Quantifying True Source Control from Brake Copper Law – Urban Runoff Copper Reduction Timeline
This presentation, which describes part of CASQA’s Source Control Initiative, will demonstrate a method for developing scientifically sound quantitative estimates of source control-generated pollutant load reductions. This method is appropriate for use in the regulatory context. In California’s most urbanized watersheds, brake pad copper is estimated to comprise more than 60% of all copper in urban runoff. To protect water quality, a 2010 California law requires near elimination of copper in vehicle brake pads by 2025. The state enacted this law in response to efforts by CASQA and other members of the Brake Pad Partnership. Many California municipal urban runoff programs are relying on this brake pad copper reduction mandate in their plans to comply with requirements to reduce copper in urban runoff. Brake pad copper reductions are already underway, well ahead of regulatory deadlines. Average brake pad formulation copper content—currently 5.6%—has dropped about 30% since 2006. “Copper-free” (<0.5% copper) brake pad formulations have become widely available, comprising >40% of all available formulations. Anecdotally, it appears that most of the vehicle industry is planning to transition to <0.5% copper brake pads prior to the first compliance deadline in 2021. To support compliance assurance planning, CASQA is preparing quantitative estimates of anticipated urban runoff copper reductions, by year, that will occur as a consequence of brake pad reformulation. Due to the nature of the vehicle supply chain and brake pad lifetimes, brake pad copper reductions will occur gradually over a period of about twenty years. Simplistic copper reduction estimates that are often bandied about tend to underestimate near-term copper reductions. Such estimates do not serve the regulated community well, nor do they engender trust among regulators and other stakeholders. CASQA has a solid scientific methodology for estimating upcoming copper load reductions in urban runoff. In 2013, estimates using the same methodology were prepared for two Los Angeles County watershed groups. The Los Angeles Regional Water Quality Control Board accepted the estimates after a detailed review of the estimation method. The spreadsheet-based computational method used publicly available data, scientific information, and assumptions based on Brake Pad Partnership information. To bracket uncertainties in brake copper reduction timelines, three reduction scenarios were developed and carried through the calculations. The 2013 estimates with this methodology indicated that by 2020, urban runoff copper loads should be reduced 17-29% as compared to a 2013 baseline. The maximum estimated urban runoff copper reduction (about 60%) should most likely be achieved between 2024-2028. Updated load reduction estimates incorporating recent data will be provided at the conference. CASQA plans to track the pace of brake pad copper reductions through Washington Ecology’s “Report of Industry-Wide Average Brake Pad Formulation Copper Content” and through brake pad formulation certification data, both of which are available on the Internet. CASQA will also track the State Water Board Surface Water Ambient Monitoring Program (SWAMP) Sediment Pollution Trends (SPoT) contaminant and toxicity monitoring program, which has an extensive statewide baseline data set, adjusted monitoring frequencies based on statistical analysis of the quantitative copper reduction estimates published in 2013. SWAMP SPoT altered its monitoring design to provide a means to track copper reductions in receiving waters and to provide timely information on the changes in receiving waters resulting from brake pad copper source control.
Dr. Moran is President of TDC Environmental, LLC. She specializes in True Source Control to prevent water pollution. Two organizations that she founded – the Brake Pad Partnership and the Urban Pesticides Pollution Prevention Partnership – facilitated development of effective and widely accepted approaches to end costly urban water pollution. Dr. Moran’s extensive public service includes serving as co-chair of the California Green Ribbon Science Panel, which advises the state on chemicals policy. Her work draws from a strong scientific education, capped with a Ph.D. in Chemistry from U.C. Berkeley.