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Increased Background Pollution Essentially Having Same Effect as Lowering NAAQS

May 2, 2012

It baffles me why so many people are concerned about potential lowering of the NAAQS when increasing background pollution is essentially having the same effect. 

What’s the difference between lowering the NAAQS by 10 ppb or increasing background pollution by 10 ppb from a SIP emissions reduction standpoint?  Not much.

Let me explain by way of example.  This is over-simplified, but hopefully illustrative.  Let’s say the NAAQS is lowered to 65 ppb.  In order to achieve a 65 ppb ozone standard assuming 50 ppb background pollution and a design value of 85 ppb a State would need to find enough emission reductions to reduce 20 ppb of ozone from a potential emissions pool of 35 ppb—in other words the State would need to find a 57% reduction in emissions.  Now let’s say the NAAQS isn’t lowered, but background pollution increases (which is expected due to projected increases in foreign emissions and climate change impacts).  In order to achieve a 75 ppb ozone standard with 60 ppb background pollution and a design value of 85 ppb a State would need to find enough emission reductions to reduce 10 ppb of ozone from a potential emissions pool of 25 ppb—in other words the State would need to find a 40% reduction in emissions.

Time to be truthful and transparent about what is happening.  Time to transform the SIP process.  We can make it happen.

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