Our local health department's air quality program administers the Clean Air Act within Lancaster County, Nebraska. Lancaster County is home to about 240,000 people and includes air pollution sources ranging from small drycleaners to Goodyear Tire and Rubber to grain elevators to a coal-fired power plant. We are currently in attainment of all National Ambient Air Quality Standards and anticipate remaining so. Our scope of activities includes all levels of air permitting, compliance inspections, enforcement, air toxics, collection of emission inventories, air quality planning and technical assistance. Our guiding principle is pollution prevention. We have a separately delegated Title V program supported by fees which we collect. We are an implementing agency for the Risk Management Planning program (112r). In summary, our local health department administrates a small air quality program which is experienced in administering a large range of air quality program activities.
The main message I bring to you today from Lincoln, Nebraska is that the Clean Air Act is working. It is holding the line on air emissions increases in our community. Title V permits, which contain all applicable air quality requirements in one document for easy reference, are causing regulated entities to pay closer attention to those requirements. Air toxics standards are being implemented and complied with. We have received virtually no complaints from the 120 regulated businesses in our community about the process or substance of Clean Air Act requirements. Light- and heavy-duty vehicle and low-sulfur fuel standards are coming on-line in the next few years which will reduce the air quality impact of increasing vehicle miles traveled which, in Lancaster County, is outpacing population growth by more than 3 to 1.
The secondary message I offer to you today is that there are some concepts we, as a local air quality program in a growing community, encourage Congress to consider as the Clean Air Act is reauthorized.
Prevention-based strategies. The Clean Air Act is a tool for public health risk reduction: the greater the air pollution reduction, the greater the risk reduction. Interestingly, the greatest air pollution reductions achieved in Lancaster County in the past 5 or 6 years were not mandated by the Clean Air Act. Between 1994 and 2000, a 53% reduction in hazardous air pollutants and a 43% reduction in volatile organic compounds occurred because of voluntary choices made by businesses to use less toxic materials and less-polluting processes. The coal-fired power plant in Lancaster County even reduced sulfur dioxide emissions by 2000 tons per year voluntarily by switching to ultra-low sulfur coal. These choices to prevent pollution rather than control it need to be encouraged and rewarded. Somehow, the lesson learned in Lancaster County, that significant environmental benefits occur through voluntary pollution prevention, needs to be applied to the Clean Air Act of the 21st century. Specifically, incentives for pollution prevention need to be incorporated for those regulated businesses willing to take that option or to go beyond the minimum air quality requirements.
Another area where prevention-based strategies are needed is in the area of maintaining clean air while cities grow. Lincoln is currently an attainment area. However, in the next 20-30 years, our population is likely to increase substantially. The land use choices and transportation plans made today may affect our ability to maintain non-attainment status in the future. The tools and funding to support assessment, innovation and "best management practices" to reduce air quality impacts of transportation should be available to communities like Lincoln that are trying to prevent unhealthy air as well as to areas that are solving air quality problems. Multi-Pollutant Strategies. The next version of the Clean Air Act needs to achieve risk reduction more efficiently and comprehensively by incorporating multi-pollutant control strategies. Certain source sectors, mainly combustion sources such as utilities and internal combustion engines (mobile and stationary), are significant sources of criteria and hazardous air pollutants and greenhouse gases. Harmonizing control options to simultaneously reduce all pollutants of concern for a particular sector is easier to implement for both industry and state/local regulatory agencies and is more cost-effective.
Examples of opportunities for better harmonization are plentiful. Coal-fired power plants have gone through separate requirements and permitting for acid rain and NOx reduction and are likely to face regulation for air toxics reduction. Similarly, the recent light- and heavy-duty vehicle and fuel standards are focused on ozone precursors. Had they been optimized to include air toxics reduction as well, a separate rule-making process under 202 (l) would not have been necessary. Reformulated gasoline (RFG), although intended for ozone reduction, has been effective in reducing levels of air toxics such as benzene, which national assessments indicate is a concern in every county in the United States. Yet, RFG may only be sold in ozone non-attainment areas. The next version of the Clean Air Act should be structured to enable multi-pollutant strategies for air pollution management.
Authorize State and Local Air Toxics Risk Reduction. The current Clean Air Act calls for a substantial reduction in cancer risk from air toxics in urban areas. To implement this, the U.S. Environmental Protection Agency (EPA) has drafted a strategy centered on identifying the pollutants and sources which contribute most significantly to public health risk based on national, regional or local-level assessments. In this draft strategy, EPA would address sources and risks ranking highly on a national-level assessment and States or localities would address risks and sources of high priority based on regional or local assessment. This is an efficient, common sense approach. Although EPA is authorized to reduce risk through national standards, the mandate and authority under the Clean Air Act for States or localities to require actions which reduce air toxics emissions identified as posing unacceptable health risk is unclear. Thus, in the reauthorized Clean Air Act, a clear mandate and authority for states and localities to cause risk-based reductions would assist our local community when national standards do not address our most pressing air toxics risks.
While other aspects of the Clean Air Act could be addressed, we have purposely limited our community's comments to these three key issues that we, as a local air quality program in Lincoln-Lancaster County, Nebraska believe are of utmost importance. Please keep prevention based strategies, multi-pollutant strategies, and authorizing state and local air toxics risk reduction in mind as you craft the reauthorization of the Clean Air Act.
Again, thank you for this opportunity to provide comments to this Subcommittee. We hope you will consider these concepts worthy of further study. I will be happy to answer any questions you may have.