CARB Consumer & Commercial Products Survey And Related Air Quality Issues

Transcription

1 CARB Consumer & Commercial Products Survey And Related Air Quality Issues D. Douglas Fratz Senior Science Fellow & Aerosol Products Division Staff Executive March 19, 2015 SATA 2015 Spring Meeting Marriott Perimeter Center Atlanta, Georgia Washington, DC - USA

2 Today s Presentation CARB 2013/2014/2015 Consumer & Commercial Product Surveys 2016 California Ozone SIP & South Coast AQMP ACP-Based Voluntary Measure CARB and Industry LVP/VOC Fate Research VOC Compliance Initiatives EPA SNAP Proposal HFC Phase Down EPA Ozone Standard Revision

3 CARB s Stated Purposes for the 2013/2014/2015 Surveys Emissions Inventory Update VOC Emissions and LVP-VOC Emissions 2016 State Implementation Plan Measures Support LVP Research and Policies Future Consumer Product Regulations

4 CSPA Estimates of the Scope of CARB s Proposed Survey CARB 2006 Survey CARB Proposed 2013 Survey 100 Product Categories 490+ Product Categories 20,000-30,000 Products 300, ,000 Products About 500 Companies 3000 Companies Data Points/Product Data Points/Product More Than Two Years Required Some CBI Sensitivity About $5 Million Industry Costs One Year s Data 90 Days to Complete Forms Massive CBI Collection At Least $50 million/year Three Year s Data

5 CSPA Negotiation Results Key Wins Numerous Products Categories Removed Grouping for Non-Volatile Ingredients No Reporting of Fragrance Components Included CSPA List of Semi-Volatile LVPs Others Grouped Product Formulation Grouping CBI Claims Facilitated Less Reporting for Aerosol Coatings Commitment to Consider Extension Requests Fixed Numerous Problems in Software Tools

6 Product Sectors Not Previously Surveyed Scented Candles Arts & Craft Supplies Aerosol Foods Fuels (Other Than Lighter Fluids) Non-FIFRA Lawn & Garden and Pet Care Products Office Supplies Pool/Spa/Jacuzzi/Pond Products Health Use Products (External OTC Drugs) Numerous Products in Other Sector Categories

7 CARB Survey Extensions CSPA Meeting with CARB on February 12 CARB Extension Policy Announced February Days for Formulators (April 1) 120 Days for Small Businesses (July 1) Responsible Parties Extensions on Request All Requests Were Granted But 30 Days Only Potential Issue: Enforcement for Late/No Submission? CSPA Will Work to Protect Members From Fines

8 2013 Survey Data Quality Review Discussed at CSPA/CARB Meeting 2/12/15 CARB Wants to Complete Review by December Intends to Update Inventory for 2016 SIP! CSPA Will Propose QC Process Involving Industry Review Companies Reporting by Sector Remove Industrial Products/ Others Outside Scope Correct Product Categorizations Correct Ingredient Categorizations Correct Product Form Categorizations Other Corrections Impacting Inventory

9 CARB Schedule for 2014/2015 Surveys 2014 Sales Data and New Formulations Survey Begins July 2015 Submission Deadline November Sales Data and New Formulations Survey Begins July 2016 Submission Deadline November 2016

10 CSPA Plans to Negotiate 2014/2015 Survey Changes Discussed at CSPA/CARB Meeting 2/12/15 Goals: Reduce Paperwork Burden and CBI Risks Possible Changes: Remove Non/Minimal-VOC Product Categories Flexible Definition for New Products Flexible Definition for New Formulations Grouping of Sales Data by Category No Reporting for Minimal Sales Changes? More Grouping of Ingredients

11 2016 CARB SIP/ SCAQMD AQMP 75 ppb Ozone Standard (Current SIP 84 ppb) Attainment in South Coast in 2031 Due to EPA in July 2016 South Coast and CARB Attainment Modeling Already Started Further Reductions: Up to 90% NOx and 50% VOCs? SCAQMD Public Process Begins Later This Year VOC White Paper Workgroup AQMP Workgroup CARB SIP Process to Follow AQMP Process Not Clear How Survey Data/ LVP Research Will be Used

12 CSPA Conceptual Proposal for ACP-Based Voluntary Reduction Measure CARB Alternative Compliance Plan Excess VOC Reductions Occur Each Year Few Companies Using (Paperwork Burdens) CSPA Conceptual Proposal Voluntary and Emerging Measure Capture Excess Reductions as SIP Credit Include Bundled Measure in 2016 SIP CSPA Working to Secure EPA Approval

13 Defense of the LVP Exemption South Coast Objecting to CARB LVP Exemption CSPA and Broad Industry Coalition (ARR) was Formed to Defend CARB Funding $600,000 in LVP Studies Chamber Studies at UC-Riverside Fate Modeling at UC-Davis ARR Funding Complimentary LVP/VOC Research Fate Modeling by SENES (ACC-Funded) Emissions Inventory Assessment by UC-Riverside (ARR-Funded)

14 Update on CARB-Funded Research UC Riverside Chamber Studies LVP Evaporation Studies/ Product Formulations Chamber Photochemistry: Ozone and PM CSPA Members Providing Formulations/Materials CSPA Seeking More Real-Life Chamber Conditions Contract Ends September 2016 UC Davis Environmental Fate Modeling Fate for LVPs Emitted in Air or Water Modeling Completed/ Draft Report Completion Targeted for September 2015 CARB Conference Call Update Scheduled for March 24 CSPA and ARR Science Team will Comment on Studies CARB Research Screening Committee Approval

15 Completed ARR-Funded LVP/VOC Research SENES LVP/VOC Environmental Fate Modeling 43 VOCs, 9 Exempted VOCs, 23 LVPs Environmental Fate: Air/Water/Soil/Sediments Most Consumer Product LVPs and VOCs Partition Out of Air to Water, Soil or Sediment (Less Ozone Formation) Results Often Very Different from CARB UCD Modeling CSPA and ARR Science Team Seeking to Explain Differences

16 Completed ARR-Funded LVP/VOC Research UC Riverside VOC Emissions Inventory Study Current CARB VOC Emissions Inventory for Consumer Products and Architectural Coatings 280 TPD 35% of coatings, 10% of personal care, and 17% of CSPA Products VOC emissions in Inventory are LVP-VOCs Inventory Chemicals Thermodynamic Properties Predictive of Alternative (Non-Air) Fate Potential for Most VOCs/LVPs Down-the-Drain, Combusted, Solid Waste, Polymer Film, Collected as Waste Solvent, Partitions to Water or Surfaces

17 Further ARR-Funded LVP/VOC Research Possible Further Studies Could Include: Assessment by SENES of UCD Modeling Study Results Chamber Studies or Modeling of Indoor Fates Further Studies on Outdoor LVP/VOC (Non-Air) Fates Air Quality Modeling of Ozone Impacts for LVPs/VOCs ARR Science Team Plans to Make Recommendations on Further Research After March 24 th Update on CARB Research

18 VOC Compliance Initiatives Retailer VOC Compliance CSPA Work with The WERCS Plans for CSPA Retailer Compliance Conference CSPA Request for Guidance/Advisories Discussed at CSPA/CARB 2/12/15 Meeting Labeling Multiple Dilutions for Multiple Limits CARB Product Category Determination Form

19 EPA SNAP Proposal HFC Phase Down EPA Significant New Alternatives Policy Program Proposed Rule to De-List HFC-134a Uses (8/6/14) CSPA Meetings with EPA SNAP Officials CSPA Comments Filed October 20,2014 Support Retaining Critical Uses of 134a Urged Extending Deadline to 1/1/18 & 1/1/17 (From 1/1/16) Asked that Variance Procedure Be Adopted Final Rule Expected in July or August 2015 EPA Developing USA GHG Inventory Projections EPA/DOS Seeking Montreal Protocol Revisions for HFCs

20 EPA Ozone Standard Revision Health-Based Standard Supreme Court: Economics Not Considered Proposed to Lower to ppb (12/17/14) NGOs Advocating 60 ppb Nonattainment in 45 states? Approaching Background Levels NAM Annual Cost Estimate: $140 Billion $1.7 Trillion loss in GDP 1.4 Million Jobs Lost Final Rule in September 2015

21 CSPA Actions to Date CSPA Comments to EPA Against Lowering Standard in 2010 Coordinating Efforts with Major NAM-led Coalition Grass-Roots Campaign to Engage State Officials Conducted Extensive Economic Impact Assessment Support for Newly Introduced Federal Legislation Participated in SBA Roundtable (1/23/15) Testified at EPA Hearing (1/29/15) CSPA Comments to EPA on New Proposal (3/17/15) Urged EPA to Retain 75 ppb Standard Allow States to Implement Current Standard First Experience in Implementation Will Help Determine What Measures are Effective (and Cost-Effective) in Further Lowering Ozone

22 Summary and Conclusions 2015 will be a critical year Many issues need to be resolved They will not resolve themselves. GET INVOLVED!

23 Thank You! Questions? D. DOUGLAS FRATZ Senior Science Fellow & Aerosol Products Division Staff Executive Consumer Specialty Products Association Washington, DC - USA