PSD REFORM. STAPPA/ALAPCO/EPA 2004 Permitting Workshop Chris Shaver National Park Service

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1 PSD REFORM STAPPA/ALAPCO/EPA 2004 Permitting Workshop Chris Shaver National Park Service

Air Quality in National Parks and Wilderness Areas: Relevant Mandates conserve the scenery and the natural and

(NPS Organic Act) Wilderness areas shall be administered for the use of the American people in such a manner as will

enhance the air quality in national parks, national wilderness areas, national monuments, national seashores, and

(Clean Air Act as amended in 1977) Congress declares as a national goal the prevention of any future, and the

2 Air Quality in National Parks and Wilderness Areas: Relevant Mandates conserve the scenery and the natural and historic objects and wild life therein as will leave them unimpaired for the enjoyment of future generations. (NPS Organic Act) Wilderness areas shall be administered for the use of the American people in such a manner as will leave them unimpaired for future use and enjoyment as wilderness (Wilderness Act of 1964) preserve, protect and enhance the air quality in national parks, national wilderness areas, national monuments, national seashores, and other areas of special national or regional natural, recreational, scenic, or historic value. (Clean Air Act as amended in 1977) Congress declares as a national goal the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory class I Federal areas which impairment results from manmade air pollution. (Clean Air Act as amended in 1977)

Federal Land Manager Role the Federal Land Manager should assume an aggressive role in protecting the air quality related values of land areas under their jurisdiction.

3 Federal Land Manager Role the Federal Land Manager should assume an aggressive role in protecting the air quality related values of land areas under their jurisdiction. In cases of doubt the land manager should err on the side of protecting the air quality-related values for future generations. (Senate Report No , 95 th Congress, 1977)

4 Success is Economic growth occurring without compromising clean air, especially in national parks and wilderness areas Effective protection of air quality and resources affected by air quality in Class I and II areas Performance goal: stable or improved air quality Performance measures: visibility, ozone and deposition Performance results: ~50% meet goal for all parameters over past decade

5 Olympic Trends in Annual Sulfate Concentrations (ueq/l) in Precipitation at U.S. National Parks ( ) North Cascades Glacier Mount Rainier Little Bighorn Isle Royale Yellowstone Craters of the Moon Acadia Yosemite Rocky Mountain Great Basin Bryce Canyon Sequoia Canyonlands Mesa Verde Capulin Volcano Grand Canyon Bandelier Gila Cliff Buffalo Indiana Dunes Shenandoah Great Smoky Mtns Organ Pipe Guadalupe Mtns Big Bend Denali No trend Increasing Trend, p <= 0.15 Everglades Decreasing Trend, p <= 0.15

6 GPRA Trends in Deciview on Clearest Days, Trends in Deciview on Clearest Days, Mount Rainier Glacier Crater Lake Acadia Yellowstone Redwood Badlands Lassen Volcanic Point Reyes Yosemite Great Basin Rocky Mountain Washington Pinnacles Sequoia Bryce Canyon Canyonlands Great Sand Dunes Mesa Verde Mammoth Cave Shenandoah Grand Canyon Petrified Forest Bandelier Great Smoky Mtns Tonto Gila Cliff Chiricahua Guadalupe Mtns Big Bend Denali Decreasing Trend, p<=0.15 Decreasing Trend, p>0.15 Increasing Trend, p<=0.15 Increasing Trend, p>0.15 No Trend Insufficient Data DRAFT

7 GPRA Trends in Deciview on Haziest Days, Trends in Deciview on Haziest Days, Mount Rainier Glacier Crater Lake Acadia Redwood Yellows tone Lassen Volcanic Badlands Point Reyes Great Basin Yosemite Bryce Canyon Rocky Mountain Washington Pinnacles Sequoia Grand Canyon Tonto Canyonlands Great Sand Dunes Mesa Verde Bandelier Petrified Forest Great Smoky Mtns Mammoth Cave Shenandoah Chiricahua Gila Cliff Guadalupe Mtns Denali Big Bend Decreasing Trend, p<=0.15 Decreasing Trend, p>0.15 Increasing Trend, p<=0.15 Increasing Trend, p>0.15 No Trend Insufficient Data DRAFT

8 Trends in Annual 4th Highest Daily Maximum 8-hr Ozone at U.S. National Parks ( ) Olympic North Cascades Mount Rainier Glacier Voyageurs Yellowstone Theodore Roosevelt Acadia Craters of the Moon Lassen Volcanic Cape Cod Pinnacles Yosemite Rocky Mountain Great Basin Sequoia Canyonlands Death Valley Mesa Verde Mammoth Cave Shenandoah Channel Islands Grand Canyon Joshua Tree Saguaro Chiricahua Great Smoky Mtns Cowpens Congaree Swamp Chamizal Big Bend Denali No trend Everglades Increasing Trend, p <= 0.15 Decreasing Trend, p <= 0.15

9 Olympic Trends in Annual Nitrate Concentrations (ueq/l) in Precipitation at U.S. National Parks ( ) North Cascades Mount Rainier Glacier Isle Royale Little Bighorn Acadia Yellowstone Craters of the Moon Great Basin Rocky Mountain Yosemite Bryce Canyon Sequoia Canyonlands Mesa Verde Capulin Volcano Grand Canyon Bandelier Buffalo Indiana Dunes Shenandoah Great Smoky Mtns Organ Pipe Gila Cliff Guadalupe Mtns Big Bend Denali No trend Increasing Trend, p <= 0.15 Everglades Decreasing Trend, p <= 0.15

10 Success Depends on Teamwork States: Design program to manage clean air resources, including, but not limited to permitting EPA: Oversees and enforces FLMs: Meaningful role in AQRV protection, including committing resources Regulated community: Expend resources for analyses of source impacts

11 FLM Role in PSD Program Affirmative responsibility to protect AQRVs Providing data on air quality and health of resources Consultation with States and EPA SIPs Permit Review Advisory role unless Class I increment violated AQRV analysis, increment consumption & BACT Redesignation of federal land

12 PSD Program Successes Awareness of Class I area values AQRVs and benefits of protection Understanding of FLM role Relationship institutionalized in many states Willingness to accommodate FLM concerns Dramatic improvements in technology BACT Regulatory tests (increments) and incentive to reduce impact below significant levels have resulted in less pollution increases Enhanced modeling capabilities

13 Mixed RESULTS Tarnish Successes Air quality in 50% of the national parks is getting worse, and over 100 units of the National Park System are nonattainment areas for ozone, including several major parks FLMs knowledge of how air pollution affects resources is far from complete Periodic review of increment consumption hasn t occurred in most states Efforts to MANAGE the clean air resource are primarily limited to NSR Framework doesn t fit the problems occurring When rules are not being interpreted or enforced consistently

14 Options for Fulfilling Purposes of PSD Program Clarification on periodic reviews, cumulative increment analyses, and fixing increment violations Improved partnership between FLM & States, including shared recognition of value of assessing and addressing cumulative impacts on AQRVs Consider more direct routes to desired outcome

Air Quality Trends in National Parks. Mike George, National Park Service December 7, 2004

Air Quality Trends in National Parks Mike George, National Park Service December 7, 2004 Trend Analysis One of the goals of the Interagency Monitoring of Protected Visual Environments (IMPROVE) & NPS criteria