Working together for clean airWorking together for clean air

Tacoma Clean Air Performance Commitment

Tacoma Clean Air Performance Commitment

May 2010May 2010

What is CAPC?What is CAPC?

• Intended, ultimately, as an alternative to the current SIP process

• EPA has demonstration projects underway in two areas:

• Tacoma, WA

• Omaha, NE/Council Bluffs, IA

• CAPC Objectives?

• Achieve same or greater environmental improvements as current process, while minimizing process

• Create a more flexible/adaptable process, while incorporating measures to ensure accountability

• Provide meaningful opportunities for the public to engage in the

process

• Intended, ultimately, as an alternative to the current SIP process

• EPA has demonstration projects underway in two areas:

• Tacoma, WA

• Omaha, NE/Council Bluffs, IA

• CAPC Objectives?

• Achieve same or greater environmental improvements as current process, while minimizing process

• Create a more flexible/adaptable process, while incorporating measures to ensure accountability

• Provide meaningful opportunities for the public to engage in the

process

Why a CAPC in Tacoma?Why a CAPC in Tacoma?

EPA recognizes the need to make improvements to the state implementation planning (SIP) process to more efficiently and effectively address air quality challenges

The Tacoma area’s PM2.5 issue is strongly driven by a single source type (i.e. wood smoke) and the impacts of wood smoke are not easily evaluated by air quality models

Many of the potential wood smoke control measures may be voluntary or incentive based and not likely to receive significant SIP credit

The Washington Department of Ecology, the Puyallup Tribe, EPA, and the Agency all have regulatory authority over portions of the nonattainment area

EPA recognizes the need to make improvements to the state implementation planning (SIP) process to more efficiently and effectively address air quality challenges

The Tacoma area’s PM2.5 issue is strongly driven by a single source type (i.e. wood smoke) and the impacts of wood smoke are not easily evaluated by air quality models

Many of the potential wood smoke control measures may be voluntary or incentive based and not likely to receive significant SIP credit

The Washington Department of Ecology, the Puyallup Tribe, EPA, and the Agency all have regulatory authority over portions of the nonattainment area

Tacoma Nonattainment AreaTacoma Nonattainment Area

Participants in the CAPCParticipants in the CAPC

EPA OAQPS

EPA Region 10

Washington Department of Ecology

Puyallup Tribe

Puget Sound Clean Air Agency

EPA OAQPS

EPA Region 10

Washington Department of Ecology

Puyallup Tribe

Puget Sound Clean Air Agency

Elements of the CAPCElements of the CAPC

MOU signed by CAPC parties

Performance agreement that focuses on attaining the NAAQS efficiently and effectively

Targeted local control measures that complement national measures

Establish agreed-upon technical or accountability metrics before the process begins so that all parties are in agreement on the end goal (i.e. how many wood burning appliances can the air shed support)

A community stakeholder process that results in meaningful public involvement and input regarding the SIP control measures (e.g. how to phase out wood burning appliances)

Ultimately, absent clean air, we will need to submit a SIP that contains all the elements necessary for EPA approval

MOU signed by CAPC parties

Performance agreement that focuses on attaining the NAAQS efficiently and effectively

Targeted local control measures that complement national measures

Establish agreed-upon technical or accountability metrics before the process begins so that all parties are in agreement on the end goal (i.e. how many wood burning appliances can the air shed support)

A community stakeholder process that results in meaningful public involvement and input regarding the SIP control measures (e.g. how to phase out wood burning appliances)

Ultimately, absent clean air, we will need to submit a SIP that contains all the elements necessary for EPA approval

Technical Analysis ComponentsTechnical Analysis Components

Gather existing technical information on source attribution in the Tacoma area

Determine the capability of the existing grid model to predict PM2.5 concentrations in the Tacoma area - identify potential areas of weakness with the model

Identify and explore other modeling tools to evaluate control measures that would meet the modeling requirements in Appendix W of 40 CFR Part 50 and the PM2.5 Implementation Rule

Agree on types of modeling to be used

Conduct modeling runs on the effectiveness of potential control measures

Gather existing technical information on source attribution in the Tacoma area

Determine the capability of the existing grid model to predict PM2.5 concentrations in the Tacoma area - identify potential areas of weakness with the model

Identify and explore other modeling tools to evaluate control measures that would meet the modeling requirements in Appendix W of 40 CFR Part 50 and the PM2.5 Implementation Rule

Agree on types of modeling to be used

Conduct modeling runs on the effectiveness of potential control measures

Timeline for the CAPCTimeline for the CAPC

March/April 2010 – MOU signed by all CAPC parties

December 2010 - Complete and reach consensus on technical evaluation

January 2011 - Begin comprehensive stakeholder process assuming agreement on the technical approach

September 2011 - Complete comprehensive stakeholder process and document the prioritization of control measures

November 2011 – Incorporate the prioritized control measures into a Performance Agreement that documents how the control measures will be implemented

March 2012 – Complete public hearings on the SIP

July 2012 – Submit an approvable SIP

March/April 2010 – MOU signed by all CAPC parties

December 2010 - Complete and reach consensus on technical evaluation

January 2011 - Begin comprehensive stakeholder process assuming agreement on the technical approach

September 2011 - Complete comprehensive stakeholder process and document the prioritization of control measures

November 2011 – Incorporate the prioritized control measures into a Performance Agreement that documents how the control measures will be implemented

March 2012 – Complete public hearings on the SIP

July 2012 – Submit an approvable SIP

Scope of the Challenge Scope of the Challenge

150,000 households in nonattainment area

20,000 have wood stoves (13% of households) At least a third are uncertified

We doubt many of the certified catalytic stoves function properly

10,000 have fireplace inserts (7% of households)

30,000 have open fireplaces (20% of households)

Total of about 60,000 wood burning devices

We’ve spent over $2,000,000 in incentives over the last three years and have upgraded about 1,000 wood stoves and inserts with no discernable change in air quality

150,000 households in nonattainment area

20,000 have wood stoves (13% of households) At least a third are uncertified

We doubt many of the certified catalytic stoves function properly

10,000 have fireplace inserts (7% of households)

30,000 have open fireplaces (20% of households)

Total of about 60,000 wood burning devices

We’ve spent over $2,000,000 in incentives over the last three years and have upgraded about 1,000 wood stoves and inserts with no discernable change in air quality