That’s a big deal because the Clean Air Act generally requires each state and EPA region to implement best-in-class pollution controls in each planning cycle, based on the development of rules and technology nationally. Good policy in one part of the country should be considered and replicated in plans across the country. So, when the EPA reviews plans for the National Ambient Air Quality Standards (NAAQS), regulating ozone and particulate matter, it has a chance to work with state and local leaders to decrease air pollution from buildings. And that’s just what’s happening.
A recent development in the San Joaquin Valley region of California shows how the Clean Air Act rules can be leveraged to advance climate action. Because the San Joaquin Valley region had particulate matter above EPA’s allowable threshold (called nonattainment), it had to resubmit its state implementation plan (SIP) to address its pollution levels.
After the San Joaquin Valley region submitted its SIP, EPA determined that the proposed control measures for addressing particulate matter didn’t go far enough, because they didn’t consider zero-emissions technologies for heating systems, even though they were already readily available elsewhere. This means that, by extension, regions across the country will face a strong federal push to clean up pollution, to the benefit of everyone breathing indoor (and outdoor) air pollution from buildings.
While EPA has not yet finalized the status of San Joaquin Valley’s SIP, the science and law are clear—and each time a SIP is due in an area not attaining air quality standards, there’s an opportunity to clean our air and upgrade our buildings with more efficient–and healthier– appliances. For example, California’s statewide SIP now includes a commitment to adopt zero-emissions appliance standards—further demonstrating that zero-emissions appliances can and should play a role in improving air quality under the Clean Air Act.
Other nonattainment areas—those that have not achieved current or past NAAQS—also have the opportunity to take similar action to strengthen existing nitrogen dioxide, ozone, and fine particulate matter (PM2.5) standards. There are several upcoming SIP deadlines for ozone nonattainment areas, including Baltimore, Chicago, and Philadelphia. By EPA’s logic, these areas should consider zero-emissions appliances in the suite of measures they submit in these plans. In doing so, states can commit to reducing pollution, as mandated by the CAA, while simultaneously decreasing fossil fuel pollution, and improving the health and housing outcomes of their residents.
States that are in compliance with federal air quality standards can also go further. States can enact stricter standards through their SIP, in support of maintaining their attainment status for existing air quality standards. They can also pursue stricter regulations outside of the SIP process by designing and implementing their own standards that go above and beyond those required by the current NAAQS. Strengthening these standards is good for states that have yet to comply with them—and states that are already making progress can go even further to protect the health and safety of their residents.
All of this regional progress can set the stage for national action by showing how we can decarbonize buildings under existing regulatory authorities. And state and local leaders can push that action forward via another lesser-known power granted to states under section 111(g) of the CAA, which allows governors to petition EPA to set standards for new sources of air pollution, like fossil fuel appliances. To date, no governor has exercised this authority. Submitting this petition would jumpstart the process for more formal regulation of fossil fuel appliances nationally.
These authorities will be essential for cleaning up our air and improving housing quality by increasing access to cleaner household appliances.
