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November 18-22, 2023
In this week's issue:
- NACAA Submits Comments on Proposed Revisions to Air Emissions Reporting Requirements (November 17, 2023)
- UN Report Forecasts Nearly 3° C Global Warming With Currently Planned GHG Reductions (November 20, 2023)
- EPA Announces $2 Billion in Community Grants for Air Pollution, Climate Environmental Justice (November 21, 2023)
- Secondary Lead Smelters NSPS Published in Federal Register (November 20, 2023)
- Extension of Comment Period for VOL Storage Tanks Published in Federal Register (November 21, 2023)
This Week in Review
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NACAA submitted comments on EPA’s proposed rule, “Revisions to the Air Emissions Reporting Requirements,” which was published in the Federal Register on August 9, 2023 (88 Fed. Reg. 54,119). The proposal would significantly amend the Air Emissions Reporting Requirements (AERR) by requiring the reporting of hazardous air pollutant (HAP) data from point sources, including “non-major” sources that emit HAPs above reporting thresholds proposed in the rule. Point sources would be required to report their HAP emissions directly to EPA using the Combined Air Emissions Reporting System (CAERS). Alternatively, state and local air agencies would have the option to apply and seek approval to report HAP data to EPA on behalf of facility owners and operators in their jurisdiction, using either CAERS or their own emissions reporting systems. The proposal would phase earlier deadlines for state and local air agencies to report emissions data to EPA for the previous year. It also includes additional reporting elements for point sources and would require state and local agencies to submit data related to prescribed fires, certain small generating units, nonpoint and mobile sources, as well as many other provisions. NACAA stated in its comments that it supports the fundamental goals of the proposed rule but emphasized the significant implementation challenges the revisions will pose for state and local air agencies. The association agreed with EPA that HAP reporting should be mandatory and that reporting requirements should apply uniformly across the country. It observed, however, that identifying all of the non-major sources subject to HAP reporting requirements will be difficult, and noted that data from sources with no existing relationship with permitting authorities or experience with emissions estimation will raise quality assurance challenges. NACAA recommended that EPA consider allowing agencies the option to report HAP on behalf of major sources within their jurisdiction but not non-major ones; it also recommended that EPA consider phasing in reporting requirements for non-major sources over a series of years. NACAA also noted that the rule as proposed does not allow enough time for many agencies that may wish to report HAP data for their facilities to make the necessary changes to state rules before the 2026 inventory year. Accordingly, the association recommended that EPA delay the start date for mandatory HAP reporting to the 2028 inventory year or later. NACAA opined that EPA’s proposal to phase in earlier annual emission reporting deadlines for state and local agencies is far too aggressive and will not allow enough time for agencies to perform critical data quality assurance tasks. It recommended that EPA retain the existing deadline of December 31, and opined that if EPA does choose to compress the reporting timeline in this rule, under no circumstances should the deadline be earlier than September 30 of the year following the inventory year. NACAA’s letter also raised concerns associated with CAERS and with EPA’s proposed reporting requirements concerning prescribed fires and small electric generating units. The association opined that in the future, EPA should work more closely with state and local air agencies before proposed rules are issued and stressed that agencies will require significant additional funding to implement the AERR revisions.
For further information:
https://www.4cleanair.org/wp-content/uploads/FINAL-NACAA-AERR-Comments-11-17-23.pdf
In a review of existing emissions reductions policy and climate science, the United Nations Environment Program (UNEP) has forecast that under current emissions reductions pledges and expected climate change, the nations of the world are on track to cause 2.9°C of warming by the end of the century. The annual Emissions Gap Report projects that to limit warming to the 1.5°C threshold, greenhouse gas (GHG) emissions must be cut by at least 42 percent by 2030, and that emissions must fall 28 percent to stay within the 2°C limit of the Paris Agreement in that timeframe. Based on current trajectories, emissions are forecast to increase 3 percent globally by 2030.
For further information:
EPA has announced it will release $2 billion for projects benefitting disadvantaged communities facing air pollution and climate change impacts. EPA’s Community Change Grants will fund projects that make communities more resilient to climate impacts; prevent, monitor or clean up pollution; invest in low- and no-emission energy projects; and reduce indoor air pollution. Announced in a Notice of Funding Opportunity (NOFO, EPA-R-OEJECR-OCS-23-04) funding will be awarded by EPA’s recently commissioned Office of Environmental Justice and External Civil Rights (OEJECR) over the next year. EPA expects to make 170 awards on two tracks. Track I will award about $1.96 billion to 150 projects between $10 million to $20 million each, while Track II will award around $40 million to 20 projects at $1 million to $3 million each. EPA is targeting five areas for investments: tribes in Alaska, tribes elsewhere, territories, unincorporated communities in small and rural places, and communities on the U.S. southern border. Local government agencies are eligible entities to receive funding if they partner with community based organizations. Funding applications will be due before November 21, 2024, and an informational webinar on the grants is scheduled for December 7, 2024.
For further information:
https://www.epa.gov/inflation-reduction-act/inflation-reduction-act-community-change-grants-program
and
EPA’s final amendments to the New Source Performance Standards (NSPS) for Secondary Lead Smelters have been published in the Federal Register (88 Fed. Reg. 80,594). As reported in the November 11 – 17 edition of NACAA’s Washington Update, the amendments affect eleven existing, and potentially as many as three new, facilities that recycle lead-bearing scrap material (primarily lead acid batteries) into elemental lead or lead alloys, and will require them to monitor, limit, record, and report emissions.
For further information:
The comment period for the EPA’s New Source Performance Standards (NSPS) for volatile organic liquid (VOL) storage vessels has run in the Federal Register (88 Fed. Reg. 81,019). As reported in the November 11 – 17 edition of NACAA’s Washington Update, the extension means that comments on EPA’s proposal will now be due on December 8, 2023.
For further information:
https://www.govinfo.gov/content/pkg/FR-2023-11-21/pdf/2023-25759.pdf