2002) and Acid-Sensitive Surface Waters

Nitrogen Deposition in the High Elevation West

• Under current emissions rates, nitrogen saturation is expected to get worse

• Nitrogen deposition is a significant problem in many western areas, including the Colorado Front Range, the San Gabriel Mountains,the Klamath Mountains, and the San Bernadino Mountains

• This is leading to high nitrogen levels in streams in several areas and changing the ecological structure of some alpine lakes and tundras

• Nitrogen saturation contributes to greater forest and grassland susceptibility to fire

Points on map represent only those forested areas surveyed for these purposes

Impacts to Coastal EcosystemsNote: Conditions are not necessarily related in whole to human-related eutrophication; to various degrees natural causes and other human disturbances may also play a role. For instance, some estuaries in Maine are typified by natural occurrences of toxic algae, which drift in from the open ocean. Once in the estuary, however, these blooms may be sustained by human nutrient inputs.

Source: NOAA, National Estuarine Eutrophication Assessment 1999

Estuaries with Highly Eutrophic Conditions

• 44 estuaries along all of the nation’s coasts are highly eutrophic• Estuaries in the Mid-Atlantic and Gulf of Mexico are particularly sensitive • An additional 40 estuaries (not shown) have moderate levels of eutrophic conditions

Wet Sulfate Deposition

Average 1989 - 1991

Wet Sulfate Deposition

Average 2001 – 2003

Acid Deposition Control Program (Title IV of 1990 CAAA)

• Overall program goal: Reduce ecological effects of acid rain and protect public health, visibility through large-scale regional reductions

• SO2 emissions goal: Reduce SO2 emissions from electric generators by 8.5 million tons (50% below 1980 levels)

• In 2003, SO2 emissions from all power generation were 10.6 million tons, 5.1 million tons (32%) below 1990 levels

• Eastern states have experienced significant decreases in sulfate deposition -- almost 30 percent -- since the Acid Rain Program took effect in 1995.

Monitored Reductions in Wet Sulfur Deposition in the Eastern U.S.

Wet Nitrate DepositionAverage 1989-1991

Wet Nitrate DepositionAverage 2001-2003

Acid Deposition Control Program (Title IV of 1990 CAAA)

• NOX emissions goal: lower annual NOX emissions from electric power plants to 2 million tons below the forecasted level for 2000

• In 2003, NOX emissions from all power generation were 4.2 million tons, 2.5 million tons (or 37 %) below 1990 levels

• Eastern states have experienced some decreases in nitrogen deposition• Nitrogen deposition has not significantly decreased since the Acid Rain

Program took effect in 1995

Monitored Reductions in Wet Nitrogen Deposition in the Eastern U.S.

Acid Rain Program ResultsSurface Water Response to Emissions Reductions

TIME/LTM (Surface Water Monitoring) Regional Trends in Lakes and Streams Acidity, 1990-2000

• Regional declines in surface water sulfate can be directly linked to declines in emissions and deposition of sulfur

• In three regions monitored, one-quarter to one-third of lakes and streams previously affected by acid rain are no longer acidic

• Regional Acid Neutralizing Capacity (ANC), a key indicator of recovery, did not change significantly in New England or in Blue Ridge streams

• Surface water nitrate concentrations are largely unchanged except in Adirondacks and Northern Appalachian Plateau

CAIR: The Next Big Step• Reducing interstate transport is critical to solving the problems of ozone, fine

particles, and regional haze• Emissions have declined under the Acid Rain Program and the environment is

beginning to improve, but full environmental recovery from acid deposition will not happen without additional emission reductions

• Clean Air Interstate Rule (CAIR), which is focused mainly on the electric power industry, would use cap and trade programs to further reduce emissions of SO2 and NOx in the eastern U.S.

Columns indicate projected nationwide emissions for the December 2003 CAIR proposal

* Yellow bars indicate level of caps for the CAIR region only (eastern U.S.)

Projected national SO2 emissions from power generation

Projected national NOx emissions from power generation

SO

2 E

mis

sio

ns

(m

illi

on

to

ns

)

NO

x E

mis

sio

ns

(m

illi

on

to

ns

)

3.9*2.7* 1.3*

1.6*

Projected Sulfur Deposition Changes with CAIR compared to the Base Case in 2010

Projected Sulfur Deposition Improvements in 2010 and 2015 under CAIR

Projected Sulfur Deposition Changes with CAIR compared to the Base Case in 2015

• Estimates for 2015 show even more reductions in the 60% range in the east.

• By 2010, CAIR would significantly reduce sulfur deposition in some areas by over 60% beyond levels expected without the implementation of the rule

Legend

100thParallel

Percent Reduction

-1 - 0

1 - 3

4 - 6

7 - 9

10 - 12

13 - 15

16 - 18

19 - 21

22 - 24

25 - 27

28 - 30

31 - 33

34 - 36

37 - 39

40 - 42

43 - 45

46 - 48

49 - 51

52 - 54

55 - 57

58 - 60

61 - 63

64 - 66

Note: this modeling represents the CAIR proposal, not the final regulation

Projected Nitrogen Deposition Changes with CAIR compared to the Base Case in 2010

Projected Nitrogen Deposition Improvements in 2010 and 2015 under CAIR

Projected Nitrogen Deposition Changes with CAIR compared to the Base Case in 2015

• Estimates for 2015 show even more reductions in the eastern U.S., with reductions reaching as much as 31% in some areas of Florida.

• By 2010, CAIR would significantly reduce nitrogen deposition by up to 21% beyond levels expected without the implementation of the rule.

Legend

100thParallel

Percent Reduction

-4 to 0

0

1 - 2

3 - 4

5 - 6

7 - 8

9 - 10

11 - 12

13 - 14

15 - 16

17 - 18

19 - 20

21 - 22

23 - 24

25 - 26

27 - 28

29 - 30

31 - 32

Note: this modeling represents the CAIR proposal, not the final regulation

The Clear Skies Act 2003 – SO2 and NOX Emissions Caps and Timing for the Electric Power Sector

2004

2008

2012

2016

2020

2004: The NOx SIP call (summertime NOx cap in 19 Eastern States + D.C.)

2008: Clear Skies NOx Phase I (2.1 million ton annual cap assigned to two Zones with trading programs)

2010: Clear Skies SO2 Phase I (4.5 million ton annual cap with a national trading program)

2018: Clear Skies NOx Phase II (1.7 million ton annual cap assigned to two Zones with trading programs)

2018: Clear Skies SO2 Phase II (3.0 million ton annual cap with a national trading program)

Sulfur Deposition Improvements in 2020 under Clear Skies Act 2003

• The top map demonstrates the effect of existing programs (Base Case) in comparison to current deposition levels.

• The bottom map demonstrates the effects of Clear Skies in combination with the Base Case in comparison to current deposition levels.

• Clear Skies, in combination with the Base Case, would reduce sulfur deposition up to 60% from current levels throughout much of the Eastern U.S.

• Sulfur deposition in the West is generally low, so the large percentage increases correspond to relatively small changes in actual deposition (less than 1 kg/ha). These increases come from expected increases in emissions primarily from sources not affected by Clear Skies (e.g., metals processing, petroleum refining, chemical and fertilizer manufacturing). A few power plants are expected to increase emissions slightly under existing programs.

Projected Changes in Sulfur Deposition with the Base Case in 2020 Compared to 2001

Projected Changes in Sulfur Deposition with Clear Skies and the Base Case in 2020

Compared to 2001

Note: Alaska and Hawaii are not included in the model domain

Note: Alaska and Hawaii are not included in the model domain

Source: 2003 EPA Analysis of the Clear Skies Act. Projections based on latest data available at time of analysis.

Nitrogen Deposition Improvements in 2020 under Clear Skies Act 2003

• The top map demonstrates the effect of existing programs (Base Case) in comparison to current deposition levels.

• The bottom map demonstrates the effect of Clear Skies in combination with the Base Case in comparison to current deposition levels.

• Clear Skies and the Base Case together would reduce nitrogen deposition across much of the country up to 35%, with larger reductions of up to 50% across most of the East and large areas of the West.

Note: The increases in nitrogen deposition in Louisiana and Washington state occur under both the Base Case and Clear Skies and are the result of increases in emissions from manufacturing and refining sources.

Projected Changes in Nitrogen Deposition with Clear Skies and the Base Case in 2020

Compared to 2001

Projected Changes in Nitrogen Deposition with the Base Case in 2020 Compared to 2001

• The projected large reductions in nitrogen deposition on the West coast are due to existing programs not yet fully implemented, such as the Tier II and Diesel Rules.

• In the West, Clear Skies would prevent further deterioration of air quality, including visibility.

• Clear Skies would allow growth to occur in the West without increasing NOx emissions.

Note: Alaska and Hawaii are not included in the model domain

Note: Alaska and Hawaii are not included in the model domain

Source: 2003 EPA Analysis of the Clear Skies Act. Projections based on latest data available at time of analysis.

Tracking Progress - “Accountability” Drivers

• Reporting requirements under Clean Air Act -- NAPAP Report to Congress

• Performance Measures- GPRA (Government Performance and Results Act)- PART (Program Assessment Rating Tool)

• Self-imposed reporting requirements (e.g., Acid Rain Program Progress Report, NOx Budget Program Progress Report, etc.)

• EPA State of the Environment Report

• A new driver: National Academy of Sciences 2004 Report Recommendations on Air Quality Management

NAS Report on Air Quality Management

• January 2004 -- NAS Committee on Air Quality Management in United States releases report

• Comprehensive assessment of effectiveness of US air quality management system

• Core conclusions:– Over past 30 years, Clean Air Act has substantially reduced

pollution emissions– Despite progress, Committee identified scientific and technical

limitations that will hinder future progress• Report intended as blueprint to address limitations,

enhance air quality management, and chart path toward more productive and efficient system

• Viewed as opportunity for EPA and to “step outside the box” to achieve better environmental results

• NAS made 5 core recommendations to be implemented through specific actions:– Strengthen scientific and technical capacity to assess risk

and track progress– Expand national and multi-state control strategies– Transform the SIP process into dynamic and collaborative

multi-pollutant air quality management plan– Develop integrated program for criteria pollutant and

hazardous air pollutants– Enhance protection of ecosystems and public welfare through

better monitoring and tracking of ecosystem effects and improving the science to support secondary or alternative standards

NAS Report on Air Quality Management

• NAS Committee recommended that EPA convene implementation task force

• Clean Air Act Advisory Committee (CAAAC) reviewed report and developed plan to prioritize and focus NAS recommendations

• CAAAC review structure– Air Quality Management Work Group– Science and Technology Work Group– Policy and Planning Work Group

• CAAAC developed 38 separate recommendations based on the NAS Report

Steps to Implement NAS Recommendations-- Clean Air Act Advisory Committee Review

Input to Developing CAAAC Recommendations Ecosystem Focus Group

• Ad hoc Ecosystem Focus Group formed to provide input to recommendations of Science and Technology workgroup

• Prioritized efforts to advance ecosystem protection and improve understanding of air-ecosystem impacts near term, given current state of science and assessment tools

• Ecosystem Focus Group members– Paul Stacey, Connecticut Department of Environmental Protection (co-

lead)– Rona Birnbaum, EPA/OAR (co-lead)– John Aber, University of New Hampshire– Jill Baron, Colorado State University/USGS– Charlie Driscoll, Syracuse University– Jim Galloway, University of Virginia – Bill Hogsett from EPA/ORD, NHEERL in Corvallis– David Karnosky, Michigan Tech – Hans Paerl, University of North Carolina

• 1.5 Framework for accountability• Develop benchmarks/measures to assess

ecological impacts of air pollution and improve ability to track/evaluate progress– Improve tracking/assessing ecosystem effects of

multiple pollutants– Conduct/facilitate integrated assessments & research

to develop/implement measurements to detect ecosystem response

– Facilitate/pursue collaboration on integrated assessments

– Examine possibility of using critical loads & thresholds

CAAAC Ecosystem-Related Recommendations

• 5.1 Program review to improve ecosystem protection• Examine current & alternative policies and programs to develop

approaches advancing ecosystem protection from air pollution impacts

• Policy/program assessment features:– Policy mandates, objectives, goals, definitions of ecosystem protection,

& historic/legal interpretation– Characteristics of air pollutant regulated, and potential magnitudes of

impact– Existing measures for reporting program progress and ecosystem

impacts– Desirable modifications to existing tracking efforts to support application

to different regulatory programs– Current & future opportunities/impediments to expanding the use of

ecological science in the policy context– Policy innovations or revisions that would help translate ecosystem

science into effective ecosystem protection policies

CAAAC Ecosystem-Related Recommendations