Finding A Better Finding A Better Way to Cleaner Way to Cleaner

Air in TexasAir in Texas

Departing from the SIP Departing from the SIP ProcessProcess

State Implementation State Implementation Plan ProcessPlan Process

State must develop plan State must develop plan demonstrating attainmentdemonstrating attainment

Based on science and best guesses Based on science and best guesses about the futureabout the future

Includes federal controls and Includes federal controls and additional state/local controls additional state/local controls necessary to make up any shortfallnecessary to make up any shortfall

Huge, complex document that Huge, complex document that requires constant review and requires constant review and revisionrevision

Reasons to Depart from the

SIP Process1. SIP-related emissions now dominated by Federal sources

2. Increased role of interstate/international pollution

3. Federal controls reducing SIP effectiveness

4. State/local controls more costly, less effective

5. SIP process emphasizes procedure over results

6. SIP process focuses state myopically on short-term

7. SIP process encourages delay tactics

SIP Related Emissions Now SIP Related Emissions Now Dominated by Federal Sources Dominated by Federal Sources

that the State Cannot as that the State Cannot as Efficiently and Effectively Efficiently and Effectively

ControlControlNatural Sources

5% Cars & Trucks

29%Industry32%

Off-Road34%

Houston 2007

Dallas 2007

Interstate/International Transport Interstate/International Transport More of an Issue and Outside of More of an Issue and Outside of

State’s ControlState’s Control EPA found in CAIR that

Arkansas significantly contributes to Houston ozone

TX in CAIR because impacts 2 counties in Illinois

Over ½ of ozone in DFW is background

Cannot tell another state what to do

→→

Federal Controls Making SIP Federal Controls Making SIP Process Less Effective at Process Less Effective at

Reducing EmissionsReducing Emissions

290 Counties in 2002 27 Counties in 2020

Federal SIP Controls Are Less Federal SIP Controls Are Less Expensive than State/Local Expensive than State/Local

ControlsControls

Federal SIP Controls Generally Federal SIP Controls Generally More Effective and More Effective and

Enforceable than State/Local Enforceable than State/Local ControlsControls

No-drive days 55 mph limit Idling restriction Delay commercial

hours Reduced power

take-offs Barbecue ban

SIP Process Places Emphasis on SIP Process Places Emphasis on Process over ResultsProcess over Results

Huge, complex documents requiring constant Huge, complex documents requiring constant review and revisionreview and revision

More important to have EPA approved SIP More important to have EPA approved SIP than to achieve attainment (sanctions vs. than to achieve attainment (sanctions vs. bump-up)bump-up)

Little incentive to evaluate real-world control Little incentive to evaluate real-world control effectivenesseffectiveness

Focus should be public health—not Focus should be public health—not paperworkpaperwork

SIP Process Focuses State and SIP Process Focuses State and Local Local

Government Myopically on Government Myopically on Finding Finding

Short-Term SolutionsShort-Term Solutions Houston Control Development Deadline Houston Control Development Deadline

Mar. 2006Mar. 2006

Rule Development DeadlineRule Development Deadline

Sept. 2006Sept. 2006

All Controls ImplementedAll Controls Implemented

Dec. 2008Dec. 2008

SIP Process Encourages SIP Process Encourages Resources to be Spent on Resources to be Spent on

Delay TacticsDelay TacticsEx./ Houston 8-hour SIPEx./ Houston 8-hour SIP 2010 deadline, 2007 submittal 65% NOx reduction needed Cannot timely attain—but

compelled to spend tens of millions: (1) developing unviable control strategies (that will eventually be thrown out) and (2) justifying a bump-up

money would be better spent reducing pollution

A Better PathA Better Path

Goals of Replacement Goals of Replacement StrategyStrategy

More real-world emission reductions at less More real-world emission reductions at less costcost

Address community multi-pollutant Address community multi-pollutant concerns historically overshadowed by concerns historically overshadowed by demands to focus on ozonedemands to focus on ozone

Find it and fix it (increased compliance Find it and fix it (increased compliance assistance and enforcement)assistance and enforcement)

Increased monitoring and measurementsIncreased monitoring and measurements Improve emission reduction technologiesImprove emission reduction technologies

Proposed SolutionProposed Solution Transform SIP Transform SIP Process into National Multi-Process into National Multi-

Pollutant Planning Process and Pollutant Planning Process and Give EPA Primary ResponsibilityGive EPA Primary Responsibility Give EPA primary responsibility to achieve Give EPA primary responsibility to achieve

NAAQSNAAQS EPA can regulate all sources and do so more EPA can regulate all sources and do so more

efficiently and effectively efficiently and effectively EPA can address interstate and international EPA can address interstate and international

transport which states cannottransport which states cannot States can assist EPA in achieving NAAQSStates can assist EPA in achieving NAAQS

Allows states to focus more on local pollution Allows states to focus more on local pollution concerns and reducing emissionsconcerns and reducing emissions

Develop National Multi-pollutant Planning ProcessDevelop National Multi-pollutant Planning Process

Initial Reaction to Our SIP Initial Reaction to Our SIP Reform EffortReform Effort

This is too big and difficult This is too big and difficult Politically this is not the right Politically this is not the right

timetime This is an idealistic endeavor This is an idealistic endeavor

that is bound to failthat is bound to fail I benefit from the status quoI benefit from the status quo This is better handled by This is better handled by

others”others”

““This is the right thing to do This is the right thing to do for the environment and for the environment and business, but:business, but:

Thankfully the people in these pictures did the right thing for our nation despite being told it could not be done