Tuesday, September 25, 2012

DIRTY BUGS!! Could an EPA energy plan mean more deadly diesel fumes?

This seemingly endless political season has been a rough one for folks at the U.S. EPA. 

Unfairly branded during presidential debates as a "job killer." http://www.newsmax.com/InsideCover/Bachmann-GOP-debate-EPA/2011/06/14/id/400010

Attacked for waging a "war on coal." http://www.thedickinsonpress.com/event/article/id/61570/group/News/  

Even accused, most tastelessly, of launching a "regulatory jihad." http://republicans.transportation.house.gov/News/PRArticle.aspx?NewsID=1325U

So it's only natural that the agency occasionally might seek to appease some of its critics -- to siphon off some political pressure.

And that's what seems to have happened in the curious case of DIRTY BUGS -- Back-Up Generators powered by diesel engines.  In this case, however, there are real concerns that EPA political concessions will mean dirtier air.

At first glance, this seems like a very, very technical story.  It has been covered well in some of the more specialized publications such as Greenwire and Bloomberg BNA, though little if any in mass-circulation outlets.

But the basic idea is actually fairly simple.  And the air quality stakes are so high that it deserves more than cursory attention.

In a nutshell: no one wants to see blackouts or brownouts. So regulators in charge of electric system reliability have tried to promote "demand response" -- encouraging energy users to avoid electricity use during periods of high demand.  In fact, demand-response companies are doing a brisk business because of related financial incentives.  Note, for example,

This is all well and good.  The basic concept seems to make a lot of sense. But what is replacing the traditional sources of power, and what are the implications?  This is where the DIRTY BUGS come in.

Hospitals, office buildings, and many companies historically have used these backup generators in emergencies to ensure reliable electricity in case of a temporary loss of power from the grid.  But now, something different is happening as the so-called demand-response market evolves.  BUG owners can actually run their engines during non-emergency periods and sell power to the grid, displacing cleaner power. (The incentives can be a real windfall: owners get paid whether the engines run or not.)

And the real problem is that the EPA is encouraging the use of DIRTY BUGS by proposing an outrageous loophoole that would permit deadly diesel engines to spew emissions for many hours a year without any emission controls.

How'd this happen?  EPA initially did set pollution standards for BUGS, but industry groups sued, and EPA proposed permitting the loophole are part of a legal settlement.  http://www.epa.gov/ttn/atw/rice/ricepg.html  And, yes, the bureaucracy has come up with a truly mind-numbing way of describing this dangerous proposal. (Rules for reciprocating internal combustion engines, or RICE. But this isn't about a gluten-free diet.)

A final rule is expected to go to the White House Office of Management and Budget in the coming weeks or months. Public health groups are very wary about the DIRTY BUG loophole.

As the American Lung Association put it in official comments to EPA:

The EPA’s proposed rule will encourage the use of backup generators, including uncontrolled generators, as routine suppliers of power to the electric grid, supplanting the use of cleaner sources of energy and creating a loophole for backup generators that will displace the deployment of cleaner, low-, and non-emitting resources.

The expanded non-emergency use of such generators will contribute emissions that will likely increase ozone and particulate matter levels and make it harder for communities to meet national air quality standards. Furthermore, such use of these generators threatens communities already disproportionately burdened by air pollution.

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0708-1140

State environmental agencies, having suffered through the smoggiest summer in five years http://blogforcleanair.blogspot.com/2012/09/gasping-for-air-clean-air-watch-reports.html

and fearful of toxic diesel emission problems, are also alarmed and raising great questions. These, for example, by the Northeastern States for Coordinated Air Use Management:

The number of [diesel generators]that may take advantage of the proposed rule’s pollution control exemptions: unknown.

· The locations of these sources: unknown.

· The times at which these sources may operate: unknown.

· The public’s exposure to increased levels of diesel exhaust and fine particulate matter from these sources: unknown.

· The resulting public health harms from the increased exposure to diesel emissions: unknown.

· The resulting impact on communities that may bear a disproportionate share of the negative environmental consequences resulting from industrial, governmental and commercial operations or policies: unknown.

· The resulting impact on the ability of states to attain and maintain the ozone and other air quality health standards: unknown.

· The impacts on future resource mixes in the electricity markets from allowing
uncontrolled RICE into economic demand response programs: unknown.

Absent this information, NESCAUM is unable to evaluate the proposed rule’s prospective impacts. And NESCAUM respectfully submits that neither can EPA.

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0708-1033

Other state experts are predicting pollution increases in the next few years if the DIRTY BUG loophole is permitted to stand.

This presentation, for example, by the Mid-Atlantic Regional Air Management Association notes that pollution from DIRTY BUG engines would trump ongoing cleanup efforts:

http://www.marama.org/presentations/2012_AirToxics/McDill-DG-Toxics.pdf

The concern is not just from states in the Northeast or Mid-Atlantic.  The state of Michigan, for example, has also raised a red flag. http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0708-0954

There is probably a simple fix to this mess.  Make sure that if these engines are used, that they have effective pollution controls.  As a spokesman for the pollution control industry noted at an EPA hearing in July, emission controls are readily available:
 
Indeed, the payback period for cleaning up is only one to two years.
 
History shows that demand-response companies can still make a healthy buck even if the DIRTY BUGS get cleaned up. http://www.enernoc.com/press/press-releases/2007/235-press/press-releases/2007/673-enernoc-expands-clean-gen-demand-reduction-program-with-san-diego-gas-a-electric
 
 
 
 


 
 








Friday, September 14, 2012

EPA staff tells science advisers: latest science points to a tougher smog standard than we were considering last year; Clean Air Watch thinks this underscores need for new Tier 3, low-sulfur gas standards


EPA staff scientists met this week in a teleconference with the agency's independent science advisers. (EPA's presentation is below.)

This was to review the most recent studies involving the health and environmental effects of exposure to ozone, commonly referred to as smog. You will recall that a little more than a year ago, the White House nixed an EPA effort to reconsider the scientifically deficient ozone standard set in 2008 by the Bush administration. (That standard is 75 parts per billion; after proposing a range of possible standards from 60-70, the EPA was preparing to issue a new standard of 70 before the heavy heel of the White House came down.)

What is most interesting about this new review, including some more recent science, is that EPA staff now is arguing that EPA should consider an even tougher standard.  As noted below:

In the current review, staff reached the preliminary conclusion that the new evidence reinforces support for analyzing levels from 70 to 60 ppb In addition, staff reached preliminary conclusion that the new evidence also supports analyzing standard levels somewhat below 60 ppb
 

Bottom line: the current smog standard is woefully inadequate to protect public health. (And, as we have pointed out, there is a massive smog problem in this country even using the Bush standard as the yardstick: http://blogforcleanair.blogspot.com/2012/09/gasping-for-air-clean-air-watch-reports.html )

We need new smog-fighting tools.  The most obvious would be the so-called Tier 3 tailpipe pollution and low-sulfur gasoline standards. These would reduce smog from coast to coast, improve the quality of life for many millions of breathers. And, according to one reliable survey, not add even a penny to the cost of gasoline. http://blogforcleanair.blogspot.com/2012/06/study-low-sulfur-gas-would-mean-no.html

 

 Here is the EPA presentation:
 
Review of the O3 NAAQS: First Draft
Policy Assessment
 
 
 
 
 
 
 
 
Clean Air Scientific Advisory Committee Meeting
CASAC Ozone Panel
September 11-13, 2012
 
 
 
Ms. Susan Lyon Stone, Dr. Scott Jenkins, Ms. Vicki Sandiford


Overview of Briefing: Structure of 1st Draft Policy
Assessment
 
 
 
     Chapter 1: Introduction and overview of document
 
Part I: Primary Standard
 
     Chapter 2: Overview of health evidence from 3rd draft ISA
 
     Chapter 3: Overview of human exposure and risk results from 1st draft REA
 
     Chapter 4: Staffs preliminary conclusions on adequacy of current primary O3
NAAQS and alternatives appropriate for analysis in 2nd draft REA
 
Part II: Secondary Standard
 
     Chapter 5: Overview of vegetation effects evidence from 3rd draft ISA
 
     Chapter 6: Overview of vegetation exposure and risk results from 1st draft REA
 
     Chapter 7: Staffs preliminary conclusions on adequacy of current secondary O3
NAAQS and alternatives appropriate for analysis in 2nd draft REA


Chapter 1: Introduction and Overview
 
 
 
 
    Purpose, legislative requirements, history through reconsideration and current review
    Overview of monitoring network and air quality, with a focus on background O3
   Background contributions to ambient O3 are relatively low across much of the U.S., including heavily populated areas in the eastern U.S. and California
   Anthropogenic emission sources are the dominant contributors to 8-hr daily max O3 concentrations on days with highest total O3 concentrations
   In areas where background O3 concentrations are highest (i.e., western U.S. and at high elevations), the key sources contributing to episodic high background concentrations include wildfires, stratospheric intrusions, and intercontinental transport
 
 
 
 
 
 
3


 
 
Chapter 2: Weight-of-Evidence Conclusions and
Controlled Human Exposure Studies
 
Weight-of-evidence conclusions regarding causality
     Primary focus on effects for which the ISA concludes the relationship is causal or likely to be causal (i.e., respiratory effects following short- and long-term exposures; mortality following short-term exposures)
Controlled human exposure studies, with a focus on:
     Large body of evidence available in last review
   Lung function decrements, respiratory symptoms, airway inflammation, airway hyperresponsiveness, and decreased lung host defense following exposures at or above 80 ppb
   Lung function decrements following exposures as low as 60 ppb
 
     New studies conducted at O3 exposure concentrations below current standard level
   Additional evidence for lung function decrements following exposures to 60 ppb
   Airway inflammation and respiratory symptoms following exposures to 60 and 70 ppb, respectively
   Consider group mean FEV1 decrements, and proportion of subjects who experience
decrements ( 10% ) that could be clinically relevant to people with lung disease
 
     Studies conducted in healthy adults, likely underestimate magnitude and seriousness of such effects in at-risk populations


Chapter 2: Epidemiologic Studies
 
     Short-term (i.e., hours to weeks)
   Studies in last review reported associations with lung function decrements, respiratory symptoms, medication use, and respiratory emergency department visits and hospital admissions
 
   New multi-city and single-city studies reinforce previous evidence, reporting O3-associated mortality and respiratory effects (respiratory-related emergency department visits, hospital admissions, mortality)
 
   Recent studies continue to report no evidence for discernible threshold within range of concentrations common in U.S. O3 season (i.e., > 20 ppb), supporting associations at O3 concentrations below current standard
 
   Key issues related to the interpretation of epidemiologic studies include confounding by copollutants, effect modification, lag structure, shape of concentration-response relationships, and potential for thresholds
     Long-term (i.e., 30 days)
   Limited evidence for O3-related respiratory effects, including reduced lung function growth, available in last review
   New studies report associations with range of respiratory effects, including new onset asthma,
1st asthma hospital admission, decrements in pulmonary function, and respiratory mortality
   Several studies report important gene-environment interactions
   Toxicology studies support biological plausibility of associations and coherence of evidence


 
Chapter 2: Public Health Implications
 
 
    Characterization of public health implications includes discussion of:
   Adversity of effects
   Identification of at-risk populations
   Size of at-risk populations
   Averting behavior
    Adversity criteria drawn from 2008 review (ATS 1985, 2000; and CASAC
advice from  previous reviews)
    Discussion of populations at risk focuses on factors for which the ISA
concludes evidenceadequate” for increased risk
   Asthma, lifestages (i.e., children and older adults), diet, and working outdoors
   Estimates of sizes of at-risk populations based on data from 2010 Census and
Bureau of Labor Statistics data on outdoor workers
   Children and older adults alone total > 110 million people, or about 37% of population
 
    New evidence for impact of averting behaviors, based on AQI reporting, suggests they may affect risk estimates in short-term U.S. epidemiologic studies


Chapter 3: Exposure and Risk Results
 
 
     Focus is on preliminary estimates of O3-related exposures and health risks remaining after simulating just meeting the current primary NAAQS, from the 1st draft REA
   Estimated exposures at and above benchmark O3 concentrations of 60, 70, 80 ppb
   Estimated O3-attributable mortality based on C-R relationships from epidemiologic studies
 
   Estimated O3-attributable respiratory hospital admissions and emergency department visits based on epidemiologic studies
   Estimated O3-attributable respiratory symptoms based on epidemiologic studies
 
     Second draft PA will also focus on:
   Estimates of population at risk for O3-induced lung function decrements
   Estimates of exposures and risks remaining after simulating just meeting alternative standards
   Estimates of incremental reductions in risk across alternative standards


Chapter 4: Staffs Preliminary Conclusions on
Adequacy of Current Primary O3 NAAQS
 
     Scientific evidence and exposure/risk information clearly calls into question adequacy of current standard, and does not support retaining current standard
 
   Evidence for respiratory effects and mortality following exposures to O3 concentrations well below the current standard
 
   Based on preliminary exposure and risk information from the first draft REA, risks remaining may reasonably be judged important for public health
 
     In the 2008 review and reconsideration, CASAC unanimously recommended a more protective standard
 
     Evidence, information, and CASAC advice supports consideration of revising current standard to increase public health protection against short-term exposures, especially for at-risk populations
 
     Second draft Policy Assessment will also consider extent to which current standard protects against effects of long-term O3 exposures


Chapter 4: Staffs Preliminary Conclusions Regarding
Additional Analyses for 2nd Draft REA
 
 
    First draft PA presents staffs preliminary conclusions regarding the range of alternative O3 levels appropriate for analysis in the 2nd draft REA
 
   In the 2nd draft PA, staff will reach preliminary conclusions regarding the range of alternative standards appropriate for consideration by the Administrator
 
    Averaging time: Appropriate to analyze alternatives with 8-hr averaging time
 
    Levels: In identifying a range of levels for analysis, staff considered the scientific evidence and the advice received from CASAC in the last review
 
   In the last review and in the reconsideration, CASAC recommended a focus on levels from 70 to 60 ppb
 
   In the current review, staff reached the preliminary conclusion that the new evidence reinforces support for analyzing levels from 70 to 60 ppb
 
   In addition, staff reached preliminary conclusion that the new evidence also supports analyzing standard levels somewhat below 60 ppb


 
 
Chapter 4: Considerations in Translating Epidemiologic
Evidence
 
 
     Ozone design values in study locations, with particular emphasis on studies conducted in locations likely to have met the current and/or alternative standards
 
     Ozone air quality distributions in locations where studies have evaluated C-R
relationships
   First draft PA presents two examples, drawn from analyses in review of PM2.5 NAAQS
   CASAC has provided extensive input on analyses of the PM2.5 epidemiologic evidence
 
     Several issues complicate the consideration of air quality distributions and C-R
relationships:
   Interpretation of confidence intervals, given that statistical precision decreases with decreasing data density
   Interpretation of associations based on O3 concentrations averaged across monitors, given that attainment is based on 4th highest concentrations measured at highest monitor
   For some studies, lack of available data necessitates use of surrogates for study areas and air quality metrics
 
     For considering alternative standards in 2nd draft PA:
   Consideration of short-term studies can be refined and expanded
   Protection against long-term exposures will be evaluated
 
10


 
Chapter 5: Environmental Effects Evidence
 
 
 
 
     Weight-of-evidence conclusions regarding causality
 
   Primary focus on vegetation and ecosystem-level effects for which the ISA concludes the relationship is causal (e.g., visible foliar injury, reduced growth/productivity, reduced yield, effects on below-ground biogeochemical cycles, and radiative forcing) or likely to be causal (e.g., reduced carbon sequestration, alteration of ecosystem water cycling, alteration of community composition; effects on climate)
 
 
     New vegetation effects evidence:
 
   Supports, strengthens, and is consistent with key conclusions drawn from previous reviews regarding visible foliar injury, growth, productivity, and carbon storage
   Increases coherence in weight of evidence based on new mechanistic studies
 
   Reinforces previous conclusions about importance of cumulative, seasonal, peak- weighted exposures in selecting biologically/ecologically relevant exposure indices


Chapter 5: Environmental Effects Evidence (cont.)
 
 
 
 
 
     Vegetation effects evidence useful for assessing the adequacy and appropriateness of the current standard and consideration of potential alternative standards
    Biologically/ecologically-relevant forms
    Averaging times (exposure periods, such as diurnal, seasonal and annual):
    Level
 
     Adversity paradigm from last review still appropriate with inclusion of ecosystem services impacts
 
     Information on other welfare effects (e.g., climate, UV-B) insufficient to inform judgments regarding adequacy of current standard


Chapter 6: Risk and Exposure
 
 
 
 
 
     Primary focus is on 1st draft REA preliminary estimates of O3-related exposures and vegetation risks that remain after simulating just meeting the current secondary NAAQS
 
    1st draft REA estimated national scale exposures and relative biomass loss (RBL) for studied tree species
 
    Assessment of visible foliar injury and other effects are ongoing and will be more fully addressed in 2nd draft REA
 
 
 
 
     The 2nd draft PA will also consider the preliminary results of analyses that used the Forest and Agriculture Services Optimization Model Green House Gas (FASOMGHG) and iTree models
 
   These analyses assess the incremental effects of O3-induced biomass loss on associated ecosystem services in timber/agriculture markets and urban forest systems, respectively


 
Chapter 7: Staffs Preliminary Conclusions on the
Adequacy of Current Secondary O3 NAAQS
 
 
 
     Scientific evidence  and preliminary exposure/risk results clearly call into question adequacy of protection and does not support retention of the current 8-hr standard
 
   Evidence of vegetation effects occurring in the field resulting from ambient cumulative, seasonal exposures allowed by the current standard
 
   National scale exposures and estimated risks of relative biomass loss (RBL) that could reasonably be anticipated to cause adverse effects are likely to remain in substantial geographic areas across the country upon just meeting the current standard
 
     Evidence clearly calls into question the appropriateness of the form and averaging time of the current 8-hr standard
 
   Available information supports consideration of revising current standard to afford more appropriate protection, by selecting a biologically/ecologically relevant standard form
 
   In the 2008 review and 2010 reconsideration, CASAC unanimously concluded that it is not appropriate to protect vegetation by promulgating identical primary and secondary standards and encouraged the Administrator to establish an alternative cumulative standard distinctly different in form, averaging time and level than the primary standard



 

 

Chapter 7: Staffs Preliminary Conclusions Regarding

Additional Analyses for 2nd Draft REA

 

 

 

     First draft PA presents staffs preliminary conclusions regarding the range of alternative O3 standards appropriate for analysis in the 2nd draft REA

 

   In the 2nd draft PA, staff will reach preliminary conclusions regarding the range of alternative standards appropriate for consideration by the Administrator

 

     Form:  Continue focus on the cumulative, peak-weighted W126 exposure index

 

     Averaging time(s):  Continue focus on 12-hr daytime diurnal exposure period (8 am to 8 pm), maximum consecutive 3-month seasonal exposure period, and 3-year average

 

     Level: In identifying a range of levels for analysis, staff considers the scientific evidence and the advice received from CASAC in the last review

 

   In  last review and in the reconsideration, CASAC recommended range of 7-15 ppm-hrs

 

   In the current review, staff reaches preliminary conclusion that the new evidence reinforces support for analyzing levels within that same range (715 ppm-hrs)