Connecticut has bad air.
Not the filthy, dirty, constantly sooty air it had in the 1970s and 1980s, when cars with minimal pollution controls burned high-sulfur gasoline and factories and coal- and oil-burning power plants shot black plumes skyward.
No, not that bad.
But data show Connecticut has some of the worst air quality on the East Coast and in the country — and it’s actually been getting worse in the last few years.
As the Environmental Protection Agency begins public hearings today on even tighter air quality standards, Connecticut not only isn’t meeting the current ones from 2008, the southwestern part of the state is no longer meeting the standards from 1997.
That same part of the state is also one of a handful of areas nationwide that the EPA projects are unlikely to meet the proposed standards by 2025.
The reasons why — coupled with mandates Connecticut is now under to fix its air problem — have re-intensified an on-going controversy. While the bad air is in Connecticut, a lot of it originated in other states and blew here. Connecticut continues to argue that the burden of cleaning things up should be on the states that cause the problem, a view that has made for tension with the EPA.
“We are extremely challenged because we are downwind,” said Anne Gobin, chief of the Bureau of Air Management at the state Department of Energy and Environmental Protection. “It’s location, location, location. We are in exactly the location where the air creates high levels of ozone.”
And ozone is the issue.
What and where it is, and how much is too much
We are talking about ground-level ozone – not the good ozone. The good ozone is the high-level ozone that protects the atmosphere and has had scientists worried — though not as much as they used to be — because of its thinning over Antarctica.
Ground-level ozone is nasty stuff. It’s a secondary pollutant created when emissions like nitrogen oxide (NOx) and volatile organic compounds (VOCs), which come from cars, power plants, industrial facilities and other sources — essentially cook in the hot summer sun.
The resulting ozone is a major component of smog, which can cause or worsen a number of health problems, especially asthma and other lung ailments. As science has revealed greater relationships between ozone and health, the EPA has been lowering the amount of ozone it will allow during the hottest months. In Connecticut, that’s May 1 through Sept. 30, though the new standards would lengthen that by at least two months.
In 1997, the standard was set at 84 parts per billion (ppb). In 2008 it was lowered to 75 ppb. And the new proposal is a range – 65 to 70 ppb.
Connecticut has greatly reduced its ozone levels from the 1980s when they would regularly top 120 ppb. And the number of days a year when average ozone levels exceed the limit has dropped from more than 100 to the teens and twenties, and occasionally to single digits – such as last summer, which was cooler than normal.
In 2009, Connecticut achieved the 1997 standard. The state is actually split. Fairfield, New Haven and Middlesex counties are part of a “greater New York City” zone that includes New York City, Long Island and parts of northern New Jersey. The rest of Connecticut is its own area.
In 2012, after some extremely hot summers, EPA declared all of Connecticut in “non-attainment” of the 2008 standard and ordered the state to meet it by the end of 2015. Even as plans were being formulated to do that, EPA declared the greater New York zone in non-attainment with the older 1997 standard, and in April 2014 began a process to require that it be brought back into attainment.
“We would work with those states to analyze what’s causing the problem and what short-term measures could be taken to mitigate pollution and help attain the standard as quickly as possible,” said Dave Conroy, the air program manager in the EPA’s Boston office, which oversees the six New England states.
But state officials have said repeatedly, and in some cases downright angrily, that lowering the ozone is something Connecticut can’t do without a lot of outside help – including from the EPA.
Where did all this pollution come from?
“Connecticut is tired of serving as the tailpipe of America,” Gov. Dannel P. Malloy said in a press release in December 2013. The occasion was a petition to the EPA to add nine states to the 12, including Connecticut, and the District of Columbia already in what is known as the Ozone Transport Region.
The region is a northeast and mid-Atlantic area that tends to be on the receiving end of air currents that carry emissions from coal-burning power plants, autos and other sources from states in the south and Midwest.
If those additional states — Illinois, Indiana, Kentucky, Ohio, Michigan, North Carolina, Tennessee, West Virginia and Virginia (part of which is already in the region) — were to be added, they too would be subject to regulations that would keep them from sending their emissions elsewhere.
Connecticut officials typically say more than 90 percent of the state’s pollution comes from out of state, but that’s along the shoreline. Inland counties have lower levels of imported emissions.
The state also produces its own NOx emissions — mostly from what’s known as the “mobile” sector. That includes on-road sources, such as cars and trucks, and non-road sources, such as boats, planes and trains.
Power plants contribute too, but in a far lower percentage than in the past because of a large-scale move to natural gas.
A big factor in Connecticut’s current ozone problem, and the reason for its backsliding, may be a shift in wind patterns.
“Connecticut is now basically taking the brunt of the direct impacts of pollution sources,” said Jeff Underhill, chief scientist for air resources in the New Hampshire Department of Environmental Services. He also is chairman of the modeling committee for the Ozone Transport Commission. The commission, made up of Ozone Transport Region states, works with the EPA to help devise regional solutions. His modeling, which uses big purple blobs to mark the worst pollution, shows a clear northern shift.
“A couple of years ago it was in Maryland where they were taking the biggest hits. Before that it was in parts of New York state and New Jersey,” he said. “The state of Maryland is almost in a state of shock because they went from having that purple dot to almost having the range completely gone very quickly.”
The question is whether the change, which involves upper- and lower-level air currents, is cyclical, or related to climate change.
“If it starts shifting back down south again, then we may just be in a normal cycle,” Underhill said. “But if it stays over Connecticut for several years, then we might have to open our eyes a little bit wider and see if there’s something more going on.”
States can do many things to lower ozone; changing the weather is not one of them.
And that gets us to the squabble.
Getting rid of ozone
A letter DEEP Commissioner Rob Klee sent to the EPA in June in response to the agency’s request for an updated plan to get Connecticut back in compliance with the 1997 standard said it all.
“DEEP believes that EPA, through this proposed action, falls short of addressing the root cause of Connecticut’s continued noncompliance,” the letter read. The letter defined that root cause as “unlawful levels of interstate air pollution.”
Calling that interstate pollution beyond Connecticut’s “regulatory reach,” DEEP called on the EPA to take action. “It is simply not equitable, just, or legal to assign Connecticut the responsibility for addressing a problem that Connecticut cannot successfully address,” the letter said.
The EPA’s Conroy was diplomatic, calling the problem “complicated.”
“What you will hear is frustration that this problem has proven to be so challenging, not adversarial,” he said. “It’s not like we’re picking on Connecticut, even though it does have the highest levels in the non-attainment area at this point in time.”
What has the state particularly incensed is that a regulation under the Clean Air Act — known as the good neighbor provision — isn’t being enforced.
“That requires all states to do a demonstration to EPA of how they are not contributing to another state’s non-attainment,” DEEP’s Gobin said. ”So EPA’s failure to address transport is a major problem.”
Conroy said Connecticut still has plenty of actions it could take. “A lot of things are still on the table,” he said. “Trucks, trains, marine vessels, further reductions from power plants — especially peaking units.”
Peaking units are essentially small, backup power plants that run only when electricity demand is high – like on the hottest summer days when air conditioners are cranked up. There are about 50 of them in Connecticut, about half of which run on diesel fuel. Another dozen or so run on another oil. And about 10 are old, dirty and have no emissions controls.
In addition, there is the Bridgeport Harbor Station power plant, which runs on coal. While it is not technically a peaking plant, in recent years it has generally run only when demand is high. While that is usually in winter, when there isn’t enough natural gas to run some of the natural gas plants, it was called into service in the extremely hot summer of 2012 when one unit at the Millstone Nuclear Power Station was shut down because its intake water in Long Island Sound had become too warm.
Bridgeport also has no add-on emissions controls, something it can get away with because of existing emissions trading and its use of a low-sulfur coal. The Sierra Club, in formal comments on Connecticut’s plans to meet the 2008 ozone standard, said Bridgeport was an obvious target.
“We certainly believe that there are some low-hanging fruit still in the state of Connecticut,” said Sierra Club attorney Joshua Berman, who wrote the comments. “And one of the first places I would look is at Bridgeport Harbor Station, which is one of the last remaining moderate-size coal plants in the east that lacks any add-on emission control.”
Berman also said the old peaking plants should be dealt with, along with just about anything else Connecticut can think of.
“We do really believe that a sort of ‘all-of-the-above’ approach is necessary for Connecticut at this point, given that it’s now achieved the worst air quality in the eastern United States. And that has to include looking at all the major sources of emissions, both in-state sources and out-of-state sources.”
Gobin said the state is working on a more stringent plan for NOx emissions from the state’s power plants and peaking units as well as industrial facilities, but he noted that their emissions are dwarfed by mobile sector emissions.
“I’m not discounting the power plants; I’m not saying we don’t need to focus on the Connecticut power plants — we do,” she said. “But that can’t be our whole focus. We have to look at this much more holistically.”
She said the state is also looking at an EPA program called SmartWay to help trucks move freight more efficiently while reducing emissions and saving money.
But she cautioned that changes need to be gradual and strategic. With the New England grid short on power because of plant shutdowns and limited natural gas supplies, any plan has to be careful not to push a power plant operator into shutting down rather than adding expensive emission controls.
The same goes for factories and other industrial operations that might decide to take their business to another state rather than spend money to clean up.
Worries for a long, hot summer
Meanwhile, a little help may finally be on the way upwind, even as the state worries about yet another – unexpected – ozone challenge.
As part of the “good neighbor” rule, the EPA in 2011 instituted the Cross-State Air Pollution Rule. It requires states to reduce power-plant emissions that contribute to ozone downwind. But it never went into effect because upwind states fought legal battles all the way to the U.S. Supreme Court.
Last year, the court ruled in EPA’s favor, and the first part of the cross-state rule is set to be implemented later this year; the second part in 2017.
It’s a start, Gobin and others said, cautioning again that it only affects power plants, not the much more polluting mobile sector. And in the interim, many of those plants have switched to less-polluting natural gas anyway.
But there’s been another, more concerning, change. Gasoline prices have plummeted to lows not seen in years. Coupled with an improving economy, many worry it will put more and larger cars on the road. If this summer turns out to be hot, that could make Connecticut’s ozone problems even worse.
“It’s a complex calculus trying to figure out exactly what the changing economy and changing fuel prices are going to bring to the Northeast,” said New Hampshire’s Underhill, whose own state stands to lose ground as well. “Hopefully that’s going to be offset somewhat by cleaner technologies for air pollution controls and cleaner gasolines, which are going to be phased in over the next couple of years.”
“I guess we’ll see what happens this summer, but it may very well be that the state’s not on track,” the EPA’s Conroy said. “The highest reading in the New York City area (including the three Connecticut counties) is an 85 ppb, and the 2008 standard is a 75 ppb, so that area has a long way to go given that its attainment date is just a year away.”
The worst penalty the state could face for being severely out of compliance is a loss of federal highway funds, though the EPA has never taken such action, and it is highly unlikely in this instance.
“I agree there is a long way to go,” Gobin said, but she again pointed elsewhere. “We can’t attain, even if we shut off all the emissions in Connecticut, if the transport piece of the puzzle isn’t addressed.
“I think it’s an issue of fairness for Connecticut. Continuing to require Connecticut to apply more and more regulations and not require that across the board when other states are contributing to our problem, and the root cause of our problem, is totally unfair.”