Question 6 - Impacts on Air - Full EAF (Part 2)
Full Environmental Assessment Form (FEAF) Workbook
The proposed action may include a state regulated air emission source.
Air pollution can harm human health, and damage elements of the ecosystem. Exposure to air pollution is associated with numerous effects on human health, including pulmonary, cardiac, vascular, and neurological impairments. High-risk groups such as the elderly, infants, pregnant women, and people with chronic heart and lung diseases are more susceptible to air pollution. Children are at greater risk because they are generally more active outdoors and their lungs are still developing.
Air pollutants are produced by many human activities. Most pollutants come from industries that manufacture chemicals and other goods, from on- and off-road vehicles and power equipment, and from energy facilities that burn oil, gas, or coal.
The Federal Clean Air Act and Article 19 of the State Environmental Conservation Law provide the framework for the State's air pollution control program. Article 19 of the ECL was enacted to safeguard the air resources of New York against pollution; and to ensure the protection of the public health and welfare, the natural resources of the State, physical property, and industrial development. It is the policy of the State to require the use of all available, practical and reasonable methods to prevent and control air pollution in New York. To facilitate this policy objective, the Legislature bestowed specific powers and duties on the Department of Environmental Conservation including the power to adopt and promulgate regulations for preventing, controlling and prohibiting air pollution. This authority specifically includes establishing standards for the coordination of State and Federal air pollution programs.
To answer this question
If information from the applicant, or from Part 1 already identifies that an air emission from the proposed project is one that is state regulated, check "yes" and then answer sub-questions (a) through (f). However, the reviewing agency may alternatively need to first evaluate and answer the sub-questions (a) through (f) in order to know if emissions are state regulated. These sub-questions are largely 'yes' or 'no' answers and will assist in more fully identifying which ones, or how much of potential air emissions will be generated. Taken together, these sub-questions will determine how question 6 should be answered. If the reviewing agency has information from Part 1 that indicates no state regulated air emissions are part of the proposed project, then check 'no' and move to Question 7.
Identifying potential impacts
The reviewing agency should evaluate the following sub-questions and decide if there will be any impact. If there will be an impact, the reviewing agency must then evaluate the magnitude of that impact, and decide if the impact will be small or moderate to large. This will depend on the overall scale and context of the proposed project as described in the Introduction to Part 2. The reviewing agency should be reasonable when conducting this review.
- If the proposed project exceeds a numeric threshold in a question, it is presumed to be a moderate to large impact.
- If the proposed project does not exceed a numeric threshold in a question, the reviewing agency should consider the scale and context of the project in determining if an impact may be small or moderate to large.
- These sub-questions are not meant to be exhaustive. The reviewing agency should use the "Other impacts:" sub-question to include any additional elements they feel need to be analyzed for potential impacts.
Applicable Part 1 Information
Answers to sub-questions (a) through (e) all offer information that will help the reviewing agency identify risks and hazards that may occur. Most of these are 'yes' or 'no' questions.
DEC's Division of Air Resources is an important resource that a reviewing agency should use to help assess potential impacts of air emissions. It is not expected that reviewing agencies do that assessment, but they should call upon others that do have the expertise to help them evaluate risks associated with air emissions. See the DEC web page: Interested Agency and Public Involvement for more information.
The National Park Service (NPS) has published a short 24 page document: Technical Guidance on Assessing Impacts to Air Quality in NEPA and Planning Documents. This report was developed specifically for use by the NPS. However, the analytical process outlined in chapter 4 can be easily applied to a much broader range of projects. These steps are summarized here:
- Determine the level of analysis needed
- Describe the types of pollutants proposed to be emitted
- Estimate proposed emission levels
- Consider the distances from the source to potential impacts
- Obtain current air quality information
- Assess the potential impact levels
- Consider impacts on human health
- Consider impacts to flora and fauna; soils and water
- Consider impacts to visibility, buildings, and infrastructure
In addition to the sub-questions, answering the following will assist the reviewing agency in determining the size and importance of these impacts.
- What is the air pollutant and what are the risks with exposure?
- What type of mitigation is being proposed to minimize the risks associated with exposure to the air pollutants?
a. If the proposed action requires federal or state air emission permits, the action may also emit one or more greenhouse gases at or above the following levels:
i. More than 1000 tons/year of carbon dioxide (CO2)
ii. More than 3.5 tons/year of nitrous oxide (N2O)
iii. More than 1000 tons/year of carbon equivalent of perfluorocarbons (PFCs)
iv. More than .045 tons/year of sulfur hexafluoride (SF6)
v. More than 1000 tons/year of carbon dioxide equivalent of hydrochloroflourocarbons (HFCs) emissions
vi. 43 tons/year or more of methane
b. The proposed action may generate 10 tons/year or more of any one designated hazardous air pollutant, or 25 tons/year or more of any combination of such hazardous air pollutants.
c. The proposed action may require a state air registration, or may produce an emissions rate of total contaminants that may exceed 5 lbs. per hour, or may include a heat source capable of producing more than 10 million BTU's per hour.
d. The proposed action may reach 50% of any of the thresholds in "a" through "c", above.
e. The proposed action may result in the combustion or thermal treatment of more than 1 ton of refuse per hour.
Will there be an impact?
Once it has been determined that the project involves air emissions that may pose a risk to human health, it is unlikely that there will be situations where there are no impacts at all related to those emissions. The agency may determine that there may be very small risks or that impacts are deemed to be not significant. However it is not likely there will be situations where there will be no impacts at all.
The size of the impact depends on a variety of factors. For instance, the emission rate, type of pollutant, and location in the environment all have bearing on the determination if the impact will be small, or moderate to large. The reviewing agency should look carefully at all of the information provided by the applicant and ask appropriate questions.
A small impact could occur under one or more of these circumstances:
- Polluting air emissions will take place, but the emissions will be at a level that will not affect pollution levels off-site.
- Polluting air emissions will take place, but the emissions will occur rarely, for short intervals of time, and the source is not located near a potentially conflicting use, such as a school, hospital, day-care center, or park.
Moderate to Large Impact:
A moderate to large impact could occur under one or more of these circumstances:
- The reviewing agency answers 'yes' to any of the (a) through (e) sub-questions.
- Air emissions will take place, and the emissions will be at a level that will affect pollution levels off-site.
- Air emissions will take place, and the emissions will occur on a regular basis, for long periods of time
- Air emissions will take place, and the source is located near a potentially conflicting use, such as a school, hospital, day-care center, or park.
f. Other impacts:
There may be other impacts identified by the reviewing agency that are not addressed by the above questions. If so, they should be identified and briefly described here.
Some proposed actions may have beneficial impacts on the environment. The reviewing agency can use the 'other' category for that purpose, too.
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