This statement addresses gains in economic efficiency which could

be obtained by removing barriers to advances in the technology and

procedures commonly used for designing air pollution abatement strategies

Cass, Glen R.

McRae, Gregory J.

English

Caltech Authors - Main

A Statement to the 
NATIONAL COMMISSION ON AIR QUALITY 
For a hearing 
12 February 1979, Los Angeles, California 
Regarding 
THE DESIGN OF EFFICIENT AIR POLLUTION CONTROL STRATEGIES 
Gregory J. McRae 
and 
Glen R. Cass 
Environmental Quality Laboratory 
and 
Environmental Engineering Department 
California Institute of Technology 
Pasadena, California 91125 
Environmental Quality Laboratory 
Open File Report No. 79-1 
A Statement to the 
NATIONAL COMMISSION ON AIR QUALITY 
For a hearing 
12 February 1979 , Los Angeles, California 
Regarding 
THE DESIGN OF EFFICIENT AIR POLLUTION CONTROL STRATEGIES 
by 
Gregory J. McRae* and Glen R. Cass* 
1 . This statement addresses gains in economic efficiency which could 
be obtained by removing barriers to advances in the technology and 
procedures commonly used for designing air pollution abatement strategies . 
2. At the California Institute of Technology we are working on methods 
for defining t he least costly means of attaining air quality objectives 
for chemically reactive pollutants in multiple source urban environments . 
Our joint experience includes the analysis of trends in ambient air 
quali t y (Refs. 1,2,3) and design of air quality models for photochemical 
oxidants, nitrogen oxides (Refs . 4,5), sulfur dioxide, sulfates (Ref. 6) 
and other fine particulates . We act as consultants on air pollution 
control strategy design. Our work has been s ponsored or used by the 
California Air Resources Board, the South Coast Air Qualit y Management 
District, the U.S. Environmental Protection Agency and the U.S. 
Department of Energy. We wish to emphasize that our comments are 
given as individuals and not as representatives of Cal tech or any 
of the agencies which support our work . 
* Environmental Quality Laboratory and Environmental Engineering 
Science Department, California Institute of Technology, Pasadena , 
California, 91125. 
2. 
2. The National Commission on Air Quality is charged with studying 
and report ing to Congress on the economic, technological and environ-
mental consequences of pursuing the purposes and programs authorized 
by t he Clean Air Act . We wish to suggest areas for investigation by 
the Commission which could lead to more cost-effective pollution control 
strategies. 
It is possible with careful study and detailed evaluation of 
control alternatives to achieve enormous savings in pollution abatement 
costs. In a city the size of Los Angeles, there are large numbers of 
opportunities for emissions control. If one only guesses at an appropriate 
combination of abatement measures, it is clearly possible to spend a 
great deal more money on air pollution control than is actually necessary. 
For example, if one had made an intuitive selection between control 
measures contained in a recent South Coast Air Quality Management District 
report (Ref. 7 ), one could easily have spent hundreds of millions 
of dollars more annually to control sulfur oxides air pollution in 
this city than a careful analysis would show is actually needed. 
Control strategy studies costing about $200,000 (Ref. 6 and 7), however 
permitted an efficient choice between available alternatives in that 
case. Unfortunately, that level of planning effort is the exception 
rather than the rule in this country. While the methodologies for 
achieving such savings are available, there are three major barriers 
to their effective utilization: technology transfer, training and time. 
3. While from a research point of view there are still many areas 
of uncertainty, it is important to recognize that much more scientific 
information is available about how to control a complex air pollution 
3. 
problem than is routinely used to make air p ollution control strategy 
decisions . A question to ask, and one the Commision might consider 
further is: "Why is all this information not being effectively used 
to improve the Nation's air quality?" From our own experience, one 
reason is that not enough effort is being made to communicate advances 
in air quality control strategy design procedures to state and local 
agencies in a form that they can readily assimilate into their 
control programs. It is not sufficient to merely describe new findings 
in Federal reports and scientific journals . Prototype air pollution 
control strategy studies should be sponsored which introduce state 
and local air pollution control officials to advanced air quality 
planning procedures within the context of resolving some real emission 
control problems . 
4 . Immediate resolution of the technology transfer p r oblem will 
not be easy . At present there are an insufficient number of adequately 
trained people capable of performing full scale air pollution control 
strategy studies using the most advanced methods available . The 
problem is particularly bad in the case of photochemical oxidants. 
Photochemical oxidant air pollution, typically expressed as ozone, 
ranks today as one of the most serious and pervasive air pollution 
problems in the country . In 1975, about 86 percent (356 out of 416) 
of the ozone monitoring sites reporting to the National Aerometric 
Data Bank exceeded the National Ambient Air Quality Standard for 
ozone (Ref . 8). This must be contrasted with the observation that 
there are less than five (5) state or local agencies who are currently 
capable of rigorously evaluating the impact of a meteorologically 
and chemically explicit photochemical oxidant control strategy . 
4 . 
We do not feel that this situation arises from a lack of agency 
interest in oxidant air quality control. Rather, it arises from the 
fact that there are so few people trained to understand the design of 
emission control strategies for photochemical pollutants. 
5. Perhaps one reason why so little technical sophistication is 
exhibited in most air quality plans formulated to date is that the 
deadlines set by Congress for performing air quality analyses are 
impossibly short. The 1970 amendments to the Clean Air Act (Sec 110 
(a) (1)) provided a statutory deadline of nine months following 
adoption of an air quality standard for states and localities to form-
ulate a plan for attaining the air quality goal. From our experience, 
the time needed for a highly trained group of engineers to design a 
technically sound abatement plan for a single chemically reactive 
air pollution problem in a major city is about two to three years 
(not including time for administrative review and approval). 
If inexperienced personnel must be trained first, then the time required 
for planning increases proportionately. One set of State Implementation 
Plans was hurriedly solicited in t he early 1970's . A second round of 
Air Quality Maintenance Plans is currently under preparation; a 
step made necessary because many of the first plans failed to achieve 
their stated goals . By 1982, we expect a similar result and a new set 
of emission reduction measures will be sought. In ten years , we will 
have expended a great deal of effort on three consecutive unsuccessful 
clean up efforts devised under unreasonable time constraints. During 
that period there was enough time to develop at least one technically 
defensible air quality plan if the incentives and institutions had 
been different. 
5. 
6. We have confined our comments to a few notes on barriers that 
prevent currently available technology from being brought to bear 
effectively on air quality control decisions. These remarks should 
not be interpreted as our advocacy of a purely 'technological fix' 
to the nation's air pollution problems. Rather, we have chosen to 
comment on a few areas in which we have particular experience. The 
hope is that advances in engineering practice permitted by more 
technology transfe~ training and time will have beneficial results 
regardless of the system of direct regulation or economic incentives 
used to make air quality control decisions. 
v. 
References 
1. Trij onis, J . C. , Peng, T. K., McRae , G. J . and Lees , L . "Oxidant 
and Precursor Trends in the Metropolitan Los Angeles Region", 
Atmospheric Environment , ~, 197B , 1413-1420 . 
2 . Trijonis, J.C., Peng, T. K. , McRae, G. J . and Lees, L. "Emissions 
and Air Quality Trends in the South Coast Air Basin" , Environmental 
Quality Laboratory Memorandum No. 16, January 1976 . 
3. Cass, G. R. "Dimensions of the Los Angeles S02/Sulfate Problem", 
Environmental Quality Laboratory Memorandum No. 15, December 1975. 
4. McRae , G. J: , Goodin, W.R . and Seinfeld, J . H. "Development of a 
Mathematical Model for Photochemical Air Pollution, Draft final 
Report to the California Air Resources Board, February 1979. 
5. McRae, G. J., Goodin, W. R. and Seinfeld, J. H. "Development of a 
Mathematical Model for Photochemical Air Pollution", American 
Meteorological Society Forth Symposium on Atmospheric Turbulence, 
Diffusion and Air Quality, Reno , Nevada, January 1979. 
6. Cass, G. R. "Methods for Sulfate Air Quality Management with 
Applications to Los Angeles" , Ph . D. Thesis, California Institute 
of Technology, 197B, 2 volumes, BOI pp . 
7. South Coast Air Quality Management District, "Sulfur Dioxide/ 
Sulfate Control Study", Air Programs Division Report, May 197B. 
B. u.S. Environmental Protection Agency, "National Air Quality and 
Emissions Trends Report, 19 76", Report No. EPA-450/l-77-002. 


The design of efficient air pollution control strategies

Air Quality Management District, &quot;Sulfur Dioxide/ Sulfate Control Study&quot;, Air Programs Division Report,

Development of a Mathematical Model for Photochemical Air Pollution, Draft final Report to the California Air Resources Board,

Development of a Mathematical Model for Photochemical Air Pollution&quot;, American Meteorological Society Forth Symposium on Atmospheric Turbulence, Diffusion and Air Quality,

Dimensions of the Los Angeles S02/Sulfate Problem&quot;,

Methods for Sulfate Air Quality Management with Applications to Los Angeles&quot;

Oxidant and Precursor Trends in the Metropolitan Los Angeles Region&quot;, Atmospheric Environment

https://authors.library.caltech.edu/34541/1/EQL_No.79-1.pdf

The design of efficient air pollution control strategies

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