HomeMy WebLinkAboutMemo - Mail Packet - 10/1/2019 - Memorandum From Cassie Archuleta Re: Ozone - Nonattainment Status And Planning Update1
Environmental Services
222 Laporte Ave
Fort Collins, CO 80522
970.221.6600
970.224.6177 - fax
fcgov.com
MEMORANDUM
DATE: September 25, 2019
TO: Mayor and Councilmembers
THRU: Darin Atteberry, City Manager
Jeff Mihelich, Deputy City Manager
Jacqueline Kozak Thiel, Chief Sustainability Officer
Lindsay Ex, Interim Environmental Services Director
FROM: Cassie Archuleta, Environmental Program Manager
RE: Ozone – Nonattainment Status and Planning Update
The purpose of this memorandum is to respond to a request made at the September 16
Leadership Planning Team (LPT) meeting to provide Council with information regarding the
expected change in ozone nonattainment status for Fort Collins and the Northern Front Range.
Bottom Line
The Environmental Protection Agency (EPA) has proposed to downgrade the Denver Metro/North
Front Range area from a “moderate” to “serious” nonattainment status for ozone in December
2019. This means that, while ozone levels have not gotten worse, levels have not improved quickly
enough to meet EPA’s standard. As a result, State agencies are currently engaged in planning and
rulemaking efforts that will lead to more regulatory air pollution control measures to reduce ground-
level ozone by 2021.
Background
Ground-level ozone is an air pollutant which, at high levels, irritates respiratory organs and affects
plant growth. Ozone is not emitted directly into the air, but rather when pollutants such as nitrogen
oxides (NOX) and Volatile Organic Compounds (VOCs) react with each other to produce ozone.
The highest ozone levels are usually recorded in summer months on hot, stagnant days with little
wind.
The highest ozone levels measured in Fort Collins, and along much of the northern Front Range,
exceed health-based National Ambient Air Quality Standards (NAAQS) set by the EPA. The EPA
first designated this area as a nonattainment area in 2012, and failure to meet the standards
resulted in downgrading from “marginal” to “moderate” in 2016, with another downgrade from
“moderate” to “serious” expected December 2019. Each downgrade comes with new timelines for
attainment, along with more stringent statutory and regulatory requirements for pollutant sources.
At the State level, the Regional Air Quality Council (RAQC) leads planning efforts to review and
revise regulatory strategies to reduce ozone causing pollutants. In Fort Collins, the major
contributing sources to ozone include oil and gas production related emissions transported from
the southeast, and emissions from vehicles and other engine sources. New and expected
regulatory actions that will affect local ozone levels include:
• The State adopted new Low Emission Vehicle (LEV) standards in November 2018, and
new Zero Emission Vehicle (ZEV) standards in August 2019. These rules apply to new
vehicles sold in Colorado beginning with Model Year 2022.
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• The State is undergoing rulemakings to reduce VOC emissions from oil and gas, in part to
lower emissions for ozone attainment planning, and in part because of new requirements
per Senate Bill 19-181 concerning oil and gas operations, which calls for adoption of new
rules that minimize emissions of VOCs, and NOX from oil and gas operations.
Beyond the Federal and State regulatory role in protecting and improving air quality, the City
engages in strategies and actions that can lead to air quality improvements, including:
• Transportation and land use planning, including planning to meet climate goals for
transportation sources, as fossil fuel use from transportation is a primary source of both air
pollutants and greenhouse gases.
• Developing and administering public information and outreach, incentive and engagement
programs regarding air quality and air pollution prevention and control. As an example, a
new ozone monitoring and education exhibit was installed at the Gardens on Spring Creek
in 2018.
• Leading by example, by integrating air quality impact considerations in City operations.
Examples include strategies and efforts to convert municipal fleet vehicles and and lawn
and garden maintenance equipment to electric alternatives.
Continuing Efforts
Continuing efforts are necessary to meet ozone standards, and Fort Collins, as well as the rest of
the Front Range, face challenges related to population growth, transportation demand, and major
industry sources such as oil and gas operations. This effort is aligned with Council’s air quality
priority to reduce ground level ozone, and continuing efforts will include:
• Air Quality Plan Update - The 2019 City Plan update included several air quality
strategies, including updates to the City’s Air Quality Plan. The Air Quality Plan is updated
administratively, and anticipated 2019/2020 updates will include several new and emerging
strategies related to ozone attainment, such as increased focus on ozone causing pollution
sources (transportation, oil and gas, and other engine sources), air quality monitoring and
reporting, increased efforts to reduce emissions from City operations, and additional
education and outreach about consumer choices and community actions that can lead to
pollution reduction.
• Regional Regulatory Actions – Per the City’s 2019 Legislative Policy Agenda (LPA), the
City will continue to monitor and engage in RAQC deliberations, and legislative action at the
State level related to vehicles, oil and gas development, and other rulemakings related to
air pollution sources. The State is required to submit an implementation plan to the EPA by
May 31, 2021.
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