Enhanced Compliance, Enforcement, and Ambient Monitoring
Section 7.6 of the Resource Manual summarizes the federal, state and regional regulations and roles in air quality management. Most notably, these include: MDEQ’s construction and operating permits that may include limits on emissions, and requirements on the facility, process, fuel and/or feedstock to limit emissions and comply with ambient air quality standards and guidelines; reporting, disclosure and emergency planning requirements; and MDEQ’s inspection, monitoring, analysis, and assistance programs. Additional strategies to improve compliance and enforcement with air quality goals include: routine incorporation and use of health impact and cumulative impact analyses to investigate and potentially quantify health risks and impacts; transitioning to a regulatory focus on public health and safety, rather than compliance; periodic integrated and long range air quality planning; additional funding to support technical staff and inspectors to increase the frequency and stringency of inspections and monitoring; increasing notification, information and transparency throughout the permitting process; providing external technical assistance for communities; increasing opportunities for meaningful public participation; increasing the stringency of permits and practices to reduce emissions from point, non-point, non-road, and fugitive sources, including lowering allowable emissions to approach actual emissions; improving emissions inventory data, particularly for PM and toxics; and requiring additional emissions monitoring and testing for industrial facilities to better understand actual emissions.
Ambient monitoring measures existing air quality in order to understand concentrations, exposures and health impacts. In addition, monitoring determines compliance with ambient air quality standards, and can help identify culpable (or contributing) emission sources. Monitoring provides the best data for community members to know what is in the air they breathe, to track trends, assess the adequacy of controls, and evaluate the performance of the overall air quality management strategy. Section 7.6 of the Resource Manual describes current ambient monitoring conducted in the Detroit area. Monitoring site locations and parameters are selected for specific reasons, e.g., some sites sample near-road and industrial impacts, while others represent the exposure of the general population. MDEQ conducts most of the monitoring in the Detroit area, which includes regular (often continuous) measurements of PM2.5, NOx, CO, O3, and lead (Pb). A small number of sites measure additional parameters, including diesel exhaust, bioaerosols, ultrafine PM, reactive species, metals, and organics. Several additional monitoring sites are operated by Marathon and other industries. MDEQ is siting an additional monitor in Southwest Detroit to respond to citizen requests. In addition, a number of special monitoring studies have been conducted by state and academic researchers to better understand air quality issues in the Detroit area, and the recent emergence of low cost monitors and sensors has enabled a number of communities to actively monitor air quality. Additional monitoring strategies include: increasing industry monitoring, including “fence line” monitoring at the facility boundary; expanding the SO2 monitoring network since SO2 “hotspots” tend to be very localized and potentially missed; identifying monitoring gaps using a structured process with public input; applying remote sensing and other techniques to develop spatially-resolved understanding of pollutant exposures; providing further analyses of collected data to understand trends and apportionments; deploying permanent or transportable ambient monitoring equipment to understand spatial impacts from particular sources, particularly heavy industry in Southwest Detroit, with sufficient data to develop annual average concentrations of toxics; providing funding and in-kind support for low-cost and community air monitoring, and enhancing MDEQ’s websites and public information to allow more informative displays of source emissions and ambient monitoring results.