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Colorado Department
of Public Health
REGIONAL AIR QUALITY COUNCIL and Environment
June 15,2005
MEMORANDUM
TO: Signatories to the Early Action Compact for Ozone for the Front Range
Metropolitan Area
Regional Air Quality Council
Jim Scherer, Chairman .
Air Quality Control Commission
Robert E. Brady, Jr., Chairman
Colorado Department of Public Health and Environment
Douglas H. Benevento, Executive Director
Colorado Department of Transportation
Thomas Norton, Executive Director
Denver Regional Council of Governments
Lorraine Anderson, Chairman
U.S. Environmental Protection Agency,Region 8
Robert E. Roberts, Regional Administrator
Elbert County,Board of County Commissioners
Stephen F. Stutz, Chair
Larimer County, Board of County Commissioners
Kathay Rennels, Chair
Morgan County,Board of Commissioners
Michael Harms, Chair
Weld County,Board of County Commissioners
Rob Masden, Chair
IN RE: June 30, 2005 Progress Report
In accordance with terms of the Early Action Compact for Ozone for the Front Range
Metropolitan Area, please find attached a report that documents progress in stakeholder
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development, securing of local control measures, public outreach and modeling/technical
planning activities, etc. This report meets the June 30, 2005 milestone specified in the Compact.
This June 30, 2005 Progress Report addresses progress towards implementation of Ozone Action
Plan control strategies, the Denver Metro areas voluntary response to the 8-hour ozone issue and
planning activities in the North Front Range to ensure cooperation in terms of possible
Conformity issues and coordination of voluntary control programs, if necessary.
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Ken Lloyd, Exe.u ye Director Margib"Perkins,Director
Regional Air Quality Council Air Pollution Control Division
cc: Doug Lempke, Air Quality Control Commission
Lisa Silva, Air Pollution Control Division
Mike Silverstein, Air Pollution Control Division
Ann Skinner, Colorado Department of Transportation
Jeff May, Denver Regional Council of Governments
Dick Long, EPA Region 8
Tim Russ, EPA Region 8
Jerry Dilley, RAQC
Ozone Early Action Compact
Denver Metro Area
June 30, 2005 Progress Report
June 23, 2005
Introduction
In December 2002 state and local agencies in the Denver area entered into an Ozone
Early Action Compact (EAC) with the Environmental Protection Agency (EPA). The
Compact is a Memorandum of Agreement between the Regional Air Quality Council
(RAQC), the Colorado Department of Public Health and Environment (CDPHE), the Air
Quality Control Commission (AQCC), the Denver Regional Council of Governments
(DRCOG), the Colorado Department of Transportation (CDOT), and EPA Region 8. The
EAC was amended in 2004 with additional signatories for Elbert, Larimer, Morgan and
Weld Counties, areas potentially affected by ozone nonattainment.
The Compact entails a commitment to develop and implement an Ozone Action Plan in
return for deferring any potential non-attainment designation for the EPA's 8-hour ozone
standard. The EAC outlines several planning milestones (including progress reports
every 6 months) that must be met, culminating in attainment of the 8-hour standard by
December 2007. The June 30, 2004 Progress Report was prepared demonstrating that an
Ozone Action Plan, emission control regulations, and supporting documentation had been
completed and adopted by the State authority, the Colorado AQCC. The adopted plan
and regulations were subsequently reviewed and approved by the Colorado State
Legislature and the bill approving the plan and regulations was signed into law by the
Governor of Colorado in May 2004.
The December 31, 2004 Progress Report addressed the disposition of comments received
from the EPA in August 2004 regarding recommendations for revisions to emission
control regulation, Air Quality Regulation No.7, to provide clarity and ensure
approvability of the Ozone Action Plan, and a necessary change to the Ambient Air
Quality Standards regulation to define the 8-hour ozone control area.
This June 30, 2005 Progress Report addresses progress towards implementation of Ozone
Action Plan control strategies, the Denver Metro area's voluntary response to the 8-hour
ozone issue and planning activities in the North Front Range to ensure cooperation in
terms of possible Conformity issues and coordination of voluntary control programs, if
necessary.
Updates on Activities Related to the EAC
Progress made toward adoption and implementation of local measures, including
schedule for adoption and implementation of these measures, any changes in the
schedule, and any additions or deletions of measures since submission of December
31, 2004 progress report:
The revisions to Air Quality Regulation. No. 7 discussed above received
legislative approval in January 2005 and were submitted to the EPA by the
Governor on March 24, 2005. These revisions did not add or delete any control
measures in the state approved Ozone Action Plan. There have been no changes
in the schedule or any additions or deletions of measures since the last progress
report.
A letter of commitment to periodic assessment of assumptions of emissions and
modeling assumptions in the OAP was sent to the EPA March 22, 2005;AQCC
action to revise the OAP with this periodic assessment is scheduled for August
2005.
The EPA proposed approval of the Ozone Action Plan in the Federal Register on
May 17, 2005 (see 70 FR 28239). The comment period closed on June 16, 2005
with no comments received
The EPA 's deferred effective date of ozone designation for the region was
proposed in the Federal Register on June 8, 2005 (see 70 FR 33409). The
comment period closes July 8, 2005.
CDPHE Stationary Sources Program staff met with Oil & Gas industry
representatives on May 23rd to discuss progress on EAC OAP control measure
implementation. All company representatives indicated they have met the initial
reduction targets for this year and are documenting the results of their efforts.
The first report of VOC reductions required by Reg. 7 is not due until April of'06.
The operators also indicated that the flares they have installed appear to be
highly reliable and generally operate well. Some companies reported they are
installing vapor recovery units(VRU) instead offlares where it is feasible to do
so. This allows them to recover a saleable product, thereby recovering a portion
of the added cost of installing VRU's.
Voluntary Ozone Outreach and Education Program
The Regional Air Quality Council's (RAQC)planning process identified a need
for much greater public outreach and education on ozone pollution. Increased
citizen understanding and awareness of the causes and solutions for ozone
pollution is an important element of the region's ozone strategy. However, no
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emissions reduction credit has been taken in the EAC Ozone Action Plan for this
voluntary program
While the RAQC's past outreach efforts have been effective in bringing together
stakeholders and identifying ozone reduction strategies, it has struggled with
raising overall awareness due to the budget constraints under which it has
operated since the program's inception in 1999. With the addition of Congestion
Mitigation/Air Quality funding, the RAQC and its partners are able to
dramatically increase their public education and outreach efforts.
The Voluntary Ozone Outreach and Education Program encompasses large-scale
outreach, advertising, education, and evaluation components in order to raise
public awareness and education about ozone issues and increase the number of
people undertaking voluntary ozone reduction steps. In addition, it will assist
with the promotion of the RAQC's high-emitting vehicle outreach project, Repair
Your Air.
The four main components of the program are briefly described in detail below:
Media Outreach and Advertising
The RAQC has developed an extensive media-advertising program with outside
assistance to raise public awareness about ozone solutions, with emphasis on
those involving motor vehicles. The three-year summer campaign beginning in
June 2005 uses a multi-media approach utilizing television, radio, print, and web-
based advertising and public information. Each ozone season will begin with a
large-scale kick-off/press event,followed by ongoing advertising and outreach.
The RAQC will continue to work closely with its local government partners in
implementing public communication efforts for their citizens and employees.
Citizen Outreach
The RAQC has been conducting public and community outreach with regards to
ozone pollution for six years. The RAQC has used its experience with conducting
outreach to the "average"person to determine what types of events are
successful. Citizen outreach includes Car Care Fairs and participation in
community events.
Local Government Outreach
Since the inception of the ozone outreach program, RAQC has been working
closely and cooperatively with Denver-area local governments, both in the public
information and operations areas. As part of this program, RAQC will not only
continue its past efforts, but also expand its outreach efforts to local governments
to encourage increased participation in educating their respective communities
and employees about ozone pollution and effective reduction strategies. The
RA QC has identified 10 area local governments to participate in afleet gas cap
testing program this summer. The results of the program will be available in
September 2005. In addition, the RAQC is encouraging local governments to
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increase their ozone outreach and education efforts by providing small grants to
those governments that submit creative proposals.
Analysis and Reporting
With financial assistance through the CM/AQ grant program, the RAQC is able to
work with a professional firm to conduct a pre and post study to determine the
effectiveness of the increased outreach and education efforts in affecting behavior
change among the public. The RAQC conducted pre-campaign research in
Spring 2005 that consisted of a telephone survey and two focus groups. Post-
campaign research will begin in September.
For more information about the Voluntary Ozone Outreach and Education
Program, visitwww.ozoneaware.org.
Progress made in completing technical analyses for attainment demonstration due
December 31, 2004, including any additional modeling or analyses since submission
of March 31, 2004 plans:
The technical analysis that supports the approved Ozone Action Plan was
completed in early March 2004 and was included in the submittal to the EPA in
fulfillment of the required March 31, 2004 milestone. The Technical Support
Document has been provided to EPA Region 8 on CD-ROM and is posted on the
Air Pollution Control Division's website, http://apcd.state.co.us/documents/eac/
All supporting reports are included in the Technical Support Document
referenced above, as well as on the RAQC website,
www.ragc.org/ozone/EAC/ozone-eac.htm. No additional modeling or analyses
has been completed beyond which is referenced in the original TSD.
A draft technical report by Environ that addressed model sensitivity was
submitted February 11, 2005 to the RAQC and APCD. The modeling platform
continues to demonstrate unresponsiveness to small refinements in the sensitivity
analyses, although it meets most of the EPA evaluation protocols.
The Ethanol Management Company sponsored a draft report by Environ dated
April 7, 2005 which sought to photochemically model the effects of the use of
ethanol blends in gasoline on ozone concentration in the Denver region. The
results of the analysis were negligible reductions/increases in ozone
concentration across the Front Range. However there continues to be uncertainty
about the results because of the importance of ethanol in increased evaporative
emissions, and the inability of current tools to precisely quant fy evaporative
emissions and the lack of sensitivity to inventory changes in the modeling
platform.
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Updates on meetings conducted by the stakeholders since December 31,2004:
The Regional Air Quality Council has embarked on a significant Voluntary Ozone
Outreach and Education Program as noted above. The RAQC Board met
formally on February 3, 2005, April 7, 2005 and May 5, 2005 to receive staff
input on the program development, give overall direction and approve contracts
for professional marketing and advertising assistance.
The Multi-Jurisdictional I/M Transition Committee, comprised of stafffrom the
City of Fort Collins, the North Front Range MPO, Pikes Peak Area Council of
Governments (PPACG), the Emissions Coalition of Colorado Springs, the
CDPHE and the RAQC, has been formed to foster cooperation and coordination
along the north Front Range in terms of potential voluntary programs to replace
the I/M programs that are being removed from the CO SIPs for the City of Fort
Collins, Colorado Springs and Greeley. The committee has met four times since
December 31, 2004 as follows: March 16th, April 6`h, May 6`h and June Is'.
The CDPHE hosted a meeting of stafffrom CDOT, DRCOG PPACG, the North
Front Range MPO, the City of Fort Collins and the RAQC on May 20, 2005 to
review revisions to Colorado's Conformity regulation. The proposed revision is
an update to conform to federal Conformity regulation and to address possible
needs for cooperation and coordination among Front Range MPO's and lead air
quality planning agencies in the event 8-hour ozone remains a SIP issue and
becomes a Conformity issue.
Updates on current progress of the State's development of the SIP (due
December 31, 2004), including schedule for adoption and implementation of State
regulations, as well as a description of public meetings and/or hearings that have
occurred or will be conducted prior to SIP submission:
The approved plan and TSD was submitted to EPA by the Governor of Colorado
in August 2004.
Since the SIP has been completed and the necessary regulations have been
adopted and revised per EPA comments as discussed above, there are no
additional meetings planned.
Updates on any obstacles toward completing the December 31,2004 milestone or
any future milestones:
Since the Ozone Action Plan has been approved by the AQCC and approved by
the General Assembly, the plan is complete, at this time. Also since the regulatory
revisions discussed above improve the approvability of the OAP and neither add
or delete any controls, there are no obstacles anticipated to meeting the future
milestones. Additionally, as noted above, the oil and gas industry reports good
progress installing the required controls in a timely fashion.
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