by Roger Caiazza
At this time there is quite a bit of noise about potential problems if Scott Pruitt is confirmed to head EPA because he would “hamstring EPA’s authority to set nationwide environmental standards”.
As I understand it he is proposing to cooperate more with the states. This post describes a particular example where states proposed an alternative approach but EPA has not used the suggestion. In a recent action EPA continues to ignore the alternative proposed. I hope to show why I think that is a mistake. If Pruitt can get EPA to respond to this type of state action I support his nomination.
In my opinion one of the bigger air quality issues is ozone attainment, particularly as it relates to interstate transport. EPA explains that “air transport refers to pollution from upwind emission sources that impact air quality in a given location downwind”. Emissions of nitrogen oxides (NOX) and Volatile Organic Compounds (VOC) can each undergo chemical reactions in the atmosphere to create ground-level ozone (smog) pollution.
The EPA website for interstate air pollution explains the “Good Neighbor” provision that requires EPA and states to address interstate transport of air pollution that affects downwind states’ ability to attain and maintain ambient standards. One of the reasons that ozone attainment has proved to be particularly difficult to attain is that the standard was recently tightened. In this example, I want to address the recent EPA Notice of Data Availability for the preliminary interstate ozone modeling data for this new limit.
EPA notes that they have completed preliminary interstate ozone transport modeling relevant for the 2015 ozone national ambient air quality standard. We are currently in the public comment period where the Agency is providing an opportunity for public review of this modeling data, including projected ozone concentrations and contributions for 2023, as well as projected emissions, including emissions from the power sector, that were used for this modeling.
In EPA’s approach the modeling projects ozone concentrations in 2023 at individual monitoring locations to determine the state-by-state contribution. EPA used a 2011-based air quality modeling platform which includes emissions, meteorology and other inputs for 2011 as the base year for the modeling and then projected the 2011 base year emissions to the 2023 base case scenario. The modeling domain covers the entire United States with a grid resolution of 12 km. I refer you to the technical support document for details of this modeling analysis.
I think that there are two glaring problems with EPA’s approach: one related to the emissions and one related to the air quality modeling. Both are related to the fact that the current ozone problem is episodic. Peak ozone concentrations only occur during several day summertime hot and humid periods which also are periods of peak electrical demand.
EPA’s emissions approach goes to great lengths to project future year emissions at the expense of actual observed emissions. EPA uses the Integrated Planning Model, a massive proprietary planning model to project the emissions in future years. Because emissions are dependent upon fuel prices, technology, regulations, and energy use trying to estimate future emissions is a very complex undertaking and can only annual or seasonal average estimates. However, the primary concern are the peak periods and this model does not project these extreme periods well.
In order to address that problem. the Eastern Regional Technical Advisory Committee was formed to prepare an alternative to the EPA emissions modeling approach. Basically the states and industry collaborated to develop an alternative based on adjustments to observed emission and operating rates. The result was Eastern Regional Technical Advisory Committee Electricity Generating Unit Emission Projection Tool. Importantly, this approach more accurately represents the actual and future emissions during ozone episodes than the EPA approach. Unfortunately, this alternative approach was not used by EPA for this modeling.
Although EPA’s air quality modeling analysis is an impressive effort, it also falls short of what I think is needed. As noted previously, EPA’s ozone projection methodology covers the entire United States on a 12 km by 12 km grid. My primary interest is New York State and the largest interstate impact of New York sources is downwind of New York City in Connecticut. I am convinced that the complex meteorological conditions during ozone episodes in this situation (land and sea breezes, elevated terrain concerns, and the nocturnal boundary layer structure along the coast) cannot be represented well enough to be accurate using such a coarse grid. Moreover, using that grid means that the many of the emissions are incorporated into the modeling at the same coarse grid resolution and there are indications that leads to inaccuracies.
There is another problem with EPA’s modeling. They used a base year of 2011. As part of comments I developed to address the previous round of EPA interstate modeling, I compared daily New York electric generating unit emissions and observed ozone levels on an annual basis by running a regression to determine if there was a relationship. Not surprisingly there always was a statistically significant relationship. However what was interesting is that that strength of the relationship has changed recently. Prior to 2014 the regression analysis always indicated that there was a relatively strong relationship but in the last three years the relationship has deteriorated substantially. In order to accurately determine what is causing high ozone today, a base year in the last three years is needed when this different regime of the relationship occurred.
I believe that in order to solve the interstate ozone transport problem, it is first necessary to understand what is going on. EPA’s preliminary modeling described in their December 2016 Notice of Data Availability will not provide the necessary level of detail to describe the current situation. The Eastern Regional Technical Advisory Committee emissions modeling approach addresses one aspect that needs to be corrected. If Scott Pruitt’s approach to administering EPA would facilitate EPA using this alternative, then I believe his nomination should be supported.
Biosketch: Roger Caizza blogs at Pragmatic Environmentalist of New York (very interesting blog, I’ve added it to my blog roll).
Moderation note: As with all guest posts, please keep your comments civil and relevant.
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Go Pruitt! Dismantle the EPA and start over.
The idea is to change EPA culture, not to dismantle it. Remember it’s very unlikely Trumpism can overcome congressional resistance, and given their incompetence it’s doubtful Trump will be reelected.
EPA is part of the executive. Trump is the Chief Executive. He can do whatever he wants to the EPA. He can disband it tomorrow and bulldoze its headquarters.
If Trump tried to bulldoze federal property the courts would probably stop him. I believe his wife would also have him committed in a mental hospital, where he would receive therapy until he’s cured.
An article in today’s Washington Post discusses Trump’s former EPA transition team leader’s desire to see a two-thirds cut in EPA employees. That seems to fall in the dismantle category.
http://www.washingtonpost.com/news/powerpost/wp/2017/01/30/trump-transition-leaders-goal-is-two-thirds-cut-in-epa-employees
This post is not about the stratospheric ozone hole (the good ozone). It is about urban ozone (the bad ozone).
The EPA’s current standard being O3 levels up to 0.070 ppm are safe?
It is not a question of what level is safe. Humans cannot stop higher levels than that, which occur naturally, especially in the eastern US, with vast forests upwind of huge cities. Punishing people for failing to attain the impossible is bad policy.
As usual the EPA has a broken, non-validated model of insufficient resolution to provide a meaningful projection on which to base policy. But that is not a problem since they already “know” what that policy should be.
The model is just a multimillion dollar fig-leaf to justify what they want to do anyway.
Hopefully, Pruitt will get approved and sweep a lot of the zealots out of this suffocating bureaucracy.
Talking about the ozone holes, can someone please explain to a very simple soul, how rays from the sun of whatever wavelength manage to drop down through a hole at the pole when the earth’s axis is at right angles to their path?
If they can do they then bounce around within the atmosphere until finally filtering through it to escape back into space?
Once again, this post is not about the stratospheric ozone hole (the good ozone). It is about urban ozone (the bad ozone).
The ozone hole scam is another good topic.
The R12 patent ran out and the price had dropped too far.
They needed and new patented product that they could sell for much more. They repeat this banning products process.
… and they now want to ban the HFCs which replaced the CFCs. It’s never ending cycle of administratively driven obsolescence.
Given that attainment of the new standard is impossible, the modeling used is somewhat irrelevant. Also, last I knew the modeling showed that NOx reductions actually increased the ozone levels in core urban areas. Have they managed to hide that? Attainment should be attainable. Maybe Pruitt can address that.
Roger, what difference does the better modeling make, such that we should want it done? This is not addressed in your interesting post.
I honestly believe that at this time we don’t know enough about what is causing the observed exceedances that we can come up with the appropriate control plan. Therefore, modeling the causes with better modeling is mandatory. The control emphasis has always been on electrical generating units but it is not clear whether this will have any measurable effect at this time. Unfortunately, the more likely source of the problem is mobile sources and trying to control them is politically unpalatable compared to electrical generators that everyone dislikes anyway.
Unfortunately, the more likely source of the problem is mobile sources and trying to control them is politically unpalatable compared to electrical generators that everyone dislikes anyway.
And the way things are moving now the “solution” to mobile sources is to electrify them which will require more … electrical generators.
The pressure to move to electrical transport is aimed at removing our ability for individual freedom of movement. Nothing else.
The greenies have no idea why electric cars are supposed to be “green” and simply have not asked where the massive increase in energy is going to come from.
Electric ( or rather electronic ) vehicles will all be net aware and can be shut down of taken control of centrally should the need arise.
The “old” machines which allow you to go where ever and whenever you want with a can of gasoline will be declared illegal.
this is about population control, not “saving the planet”.
climategrog is correct. We are moving towards a society where the government is inserted in every aspect of our lives and controls what we can do and where we can go on a very fine scale.
Agreed, except that I do not think there is a control plan that will bring attainment. Certainly not just via power generators without hammering the mobile sources too.
Years ago I talked to a modeling expert and asked what he thought would work. He said that compressed natural gas might be the best option because it eliminated the VOCs from mobile sources. Of course converting the entire fleet to CNG is not a viable alternative politically.
Politics aside, forced conversion to CNG also could not pass a cost-benefit test, making it a bad policy.
I do not disagree.
CNG is pathetic as a fuel for vehicles – low energy density, requires huge pressures to carry reasonable amounts, requires significant recalibration of engine electronics etc.
Propane (even mixed with 30% butane – known as “LPG”, or Liquified Petroleum Gas) is much better – you can flick between LPG normal “gas” at the flick of a switch, and done properly there is no reduction in power output or range. You can do this even in a points-and-carby engine. Significant infrastructure is already in place too.
Anyone concerned with safety should examine the facts – truth is, an LPG tank is likely to be the most UNdamaged part as the result of a vehicle fire, and the only significant risk is a BLEVE, which is very much a greater risk with CNG.
Propane would probably have the same effect on ozone
How about piping in fresh air to cities?
Is it possible to filter out the pollutant? Similar to catalytic converters in vehicles.
Near ground, individual ozone molecules have very short half lives, because the molecule is unstable. (Which is why it is only abundant in the stratosphere.) On stagnant hot days it is continuously created by NOx reacting with VOCs. Catalytic converters are removing these precursors, not ozone.
So , that as a yes, then.
Again, everything focuses on the coastal elite issues and yet, ozone transport does impact the fly-over states.
Muskegon Michigan is a case in point. Muskegon is an illogical non attainment site, located as it is on the Western Shores of Lake Michigan, an unobstructed view of open water, miles of sand beaches and an amazing sunset, each night. How can this idilic site regularly fail EPA’s inspection? Why the NOx from Chicago a hundred miles, Westward, and upwind of course.
The impact of Muskegon’s non-attainment should be observed in the health of the Muskegonits respiratory health. For the EPA to be bothered to call out this city, and, if one uses the latest 70 ppm EPA’s threshold for damage, well folks, one has to look far and wide, and even a bit wider to observe some respiratory impact. Damage is confounded of course by cigarette smoking and the use of wood burning stoves for heat. When everything is gathered into the stew, Chicago’s emissions are hardly, if ever noticed.
The EPA’s ratcheting down of atmospheric ozone concentration levels has no value except in another existential threat that EPA seems to want to control, through the regulatory process. There is of course science to suggest that episodic lack of EPA regulatory attainment has consequences, but for the life of me, I can’t find the science except by innuendo via press releases, by….EPA, which doesn’t do its own science anyways.
Hmmm. Stating facts when there are none, is…FAKE News which we have seen a lot of not only recently, but in the EPA formation of rules process. Surprise!
I apologize for the coastal elite issue. My background is New York State so I am well versed in the particular NYS issues but because I am from upstate New York I can also sympathize with the Muskegon issue. Perch River on the eastern end of Lake Ontario has the same problem only the upwind city is not only out of the state it is out of the country – Buffalo has an impact but Toronto has got to be a bigger cause of any ozone spikes they get.
I agree with your point about racheting effect. What is the end game? Do EPA and the advocates really want to shut down everything, because that is what they would have to do, to meet their lower limits? If you want to meet the limits tell people they cannot drive their cars when an episode is occurring. That is not going to go over at all.
well that is the obvious aim of imposing draconian “pollution” limits based on non validated model output.
Initial efforts in the 70 and 80s where highly beneficial in cleaning up and controlling industrial pollution. Sadly the power has gone to their heads and they now have to justify their continued existence by creating ever more and stricter controls.
They have also been infiltrated by ecological zealots who want to totally shut down industrialised society.
Does atmospheric modeling use different grid sizes based on physical needs? This is done in other fields. For example, coastal areas could be modeled at higher resolution.
Yes they do use different grid sizes and that could be used to model the coast at a greater resolution. The issue is that in this case EPA’s compliance modeling only uses the relatively 12 km grid spacing.
Took me quite a while to brush up on ground level ozone ‘pollution’ issue. See the issues differently than the post. Two thoughts. First, the big surface problem was solved decades ago. LA is an example, as I remember vividly visiting grandparents there in 1956- choking– and 1966 –merely eye watering. Now, no problems almost ever.
This is now a residual problem of much lesser import, where cost benefit is dubious (I did not track that issue to ground, as got murky in a hurry). Second, the pursuit of perfection is usually infinitly expensive. So the potential cost benefit is logically dubious.
That’s been a problem for sure, trying to eliminate the last 0.0001% of whatever. Hopefully, Trump will point the EPA down a rational, cost-as-well-as-benefit course.
Given all the great stuff going on in politics, it’s tough to hold back, but I guess I will :)
Ultimately that is the problem – ambient ozone has come down a lot but EPA keeps moving the goal posts requiring ever more stringent and exponentially more expensive controls. The potential cost benefits calculations are dubious.
Nonetheless the regulated sources have to play the game and EPA is not doing the work correctly, in my opinion, to actually “solve” the problem they have defined.
Have you any evidence that ground level ozone is any sort of a problem? To whom?
According to EPA (https://www.epa.gov/ozone-pollution/health-effects-ozone-pollution) “Ozone in the air we breathe can harm our health, especially on hot sunny days when ozone can reach unhealthy levels. Even relatively low levels of ozone can cause health effects.”
“People most at risk from breathing air containing ozone include people with asthma, children, older adults, and people who are active outdoors, especially outdoor workers. In addition, people with certain genetic characteristics, and people with reduced intake of certain nutrients, such as vitamins C and E, are at greater risk from ozone exposure. “
“Children are at greatest risk from exposure to ozone because their lungs are still developing and they are more likely to be active outdoors when ozone levels are high, which increases their exposure. Children are also more likely than adults to have asthma.”
In my opinion, the ultimate issue is how good is good enough. As Rud points out “the big surface problem was solved decades ago.” Neither of us argue that ozone was not a problem in the past. I suspect that somewhere, someplace there is some sensitive individual that at the highest currently observed levels may have some lung issues but I think that at these levels lung recovery is quick and simply avoiding exercise on those days limits impacts. The ultimate policy issue is whether or not we need to continue to tighten the standards for these limited impacts when the control costs are so high.
My understanding is that ozone was originally a proxy for smog, the latter involving a great many other chemicals. Somehow it took on a life of its own, with EPA doing the usual questionable epidemiological studies to make it seem far more unhealthy than it really is.
Thank you Roger,
I read your reference. There is no science there, only motherhood.
“The ultimate policy issue is whether or not we need to continue to tighten the standards for these limited impacts when the control costs are so high.”
There should be no ‘standards’ for no problem! Has your EPA even stated the means of generating ozone? Most low altitude O3 is generated by electrical discharge in a humid atmosphere. Excessive O3 seems to aggregate airborne particulates, is that the issue? Just what are these fools trying to ‘regulate’? Is this just another version of the CO2 SCAM?
Will, the ozone EPA is trying to regulate comes from the interaction of NOx and VOCs, not electrical discharges.
David Wojick | January 30, 2017 at 1:02 pm
‘.especially in the eastern US, with vast forests upwind of huge cities.’
Are you claiming ozone comes from forests?
David Wojick | January 30, 2017 at 6:47 am
“It is about urban ozone (the bad ozone).”
You certainly bounce around lots! Can you state what you mean?
David Wojick | January 30, 2017 at 7:42 am
“Also, last I knew the modeling showed that NOx reductions actually increased the ozone levels in core urban areas.”
Yes O3 quickly oxidizes NOx -> NO(x+1) + O2; ’tis automagical!
David Wojick | January 31, 2017 at 12:30 pm
“Will, the ozone EPA is trying to regulate comes from the interaction of NOx and VOCs, not electrical discharges.”
Just what Volatile Organic Compounds are you interacting with NOx to produce even one molecule of O3! Do you have a reaction drawing?
Is it the EPA or you that is doing the same SCAMMing as the CO2 Clowns!
I know very little about the chemistry, since my field is regulations. EPA tried for decades to reduce urban ozone by reducing VOC emissions from human activities. Trees apparently emit lots of VOCs.Then they went after NOx from power plants. It has been a long time since I looked at urban ozone but this used to be my bible (free PDF). I am sure that it answers all the basic questions, and then some.
https://www.nap.edu/catalog/1889/rethinking-the-ozone-problem-in-urban-and-regional-air-pollution
Will,
Thank you for this quote: “There is no science there, only motherhood.”
That my friends is very often the EPA playbook.
For many of the zealots, the problem they have defined is industrialised society. Having solved the real pollution problems long ago they are now drunk on power.
Further regulation is counter productive since it will simply strangle any production left in the US and export the pollution problem to other countries where life and labour is cheap and pollution controls are minimal if not non existent.
Will Janpschka- trees and many plants produce volatile organic compounds(VOC) that react to sunlight. The Great Smoky Mountains are smoky because of the forests on them. The VOC’s react with ozone, oxygen and nitro oxides to form smog which is a yellowish haze that can have very bad effects on people with asthma or lung disease. The classic smog was almost all caused by automobiles and poorly controlled power plants of the era(1950’s-70’s). Vehicle emissions controls and power plant scrubbing systems have virtually completely controlled it.
The VOC’s are some commercial solvents. The plant ones are mainly a class called terpene’s- complex, reactive hydrocarbons.
The emissions from forests cannot be controlled and reduction of the already minute quantities of ozone, such as around New York, won’t make any difference. As ristvan points out it’s only a problem a few days a year during summer, and then for only a part of the population.
Roger Caiazza, thank you for the essay.
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AGW’s museum label (In the spirit of the linked article) would be– e.g.,
Evidence of the politicization of AGW science since the ’70s is based on the fact that “global warming” was renamed “climate change” in the ’90s.
The EPA lowering ozone ambient standards from 75 ppb to 70 ppb to protect human health seems to be a reduction to absurdity. Before the 1984 Olympics in LA, Gong and associates measured peek performance of 17 elite cyclists in an environment chamber with 0.12 ppm and 0.20 ppm ozone. The authors reported (1986), at the lower concentrations there were little to no consistent effect to any parameters. The current attainment levels 75 ppb already are almost half the values in this study’s pre-Olympic assessment. The proposed lowering standards to 70 ppb should have some basis in fact one would expect, and as is, a cost/benefit analysts would unlikely stand scrutiny.
The Elites, as was spoken by Warren Buffet, are fearful only of what they can’t control. What they breath is one of those fears. But perhaps the EPA can come to their imagined need, for pure air. Next decade 60ppb.
When it comes to Big Oil, EPA is right there in their pocket, or should I say Big Oil has too many former employees work at EPA in key positions. EPA’s mobile source emission model called MOVES is a great example. Let the oil companies design the test fuels for which this model is based on and you control the outcome you want. If we want to model real world emissions, shouldn’t the model use real world fuel parameters?
Time to stop the inbreeding between EPA and Big Oil…