The Issue
U.S. EPA will soon officially rule that the air in certain areas of Ohio is not healthy to breathe due to excess levels of small airborne particulates (PM2.5) and of ground-level ozone smog. Those unhealthy areas will be designated "nonattainment" areas. Any area in Ohio that is designated nonattainment must meet tough new federal Clean Air Act requirements for controlling PM2.5 and ozone. If any geographical area within the State of Ohio is designated nonattainment, Ohio EPA has until 2007 to develop and submit to U.S. EPA a detailed plan that will describe how all nonattainment areas will implement strategies to attain compliance with national ambient air quality standards (NAAQS). Implementation deadlines range from 2007 to 2014 and Ohio and its nonattainment areas may face severe penalties if the NAAQS are not attained on time.

The Air Here and Now
Here are U.S. EPA's deadlines for designating these areas and the new standards:

• Fine Particulates (15 micrograms per cubic meter: annual average) by December 31, 2004
• Ozone (80 parts per billion: 8-hour average) by April 15, 2004

Based on current monitoring data, the following counties are not expected by Ohio EPA to meet the NAAQS for either PM2.5 or ozone when EPA formally identifies non-attainment areas next year:

• 8-hr ozone -- Hamilton, Clermont, Butler, Warren, Clinton, Mongtomery, Greene, Miami, Clark, Madison, Franklin, Delaware, Know, Licking, Fairfield, Lawrence, Washington, Jefferson, Columbiana, Stark, Mahoning, Trumbull, Ashtabula, Lake, Geauga, Portage, Summit, Medina, Lorain, Cuyahoga, Lucas, Wood.
• PM2.5 list -- Lucas, Hamilton, Butler, Montgomery, Clark, Franklin, Scioto, Lawrence, Lorain, Cuyahoga, Jefferson, Stark, Summit, Portage, Trumbull, Mahoning.

A large percentage of the air pollution that causes PM2.5 and ozone is emitted by coal-fired power plants (both in Ohio and in upwind areas) and by older diesel buses and trucks and construction and other off-road equipment.

The Stakes for Health and the Economy
In Ohio, fine particles from fossil fuel power plants contribute to an estimated 1,900 premature deaths each year according to a study by Abt Associates, the firm the conducts health benefits analysis for the USEPA. A study by the (STAPPA/ALAPCO) determined that fine particulate emissions just from non-road diesel engines, such as construction equipment, contributes to 340 premature deaths in Ohio each year. PM2.5 penetrates deep into the lungs, making asthma more severe, causing chronic bronchitis, degrading lung function, aggravating cardiovascular disease and potentially triggering heart attacks. Particulate matter from diesel engines has been found by a number of authorities to be a probable carcinogen.

Ozone may lead to death and serious illness. Ozone inflames lung passages and makes breathing difficult. It can trigger asthma attacks, and it increases susceptibility to respiratory illness and respiratory-related hospital visits. Repeated exposure to high ozone levels permanently damages the lungs.

Children, the elderly and those with existing lung disease face increased risk from both PM2.5 and ozone.

Illness caused by respiratory distress related to air pollution is results in work absenteeism and lost productivity. Particulates and ozone smog contribute to the regional haze that blankets our national parks and forests, impairing the clear views that attract tourists. Ozone also damages crops and forests. And NOx and PM2.5 also contributes to the acidification and nitrification of our lakes, rivers and streams.

Federal nonattainment designation also can harm the local economy less directly but with equal force. In Ohio, here are some of the potential impacts:

• General stigma that area air quality has been judged unhealthy;
• Disincentive to business development, because:
  • New industry cannot locate here unless it offsets its own emissions and more;
  • There is an increased possibility of future emission control expense.
• The effects of potential federal sanctions for noncompliance include:
  • Higher emission offset ratios (2:1);
  • Cutoff of federal highway dollars;
  • Redesignation of the area to a more severe classification-additional control measures required in exchange for additional time to attain standard.

The Challenge
Ohio EPA must develop and submit to U.S. EPA a State Implementation Plan - a "SIP" - describing how it will meet the new PM2.5 and ozone standards. Ohio's SIP is due in four years from the date of a nonattainment designation. Compliance with federal standards is required soon thereafter. Pollution controls must be in place three years prior to the compliance deadline.

	Pollution Controls in Place	SIP Required	Attainment Required
Fine Particulates	2006	2007	2009
Ozone	2004-2010+	2007	2007-2013+ depending on severity of non-attainment designation

The Opportunity
Two major emission sources could provide most of the reductions that Ohio needs to develop a sensible pollution-control strategy that will deliver clean air at reasonable cost. They are:

• Coal-fired power plants (particularly units more than 25 years old)
• Heavy-duty diesel equipment (particularly older buses, trucks, off-road and construction equipment).

The Current Federal Plan
Power Plants: Nationally, power plants emit 63% of the sulfur dioxide (SO2) that contributes to PM2.5, and 21% of the oxides of nitrogen (NOx) that help to form both PM2.5 and ozone. In Ohio, power plants account for an even greater percentage of these pollutants, 86% and 37% respectively. Unfortunately, the administration's proposed national legislation gives plants a decade and a half to realize only modest cutbacks in SO2 and NOx.

Heavy-Duty Diesel: Nationwide, diesel engines are responsible for 25% of all NOx emissions and 15% of all PM2.5 emissions. Existing on- and off-road diesel engines that power buses, heavy trucks, construction and other equipment are major PM2.5 emitters. Yet many will operate for two to three decades, or even more. Current enacted and proposed federal regulations, while a good step, will not fully address the problem until 2030.

The Better Alternatives
Power Plants: U.S. EPA's own program model, as well as pending national legislation filed by Sen. Thomas R. Carper of Delaware [107th Cong., S. 3135], and Sen. James M. Jeffords of Vermont [108th Cong., S. 366] would cut PM2.5 emissions by up to 50% more than the current administration's Clear Skies proposal, and do it 8 years earlier. Compared to Clear Skies, this approach by 2020 would prevent an additional 12,000 premature deaths and save an additional $90 billion - every year. The benefit/cost ratio is 30% more favorable, as well.

Heavy-Duty Diesel: Reductions of up to 90% in PM2.5 emissions from existing diesel engines could be achieved by the end of the decade by using retrofit equipment that is available and cost-effective today. For example, catalyzed diesel particulate filters can reduce PM emissions by over 90% (as well as toxic hydrocarbons and carbon monoxide by similar amounts) when using ultra-low sulfur diesel fuel; they cost about $7500, depending on the size of the retrofit. Diesel oxidation catalysts are less expensive, but reduce PM only by about 20-50%. Retrofits of existing diesel engines will produce needed emissions reductions far earlier than those promised by recently adopted federal highway diesel regulations and recently proposed federal non-road diesel equipment regulations.

A Suggested Strategy
Ohio can avoid costly federal mandates and legal challenges by adopting a strategy that supports stronger yet cost-effective measures to control pollution from power plants and from heavy diesel equipment. It should:

• Join the national fight for tougher power plant legislation from Congress;
• Urge U.S. EPA to implement new, stronger rules to address the interstate transport of fine particulates and ozone smog;
• Analyze the costs of noncompliance with the new federal PM2.5 and O3 standards;
• Develop local or statewide programs to control emissions (especially PM2.5) from older, high-polluting diesel engines;
• Take steps to accelerate the availability of ultra-low sulfur diesel fuel in Ohio (it will be widely available for highway diesels by fall 2007 per U.S. EPA regulations); and
• Work with local and regional public health groups to deploy a strategy that gets the message across to Washington.

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