The state is currently trying to use the 179B waiver to account for total ozone emissions. This loophole in the Clean Air Act allows states to claim that they would have met the requirements for clean air if not for emissions from outside the US. However, in 2021, the EPA rejected the state’s attempt to blame China for its ozone nonattainment as insufficient. 

We appreciate the state’s efforts to regulate the industrial sources we control in Utah. We should prioritize these programs instead of wasting resources and avoiding compliance with attainment levels. While ozone can cross state borders and is soon to be regulated through the CSAPR rule, the state’s initial modeling showed limited contributions from international sources. 

Chemical solvents are responsible for more than double the amount of ozone compared to vehicles in the Northern Wasatch Front (NWF). Despite the state’s efforts to limit motor vehicle emissions, no concrete programs have been put in place to address solvent usage. Reducing the use of solvents could significantly decrease ozone levels in our airshed. According to the NWF Ozone Moderate SIP, current regulation R307-357 is aligned with the federal Ozone Transport Commission model rule. However, some states are proposing stricter regulations on solvents that emit VOCs, which are harmful precursors to ozone. It’s crucial for the State of Utah to assess the risks that solvents pose to public health and the environment, just as other states are doing.

Utah has already restricted the use of some of these chemicals in industrial and commercial settings. Regulating these solvents can have additional health benefits by reducing carcinogenic exposure. Utah can further regulate these areas to address the issue of ozone emissions.

California has some of the strictest solvent regulations in the country, banning several solvents on top of current EPA regulations such as methylene chloride, tetrachloroethylene, trichloroethylene, toluene, chloroform, methyl ethyl ketone (MEK), ethyl acetate, isopropyl alcohol, acetone, butyl acetate, and methyl ibutyl ketone (MIBK). It also requires the use of low-VOC solvents in various applications.

Similarly, New York, Vermont, Oregon, and Massachusetts have banned similar solvents and require the use of low VOC solvents in many applications.

 Professor John Horel is currently conducting research at the University of Utah on the effects of exposing more of the Great Salt Lake Playa. This exposure can lead to increased heat and reflectance from sunlight off of the lakebed, which catalyzes the reaction of pollutants in the air and results in the production of a significant amount of ozone. To address this issue, the DAQ could collaborate with the newly formed office of the Great Salt Lake Commissioner, demonstrating a good-faith effort to address ozone precursor and ozone generation in the larger context of the Great Salt Lake’s water and air issues.