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New Ozone Standard and Foreign Pollution

December 5, 2014

World PollutionCan anyone help me understand this?  I can’t figure it out.  Seems non-sensical.  It’s from EPA’s proposed ozone rule:

Foreign Pollution Quote in Proposed Ozone Rule

 O3 and O3-forming pollution from natural and international sources could prevent ambient levels from reaching attainment levels in locations where the impacts of such sources are large relative to the impact of controllable man-made sources of NOX and VOC emissions within the U.S., especially in locations with few remaining untapped opportunities for local emission reductions.”–U.S. EPA, Proposed Ozone Rule (see http://www.epa.gov/glo/pdfs/20141125proposal.pdf)

Does anyone understand this?  Even if the impacts of foreign pollution is small relative to the impacts of domestic pollution, foreign pollution can still affect attainment right?  For example, if domestic pollution is 70 ppb . .  foreign pollution is 1 ppb . . . and the standard is 70 ppb–then foreign pollution is still affecting attainment regardless of its relative importance, correct?

More head-scratching to me is the following scenario–which  no one other than me seems to have figured out:

Scenario:  If domestic pollution is 75 ppb . . . foreign pollution is 5 ppb . . . and the standard is 70 ppb but the State can implement RACM at let’s say $25k per ton to reduce pollution below 70 ppb–then even though foreign pollution is impacting attainment the pollution is not acknowledged but is simply offset by additional domestic controls regardless of the fact that the pollution could perhaps be reduced at $5k per ton at the foreign source.

It’s becoming “a small multi-pollutant world after all”.  Time to treat it as such.

The world is changing.  We must change with it.  Time to transform the SIP process.  We can make it happen.

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