EPA Publishes Proposal to Retain 2015-Set Ozone NAAQS
On Aug. 14, U.S. EPA’s proposal to retain the existing National Ambient Air Quality Standards (NAAQS) for Ozone was published in the Federal Register. The existing primary (health-based) and secondary (welfare-based) standards for ozone, established in 2015, are set at 70 parts per billion (ppb). According to EPA, the proposal is based on its judgment that the current NAAQS protect the public health, with an adequate margin of safety, including the health of at-risk populations, and protect the public welfare from adverse effects.
ACA and the coatings industry support retention of the national ozone standard of 70 ppb for ground-level ozone, and will be submitting comments to EPA to that effect.
EPA will hold virtual public hearings on Aug. 31 and Sept. 1 to discuss the proposal with interested stakeholders, and ACA will participate. EPA’s comment deadline for the proposal is October 1.
In October 2015, EPA lowered the NAAQS for ozone from 75 ppb to 70 ppb.
Volatile organic compounds (VOCs) combined with nitrogen oxides (NOx) and sunlight, produce ground-level ozone, a principal component of smog. EPA has cited emissions from industrial facilities, electric utilities, motor vehicle exhaust, gasoline vapors, and chemical solvents as major man-made sources of NOx and VOCs. However, studies have shown, and EPA has acknowledged, that ozone levels have improved by 33 percent over the past 30 years, and VOCs have decreased by 53 percent.
Under the Clean Air Act, EPA is required to set health-based NAAQS for specific pollutants, including ozone. This standard must be reviewed every five years, and EPA cannot consider implementation costs when setting NAAQS. NAAQS are standards for outdoor ambient air that are intended to protect public health and welfare from pollution. “NAAQS do not directly limit emissions of a pollutant; rather, they set in motion a long process in which states and EPA identify areas that do not meet the standards, and states prepare implementation plans to demonstrate how emissions will be lowered sufficiently to reach attainment.”
States are tasked with enacting pollution control regulations to meet the national standards by updating their state implementation plans (SIPs) with more restrictive VOC standards. This process is very mature and, for several decades now, federal, state and local regulations have limited VOCs in coatings and how these products are applied and used.
Since the late 1970’s, the paint and coatings industry has significantly reduced its emissions of VOCs and hazardous air pollutants (HAPs), and this trend continues. Market forces have played a role as the industry has become more service-oriented, providing just-in-time orders, smaller batch sizes, more waterborne and low-VOC coatings, and better transfer technology. VOC emissions from architectural coatings have drastically decreased over the last few decades as industry has moved towards low-VOC waterborne technologies, even while the use of architectural coatings has increased over the same period nationwide.
More than 90 percent of architectural coatings sales in the United States are now for environmentally preferable water-based paint and many manufacturers are developing very low VOC paint products specifically for vulnerable populations. In addition, modern aerosol coatings formulas are being developed with very low reactive solvents, resulting in significantly less potential for ozone formation. Since 1980, total emissions of the six principal air pollutants have dropped by 67 percent, and ozone levels have declined by 33 percent.
ACA believes that emphasizing market-driven innovations and existing policies to improve fuel economy, increase energy efficiency, and reduce air pollution from cars, facilities, and products will drive further air quality improvements over the next decade.
More information can be found on EPA’s website.
Contact ACA’s Rhett Cash for more information.