Utility perspective on ozone reduction in the eastern US

The 1990 Clean Air Act Amendments mandated significant new efforts to achieve reductions in ozone precursors and attainment with the standard. The states have bought into the EPA process and formed the Ozone Transport Assessment Group (OTAG) to get new answers and help towards an eventual solution. A major target in these efforts is nitrogen oxide emissions from fossil-fuel fired utility boilers. In fact, utility NO_x emissions are targets of several EPA efforts including: reductions in acid deposition; attainment with the current ozone standard; attainment with proposed and perceived new ozone and fine particulate standards; progress in achieving visibility goals and mandates; and, even eutrophication concerns. Additionally, NO_x emission reductions have entered the electric utility competition tidal wave being the issue in the environmental impact statement related to the recently issued FERC open access rules. EPA continues to advocate massive utility NO_x controls through implementation initiatives and programs. These programs and initiatives are generally premature to the science debates that will be part of OTAG and proposed new ambient standards. The expectation that regional control of utility NO_x emissions will provide significant relief from the intractable problem of achieving attainment with ozone standards is at best an expectation with little scientific basis and probably closer to a sincere hope of environmental agencies with little control of the issues that contribute to ozone nonattainment. This paper details these issues and gives an electric utility perspective