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PPACG chair/Manitou Springs mayor: 'Economic consequences' in EPA ozone plan

       Editor's note: A proposed tightening of national ozone regulations, which the federal Environmental Protection Agency (EPA) claims would improve the health of all living things, fails to consider local issues and could cause “economic consequences” to our region, according to a letter approved by a vote of the Pikes Peak Area Council of Governments (PPACG) Board of Directors March 11.
       The letter, which will be submitted for EPA review, was signed by Marc Snyder, PPACG chair and mayor of Manitou Springs.
       Stricter ozone-level standards are an outgrowth of President Obama's 2013 Climate Action Plan, “which directed EPA and other federal agencies to take a series of actions to reduce carbon pollution, prepare the U.S. for the impacts of climate change, and lead international efforts to address global climate change,” according to an “overview” document provided by PPACG staff.
       The PPACG letter appears in its entirety below.


       [To] Environmental Protection Agency
       Washington, D.C.

       Re: EPA [Environmental Protection Agency] Proposal to Revise the National Ambient Air Quality Standards for Ozone

       The Pikes Peak Area Council of Governments is the lead air-quality planning agency for the Colorado Springs region. The PPACG Board of Directors, which represents 16 local governments in the region, has
Pikes Peak is in the background in a photo taken on a clear day during the Arbor Day celebration at Rock Ledge Ranch in 2004. Ozone is an air quality pollutant that can contribute to smog.
Westside Pioneer file photo
a number of concerns about the EPA's proposal to lower the primary and secondary ozone standard from 0.075 ppm [parts per million] to a level between 0.065 ppm and 0.070 ppm. In its proposal, the EPA has not adequately addressed issues such as high background concentrations, effects of elevation on ozone concentrations, credits for existing regulations and strategies, and the economic burden of a lower standard.

       Background concentrations
       Colorado has extremely high background ozone concentrations, and in Colorado Springs (located 60 miles south of Denver), modeling has shown that background ozone concentrations can represent almost half of the observed concentrations at our monitoring stations. This is also consistent with an EPA memo [in 2015] that showed Denver's 55 percent background concentration is the highest of 12 major U.S. urban areas.
       Although the EPA does appear to address unusually high ozone background concentrations through exemptions contained in their proposal for rural transport areas, there does not appear to be any consideration for high background concentrations in urban areas. Because background concentrations cannot be controlled through local regulations or strategies, meeting any new proposed standard will be more difficult in these areas. Spikes in background ozone concentrations could cause Colorado Spring and other areas to be in non-attainment and require more stringent regulatory controls.
       As EPA's Policy Assessment for the Review of the Ozone National Ambient Air Quality Standard (2014) identifies, the highest levels of seasonal mean background concentrations are confined to Colorado and other intermountain western locations. This means local strategies will potentially be less effective than in other parts of the country in reducing concentrations. The EPA clarified in [another 2015] memo that under the Clean Air Act, states are not responsible for reducing emissions that they cannot control. The EPA's current proposal does not appear to adhere to the Clean Air Act in this respect.

       Elevation
       Elevation is a contributing factor to high background concentrations. The EPA concluded in 1978 [“Altitude as a Factor in Air Pollution”] that “air pollution is affected by a change in altitude,” but the EPA proposal does not account for the effects that elevation has on ozone concentrations.
       It has been shown that background ozone levels increase with elevation, and for the interpretation of ozone surface data, the altitude of the station and the possible role of rapid vertical transport should be considered as key elements. Vertical profiles of ozone concentrations show an increase in ozone concentrations at altitude. This is a significant concern to our region, since both our monitoring stations are above 6,000 feet.
       Cities with surface elevations above 1,500 meters have lower atmospheric pressure and cause mobile sources to perform less efficiently and emit greater amounts of hydrocarbons. This can cause high altitude monitoring stations, all other conditions being the same, to have higher concentrations.
       The combined effects from monitoring stations located at higher elevations and areas that are shown to have higher background concentrations unfairly penalize certain areas and will require implementation of additional strategies if not accounted for in EPA's proposal.

       Existing Control Strategies and Regulations
       Colorado has already taken several steps to proactively address ozone concentrations, including Clean Air Clean Jobs legislation passed in 2010, the Regional Haze State Implementation Plan, innovative oil and gas regulations, and other statewide policies, regulations, and strategies. All of these statewide strategies have helped in reducing ozone concentrations. Our understanding is that if an area is placed into attainment for the first time, such as Colorado Springs, it will not be able to take credit in the State Implementation Plan for regulations or strategies like these that are already in place. There needs to be more flexibility so areas can take credit for existing strategies and regulations.

       Economic Impacts
       There will be economic consequences to our region and state by making the current ozone standard more stringent. The funding necessary to implement ozone reduction strategies is not available locally or through the state, and our understanding is that there have been no discussions regarding the possibility of additional federal funding through Congestion Mitigation Air Quality or any other federal funding sources. Many strategies that have already been implemented for our region and throughout the state have had a significant cost. The economic impacts from lowering the standard will affect citizens, businesses, and growth.
       Many areas are still in nonattainment for the old ozone standard of 0.084 ppm and for the current ozone standard of 0.075 ppm. Before revising the current ozone standard to be more stringent, federal resources should be spent to bring these existing areas of nonattainment into attainment. The health effects from ozone concentrations in these areas are much more severe than the potential health impacts if the standard is lowered to a level between 0.070 ppm or 0.065 ppm.
       Thank you for your consideration of these important factors. If you have any questions, please contact me at 719-471-7080.

       Sincerely,

       Marc Snyder
       Chair, PPACG Board of Directors

(Posted 3/19/15; Politics: State/Region)

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